ML20204G573

NRC Staff Third Set of Interrogatories & Request for Production of Documents to Towns of Amesbury,Newbury, Salisbury,West Newbury & Merrimac & City of Newburyport....* W/Certificate of Svc.Related Correspondence

ML20204G573
Person / Time
Site:	Seabrook
Issue date:	10/06/1988
From:	Bergquist S NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	AMESBURY, MA, MERRIMAC, MA, NEWBURY, MA, SALISBURY, MA, WEST NEWBURY, MA
References
CON-#488-7309 OL, NUDOCS 8810240155
Download: ML20204G573 (20)

Text

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t RCtAno connespopp D N.E,:.i c r?

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'83 OCT 19 P 4 :0()

BEFORE TFE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of

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FUELIC SERVICE COMPAN) 0F Docket Nos. 50-443-OL NEW HAMPSHIRE, et al, f 50-444-OL (Seabrook Statien, Units 1 ard ?) )

NRC STAFF'S THIRD SET OF INTEP.ROGATORIES AND Rf0 VEST FOR PRODUCTION OF DOCUPENTS TO THE T0kh5 0F AMESEl'RY, NEkTt'RY, SALISBURY, WEST NEWEURY, AND PEPPIPAC, TFE CITY OF NEWBURYPORT, AND THE

_COMfi0hKEALTH OF MASS AC,H_USETTS CONCERNING SFMC CONTENTIONS Purstent to 10 C.F.R. 16 2.740b and 2,741, the NRC Staff hereby requerts that the towns of Amerbury, Newbury, Salisbury, West flektury, and Perrimac, the City of Newburyport ('In*.ervenor" cr "Intervenors") and the Comorbeelth of Massechuse+ts ('Cornmonwealth", as herein defined) individ-ually respond to tre following interrocatories, and produce for inspectiori and ccrying the deceents requested belw.

Eich irterrcgatory shel' ba answered separately and fully and shall include all pertinent information available to the above-noted parties, l their officers, erployees, directors, advisors, representatives, or counsel, based upon the personal knowledgc of the perser answering, The prcduction of the documents requested herein shall take place at the hearing fivisire, Cftice of the General Coursel, Nucleer Regulatory Comissior.,11555 Rockville Pike Reckville, Paryland, 8810240155 001006 3 PDR ADOCK 050 0

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Instructions A. To the extent that you do not have specific, complete, erd accurate information with which to answer any interregatory, you should so state; and the interrogatory should be answered to the extent information is available, identifying each person who is believed to have accurate informatinn with respect thereto. Fhere exact information is not avail-able, estinated informatict should be supplied; in that event, the answer should state that the information is an estimate and should identify the basis ch which the estimate was made. Where appropriate, the upper and lower hcundaries, cf the estirete should be given.

B. E6ch interregatory shall be deemed to be continuing, and you are requested seaseratily to supplement your answers with additional facts, docurrerts, inferration, and nar'es of witnesses which become knewn, in accordarce with 0 2.740(e)(l' ard (2) of the NRC's Rules of Practice.

C. The words 'and" and "or" shall be construed either conjunctively cr disjunctively so as te bring within the serpe of these discovery requests ary information tha+ night otherwise be construed to be outside their scope.

D. Wherever apropriate, the singular fom of a werd shall te interpreted in the plurcl, and vice versa, so as to bring witlin the scope of these dirrevery requests any inferration that might otherwise be construed to be outside their scept.. I E. Wherever appropriate, the retruline fom of a word shall t;e irderpreted at feminine, erd vice versa, so as to bring within the scope i

of these discovery requests any information that might otherwise t'e censtrued te it cutside their scope.

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F. Please produce each document in the form and condition in which l

it exists on the date of service of this request, including all coments, notes, remarts, and other material that may have been added to the docu-1 f l rent after its initial preparation. l 1 ,

G. If you ebject to or claim a privilene (attorney-client, work product, or other) with respect to any interrogatory or document rec;uest, 4 in whole or in part, or seek to withhold documents or information because .

j cf the alleged preprietary nature of the data, please set forth all f

] reasers and the underlying factual basis for the objection or claim of privilege in sufficient detail to pennit the Licensing Board to determine j the salidity of the objection or claim of privilege. This description f l rheuld include with respect to any docur:ent: (1) author,addressor,  ;

I j eddre.t.ee, recipients of indicated and "blind" copies together with their l 1 '

l fob titles; (2) date o' preparation; (3) subject natter; (4) purpose for I which the docurent was prepared; (5) ali persons to whom distributed,

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shown, nr explained; (6) present custodian; (7) all persens believed to  ;

i beve a copy of the docunent; ano (B) the reture of the privilege er {

i ctjectier, esserted.

P. For any dccument or part of a docurent that was at one tine, tut l j is no lenger, in your pcssession, custody, or ccrtrol, or which is no i

longer in existence, or which cannet be located or produced, identify the

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i decurent, state where and how it passed out of existence or why it can no longer be located end the reasons therefor, and toentify each person  !

, ht.ving knowledge concerning such disposition or less and the contents of )

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! the docunent, and ideritify each document evidencing its prior existerce j and/or any fact concerning its ncrexistence or loss.

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j I, khen, in order to answer a question fully or accurately, it is  !

i i necessary to distir.guish between the responses of individual Intervenors  ;

i er identify individuel Intervencrs, such distinctions or identifica. l l

i tions should be made in the answer, j

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i l Cefinitier.s and Guidelines to be Used  !

j in Resp,onding to this Reque,s_t l i  :

i 1. The verd "actions" or "action" shall mean any task or act which would  ;

i er right be perforced by you, the Comonwealth and/cr any Intervenor (as  !

I j herein cefined) in the event of a radiological emergency at Seabrcek i l Station includirg, but not linited to, assessing accidents, mitigating I

l harn from an accider.t. giving nctice to the public, protecting the public j i

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} by any reer.s whatsoever, traffic centrol, radiological monitort,9g, and I J l cerrunicatters.  !

]  ?. The word "Comonwealth" shell mean the Cerronwealth cf hassachusetts, l 4 i er cry departunt, agency, subdivisien, employee er contractor er  !

i consultent of the Cerronwealth, and any municipality, tchn, township, ,

county, or other governrental unit of general or limited jurisdiction in j the Ocmonwealth, f

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! 3. The werd "document" as used herein shall meer any written matter,  !

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j whether proc'uced, reproduced or stored on paper, cards, tepes, disks,

belts, charts, films, cceputer storege devices nr any other r.edium and l

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thall include, without ifmitation, retter in the form of bocls, reports,  !

studies, statements, speeches, retebooks, agreements, appointnent (

l calendars, working papers, raruals, memorerda, notes, procedures, orders, j l

j instructions, directioris, training raterials, records, correspondence, '

l diarics, plans, diegrams, drawires, periedicals, lists, telephene legs,  ;

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rirutes, photcgraphs, and any published naterials and shall also include, l l without limitation, originals, copies (with or without notes or changes l j thereon) and drefts.  ;

4. The werd "communications" shall mean correspondence, contact, l

f discussion, or any other kind of written or aral exchange between two or f i

rore persors or entitict including, but not ifmited to, ell telephone i

! conversations, face-to-face r.eetings or conversatiers, visits, l I  !

1 conferences, internal and external discussions, and exchange of a document  !

or decuraents ,

t i j 5. The Sttff reouests that documents produced in compliarec with this i  !

j reques* he accompanied with an indicatien as to the particular paragraphs  ;

1 j under which the documents arc being produced.

6. The werd "emergencies" sht.'1 rear radiological and norradielegical l

i emergercies, ard shall include all natural and "mannade" disasters such as  !

1

) fleeds, tornedees, fires, hurricanes, earthouakes, riots, irdustrial

! f i accidertt., transporte. tion accidents, acciderts involving radiation or

} l radiolegical materials, and accidents involving any other hazardous or j t

dar,gerous materiels. i

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7. "Intervenor" er "Intervenors" means the Corronwealth of (

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l l'assachusetts, the tet.ris of Amesbury, Newbury, Salisbury, West Newbury, f L

j t.rd Ferrinac, ano the City ef Newburyport, or any cf then, or eny agency 1

l' thereof, erid any agent, er.plovae, censultart, contractor, technical l cdvisnr. representative er other persen acting fer or on behalf of them, j i i or at their direction and control, or in concert with or ass 4 ting them.

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C. "Contractor" means any person, ret affiliated with the Comonwealth or Interveners, who perforred work coricerning Seabrook or, behalf of the 4

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Corronwealth or Intervenors and/or pursuant to a contract with the Connenwealth or Intervenorst or sub-contractors who performed work en behalf of a contractor with when the person was not affiliated and pursuant to e ccr, tract with such contractor. A person other then a contractor, who contractr. with the subcontractor, shall be deemett a subcontractor.

l 0. 'Cercerns," *ccreerning," cr any other derivative thereof, includes referrirs to, respcoding to, relating to, pertainino to, in connection with, comprordring, reroriali:ing, cercenting on, regarding, discussing, 1

shewing, describirg, reflecting, analyzing, supporting, contradicting, and constituting.

10. "Ycu" or "your" reans the Cerronwealth cr Interver.cr to whom these f riterregateries anc cocur.ent reaver,ts are addressed, or any agency i thereo', trt any agert, taployee, consultant, contractor, technical t.cvfror, representative or other persen acting for or on behelf of them, or at tho'r directiori and control, or in cor. cert with or asristing tb m.

11. "Identify" when usu' in refererte to a naturei person reens to set l for th the fellowing:

1. his nare;

p. his last br.cwn residential addrest.;

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2. his last known business address;

a. his lest employer;

!. his title or pcsition; '

6. his aree et retnonsibility;

7. his buttress, professional, or other relationship ritt 1

Intervenors; etc

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! I j 8. if any of the above infomation is changed subsequent to (

the tir.e period referenced in a particular interrogatory, t 1 t l set forth in the answer, and label appropriately, current  !

j infomation as well as the informatien applicable to the f l t he period referenced in the interrogatory.

I t IP. "Identify" when used in reference to a corporation or other entity l

l that is not a natural person shall mean tc set forth the followirg:  !

1. the full narre of such persen, including its legal nere and i j any assured or trade nan.es under which it transacts or has 1 i i transacted business;

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i F. the nature or fom of such a person, if known; J j

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3. the cddress o' its principal place of business or the  !

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prircipal place where such person is to be found; j 4 whether the Cornterwealth cr Interveners have or hase bed t l i any relationship or affilittien with such person, its f I t

effiliates or subsidiaries, and, if so, a descriptien of  !

j such relattership; and i 1

!. if any o' the ahnve infermation has changed subsequent to the tire pericd refertrced in a particular interrogatory, j

{ set forth in the answer, ano label appropriately, current I i

inforretion as well es the infomation applictble to the tire referenced in the interrogatory.

13. "Ictotify" wher used in reference to a decument shall r:een to set i i

forth the following:

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) 1. its title; I

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-C-P. its subject matter;

3. its date; l 4 its e'Ither; -

E. its addressee;

6. its file designetton or other identi'ying designation; and

j 7. its present locatien and present custodian.

12 "Identify' with respect to a contact or comunication shall mean to I set forth the followirg

1. the date of the comunication; 0, tha place of the mak1rc or4 place o' receipt of the conmunicatien;

3. the type and mear.s of corrunication; 4 the substance of the ccerunication; l

! E. each percen raUng a cenitunicatinn, and his location at the i 1

tir+ the cerrunicatice was made; [

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(, each percen to whom the comunication was rade, ard his  !

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) location at tie tire the comunicetten was made; i

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7. all otber persons presert during, participatirg in, or

receiving the corecnication and the locatien of each such .

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l person et the tirt; I 1 I a L i

8. each dncurent coticerning such corrunice:icn; and 1 0, eacF doeur.ent ugeri which the cornunication is based er  !

P whier is referred to in the ccerunicatter. {

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4

9 Interrogatories ard Requests for Production of Documents

1. Define the tere "ad hnc" as it is used in any of your conten-

+1ons concerning the Seabrook Plan f or Passachusetts Comn4,nities (SPFC).

T. Identify anc list all ections to protect thc public in the event of e radiologitti er,ergercy at SeabroCI Station which -

a) you sculd take, b) yc u r,ight take.

c) you could take.

.t . Identify ard list all resources to take the acticns identified in response to the prier Interrogatory (Interrogatory hc. ?) yev -

(e) have.

(b) may havr.

l 4 Identi'y erd list all actions set out in 10 C.F.P., 9 SC.47(b) erd Sectier. II of NUREG-CC54 that ycu would rot take in the event of a tediological erergercy at Seabro-J.

f. State whether "ad hcc" actior's, as set forth fr your certentions tc be taker er which nigb' be taker in the event c' are accidert at f(t. brook, ir,clude any action that is ircluded in any plan, precedure, trarual, training n,att rials or try other occurent, whether or not thet dcct,r,ent was pt

• pared or is cesignated te be used in response to e radio.

leciet' erergttcy.

6. If the answer to interrogatcry 5 ir anyt" 99 other than an trc3alified "no" -

(a) Identify ard li!+ er) such do- ' 't, (b) is te cry such decur ' der t' fy the ' .u on to i tal er 'r whict right be teker, set out " - -

s fro .A

(c) Set eut the departrrent, municipality or other goverreental body which would take or riight take such action.

(d) Set cut the number of persons f ri each goverreental body who would take or reight take suet artion.

(e) Cescribe the trainir,(,, which any of those persons have received.

(f) Identify all training docurents or raterials used in the trairirg of such persons.

(c) Identify all equipment which is unde your possession er control which cculd be used in the event cf a radiological emergency at Seebrcok.

7. Ir. regard to Jcint Interverors' Contention 41, set out -

fe). The narre ard title of each official who has ste.ted or otheneise resitiuly indicatrd that he has r.o intentier cf irplerenting or folicwing the SPMC.

(b). The date are tFe fom in which such irdention was rade public.

'r.). The nau crd title of zl1 other officials respensible fer redirlet cal i preparedness in Metsachusette vbu have rot indicated such an intention.

(d). Define ttt werd "prepa*cdness" es usec in the Centention.

(e). Deffre the werd "response" er. usnd in tFe Contenticr.,

(f). List all dccuments or cther stattter.ts wherein you rade detemirations that adequate plarning is net possible for a reviolegicel emerger .y et Seabreen .

(g). Set eut the date when such decerents were prepared or $+atements were made and kho made er prepared such staterer.ts.

(h). Set eut the legal autt crity te rake the deterrinatiert in those statements.

8. In regard to Joint Interverers' Contention 42 -

(e). Set out all reasons that it is maintained that presumption in

10 C.F.R. I 50.47(c)(iii) should not be applied to the SPMC.

(b) In the event Seabrook is liter. sed, in order to see that emergency preparedress is not ir. complete or uncertain for Seabrook strerately siete what actions - -

(1) will ycu tele, (2) might you take.

(3) could you take.

(c) If you raintain ttat you do not krow what actions you will, right and/or ccold take, set out separately the rinimum actiers ycu -

(1) will take.

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) (2) nicht take.

(3) cculd take, i

(d) In the event Seabrook is licensed and in order te see that l erergercy preparec'ress is not inctcplete ct uncertair for Seabroci l '

! seperately state what pleor.ing -

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) (1; vill ynu perfom? l t  !

! (2) night you per'em*( .

J (3) could you perform?

(e) If you raintain that you do not krew what plerning will. Ficht

, ard/cr could Le perfortred, set out seperately what r.inimum planning l

you -

(1) vill perfom.

1 (2) might perfore.

4 j (?) could perfcm.

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l (f) Does a disavowal of knowledge of actions that you will, might or l I

could take riean that actions tn protect the public health and safety j will not be taken by you in the event of a radiological emergency et l l

Seabrook?  ;

(g) Does a disavowal of what planning you will, might and/or could perfom nean that you will not perform any planning for a j radiolcrical erergency at Seabrook should Seabrook be licensed?

4 (b) For nach protective action set eut in the SPMC - [

i i (a) Set out completel the nature of the actions you would take (

to protect the pu lic health and safety. j (b? Set out why you believe each of these actions would be more  !

efficacious in prctecting the public health and safety '

j than the detions set out in the SPMC. f I l (i) ftparateiy state all reasons why ytv believe taking ad hec l l

actions in regard to ar accident at Seabroot would be core J

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efficacieut in protecting the public health and safety than following l the SFliC. t i  :

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9. In regards to Joint Interveners' Centention 0 -

(a) Set cut all evidence that yeu have te rebut the presurption l

8 recittf in that contention.

l j (b) List all t'ccuments that will be offered as eviderce.

j (c) List all witnerses, and provide a futi statement of their testircry and their qualificatiens te give such tectirony, including {

l i a full statenent of tFrir expertise and training.

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1C. In regards to Joint Interveners' Centention 4 6 - I

! (a) Set cut all evidence you have en this Contentien.

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13 (b) 1.ist ell documents that will be offered as evidence.

(c) List all witnesses, and provide e full statement of their testircry cnd their quelificatiens to give such testimory, including  !

i e full staterent of their expertise erd training, j Id) Set out each ewner of Seabrook lictnsed to do business in Passachusetts.

(e) is New Parpshire Yankee or ary corporation aligned er connected to it lictnsed to dc business in Passachusetts? Identify all such (crepanies or ccrporatior4.

I (f) Defir.e the tem "ordinary course of bustress" as used in the ,

Contertien.

(g) St* eut all reesens why you raintain that the bankruptcy court I

i rus' approve energency preparedress activities for (1) New Harpshire  !

Yar,kee er.d (?) the Public Service Ce. of New Harpshire.

l (h) Set cut all previsions of the bankruptcy coce referred to as not pemittf rf the activities set out in the contention.

! (1) pefire the terfn 'celegation" as used in this contentier.. '

(j) Set out the besas fet tFe avement that the SN'C contemplates e l 'delegatier".

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(L) Ett out the nature of the delegation. l l (1) fet out all reasers whv yeu believe such delegitiens would te unlaw'ul.

11. In regard to basis A.1, to sleirt Interserers' Conten+. ion 44A -  !

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f t. ) Set cut the bcsis oper. which you assert the delegation may r.ct I i be to "a foreign private corporation',

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(b) is Public Service Co. of New Harpshire "a foreign private corporation"?  ;

(c) Is New Harpshire Yanlee a private foreign corporation?

(d) Set cut all evidence you have to support the clair that I

autherization eculd not be ghen to NHY 0P0 to irplerent the $rt'C.

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] (e) Provide all docurents supporting that assertion.  ;

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j (f) Frovide the rare of ell witnesses erd their testirnony you have

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to suprert that staterrert.

j (c) fit cut the qualifications of those witnesses including their 1

errrrtise cnd training. I

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(h) Defire the tem "authorire" as used in bt.fis A.1 to Joint j .

Interveners' Cortertien 44A.

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!  !?. In regard to basis A.P. to Joint Intervenors' Contentier 44A -

{ (a) Set out which of the list of 19 actions set cut in the l i certentior; are the 7 which applicarts' acknowledge it cariret perfom without euthoritetion frori th( governrert.  !

(b) Ptfire the term recorredations" as used in thir list of 19 i j items.

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1 (c)  !$ it rairtairied that NHY-0PO cannot riake recorredations to l J

j l'assachusetts or Nassachusetts efficials?

l (d) Is it rnatnteired tW NM ORO cannet voice reccrrrnendatient to l

] th( rublic? ,

i (e) Set cut the basis for your answers to the inediately preceding I

• interrogatories if ycu rairtcin such rectn endatiens cannot be.

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)1 r9adt.

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i (f) Or: tail and set out the sevrce of the prebibition on NHY-ORO naking such recorrerdations, i

(g) As to each of the in items listed in basis A.P. of Contentier  :

i 44A set eut what "best effort ections you would, could, or night

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l t a kt. ir the event of a radiolcrical erergency at Seabreek, i

i, Ih) In retard to the first listed item in basis A.O. -

(1) Can radio stations broadcasting from New Harpshire be heard in  ;

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l'assachusetts?

(?) If there are such statiers, list ell located within 50 niles of I W sachusetts that car be beard in the ftassachusetts pertion of the Seabrook EF2.

] (3) Vhat limitations exist, if ary, on New Hampshire Yannet asking l

stetiens in ?!ew Hampshire to broac'er.st emergency ressager in case of an accident at Seebrook?

j li) !n regard te tFr eleventh iten listed ir basis A.2 -

j (1) Khat limitations do y'ou clate will exist en Aeplicart should it reccioa a r PC license fer Seabrook ' rem asking fer Federal artistance? '

{ (?) Set cut the statements, or reguletions you clein support i

! your petition it this itera.

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(3) 5et u.t the basis of your position in this item, i i (j) In regard tri the twelf th itera listed in basis A.2 -

(1) Vbat litnitations do ycu claim will exist on Applicant a

theuld it receive a fFC license fron Seabrook to 1 cerrunicate the views of relevant governments te the public and third partiet?

I-(2) Set cut the statutes or regulations ycu claim suppert your

, pcsition in this iter.

l (b) Set cut the basis of your position in this iter, t

! (k) In regard to the thirteenth iten listed in basis A.0, -

(1) itat limitaticns exist er, Applicarts er NHY-ORO idertifyirs areef. cf dangeri 1

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(0) Khat limitettons exist on Applicar.ts or NHY-ORO determining

• l that there are areas from which the public should be i excluded? L i i j (3) that limitations exist on Applicants' communicating to you l 1 such identification or determinations?  !

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i (4) What limitatices exist on Applicants' comunicating to the public such identification or deteminatiers?

I (f) Set out the statutes or regulations you clain supports your  ;

petition and identify which part of your positier in regaro i to itern 15 you clairn each supports. '

(6) Set out the basis for your positinn on this iteci. f

{ (n) In regard to the eighteenth iter listed in basis A.P. - f f

1 j (1) Identify the individuals referred to, f (T) refine the term "behavirr" as used in the iten, f (3) Set eut the "behavier" claimed which will put others at irmediate ritk.

(A) Define in tems e.f time the term "imediate" as used in the i iten.

l (F) Define the term "rist" as used in the item. l 1

l (f) tet out the "t;ehavior" claimed that will irepede the j i irrplerentation of prntective reasures, j i

(7) Set out the prntective measures referred to.  !

i (P) Set out hew the behavier will ir"rede these retsures. l' l (9) Defir.e tho tent. "control" as used in the iten, j (10) khat will yeur law enfercement of#icials de or could they j dn to prevent the behavior referred to ir: this iter.,  !

13. In regard to basis f 3. to Joint Intervencrs' Contention 44A -

(1) Define the tem "purretry" as used in this baris, j (?) Give each reason why yeu would ret follow the directives er recoverdations of tmy-ORO personnel.

(3) lf you would not follow NHV-ORO recereendations uncer the SpFC, specifically icentify the actions which you believe

> would be more *fficacious to protect the public bealth and 1 scfety in the event of an accident at Seabrook that -

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- 17 (i) You would taka.

(ii) You rright take.

(iii) You could tale.

(4) Set eut each ranner in which such actions would be rnore efficacious thar follewing directives or recomendations of SFMC personnel.

l4. In regard to basis B to Joint Intervenors' Contention 4 U -

(a) Cc ycu raintain that, should Seabrook bo licensed by the NRC, actiers by NHY-CFO to protect the public health and safety in the event of an accident et Seabrook vculd be outside the ordinary course of business?

(b) Do you refrtain that it vould be frproper for LHY-0R0 to take such actions to protect the public health and safety in the event of ar cccident at Seabronk?

(c) Set out the factuel erd legal basis for your answers to perts (a) art (b) to thit interrogatcry.

(d) is it yeur positiori that the application for a NRC license for Seabrook is cutside the "ordinary course of business" for PSNH?

(e) 15 it your pcsition thet erergercy planning is recessary te obtain a license for Feabrook.

15. Produce a copy of each decurent respcnsive to, identified in response to, et concernirg the preceding interrogatories.

Respectfully subtritted, fk h< 4L Stephen A. Bergquist Counsel for hRC Staf' Dated at Rockville, l'aryland this (th day of Octeber 1900

w""n-UhlTED STATES OF AMERICA NUCLEAR REGULATORY CCf! MISSION BEFORF THE A, TOPIC SAFETY ANii LI, CENSING BOMED CCT 19 P4 :00 In the Patter of )

Docket Nos.brs fS-443- OL -

FUPLIC SERVICE CCMPANY OF E0-444'0L NEW H/PfSHIRE, e_t 1,.1 Off-site Emergercy Planning (Scabrook Statier, Units ! and 2)

P 4 CERTIFICATE OF SERV!CE

, I hereby ecrtify that ceptes of "NRC STAFF'S THIRD SET OF INTERROGATORIES AND t

REQUEST FOR FF0 DUCTION OF C0CUMENTS TO THE TOWNS OF AMESBURY, NEWBURY.

sal.!SBURY, l'EST NEWBURY, AND MERRIMAC, THE CITY OF HEWBURYPCRT, AND THE

CGMMONWEALTH OF PASSACHLSETTS CONCERNING S Ff'C CONTENT!0f:!" in the above-captiencd proceedirg have been served on the fcilowing by deposit in the United. States riati, first class or, as irdicated by an asterisk, by l deposit in the Nuclear Regulatory Comissier's internal trail syster, this 6th day of October 1988.

Ivan W. Smith, Chairman

• Atonic Safety ard Licensing Acn.it istrativt Judge Boarc Parel (1)*

Atomic Sefety erc' Licensing Beard U.S. Nuclear Regulatery Corr issicn U.S. Nuclear hsulatory Comission Washington, DC 20555 Washingten DC 20555 Docketing ar.c Service Section*

i Gustave A. Licenberger, Jr.* O'fice c' the Secretary I

Administrative Judge U.S. Nuclear Regulatery Comissier Atonic Safety and Liccrsing Beard Washington, DC 20555 j U.S. huclear Pegulatory Commissinr. '

Pashingter', CC 20555 Threas 6. Picran, Jr. , Esq.

l Rcbert K. Gad, !!!, Esq.

l Dr. 1 err," Harbour' Repes 3 Gray Ac'ninistrative Judga  ??5 Franklin Strret i Atoric Safety & Licensing Beard Boston, PA 0?l10 i U.S. fleclear Reguletery Comission i Washiroton, DC 20555 H. J. Flyer, Esq.

Assistant General Counsel Atoric Safety anc Lic ensing Federal Emersercy Managerent Agency i irreal Panel (5'* E00 C Street S.W.  !

U.S. Puclear Regulatory Cemission Washington, JC l0472 Washirgton, OC 20!55 4

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Philip Ahren. Esc. Calvin A. Carrey Assistant Attorr.ey General City Hall Office of the Attorney Gereral 126 Daniel Street State House Station Pertsmouth, NH 03P01 Augusta, PE 04333 Pr. Angie ffachiros Chairran Carol S. Sneider, Esc. Peard of Selectren

Assistant Attorney General 25 High Road Offite of the Attorney Genert1 1

flewbury, l'A 09150  ;

One Ashburton Place, 19th Flcer Bosten,la 02108 Allen Larpert civil Defense Director Gecrge Cana Bisbee, Esq. Tevn of Brentweed ,

Assistent Attorney reneral .90 Franklin t Office of the Atterrey General Exeter, NH 03023 l l 05 Capitol Street Concord, FF 03301 Filliam Armstreng Civil Defense Director Ellyr P. Weiss Esq. Town of Deter Diane Curran. Esq. 10 Front Street

Harrer I l'eiss Exeter, NH 03833

. .001 S Street, tv Suite 430 Gary W. Holres. Eso.

j Washirc+en. DC 70000 Holmes & Ellis l 47 Winracunnet Pcad i Robert A. Cackus. E:r,. Harspton, NH 03842 9eckus, Meyer 1. Soloren 11C Lowell Strtet J. P. Nadeau

,  !!anchetter, NH 03100 Board of Felectmen i

10 Central Strett i i Peul t'cEachern, Esq. Rye, NH 03870 fatthew T. Oreck, Esc.

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Staines & McEechern .1udith H. Mizner Eso, 75 Maplevecd Avenut 541verglate, Gertner, Eener.

P.O. Box 360 Fire A Good i Portsmouth, hF 03801 FE Eoard Street I

) Eesten, PA 02110 l Charles P. Grahan, Esq. l 1 McKay, Furphy A Gratam Robert Carrigg, Chainran

) l 100 Main Street Board of Selectrren  ;

Aresbury, MA 01913 Town Office Atlantic Avenue  ;

4 Sandra Cavutis, Cteirran Nerth Hampton, hH 03070 '

l Board cf Selectr.or '

RFC tl, Enx 1154 l Kensington, NH 030:7 1

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, ,, l'illiam S. Lord Peter J. ftatthews, Payor F, card of Selectren City Hall Towr, Pell - Frierd Street Newt'uryport, PN 09150 Amesbury PA 01913 Michael Santesuosso, Chairman firs. Anne E. Geode.an, Chairman Board of Selectren ,

Ceard of Selectrr.en South Hampton, f!H 03827  !

10-15 f.'emarket Road Durhan,f:H 03824 Ashed N. Amirian, Esq.

J Town Coursel for Merrirac Hon. Gorcor. J. Purphrey 370 Main Street l'nited Statts Senato Haverhill, P/ C8130 531 Part Senate Office Building l

Washingten. DC 20510 i Richard R. Oor,ovan Robert R. Pierce. Esq.

, Federal Erercency Managerent Agency Atomic Safety and Licensing '

Federal F4pienal Center Board Parel 130 itsth Street, S.W. U.S. Nuclear Regulatory Cernission Bothell, Vashingtort 96021-979C Washington, D.C. 20555

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]Ch It'epher, s. Pergquist #(

cGig,f I l

l Ceursel for NRC Staff '

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