ML20205D672
| ML20205D672 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/24/1988 |
| From: | James Smith PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#488-7331 OL, NUDOCS 8810270171 | |
| Download: ML20205D672 (21) | |
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DCLKETE0 uwe UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISCION gF r'.r '
C t.r vi before the ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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Docket Nos. 50-443-OL PUBLIC SERVICE COMPANY OF
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50-444-OL NEW MAMPSHIRE, et al.
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Offsite Emergency
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Planning Issues (SeabJook Station, Units 1 and 2)
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APPLICANTS' MOTION FOR SANCTIUNS AGAINST MASSACHUSETTS ATTORNEY GENERAL
("MASS AG') FOR FAILURE TO COMPLY WITH THE BOARD'S PROTECTIVE ORDER THE MOTION Applicants move, pursuant to 10 C.F.R. 5 2.707, that the Bodmd dismiss JI Contentions 45, 55 and 58 and their bases to the extent they go to the issue of the willingness of the bus companies relied on by the Seabrook Plan for Massachusetts Communities ("SDMC") to respond to a radiological er.ergency.
The sanctions sought are necessary, fitting and proper for the repeated failure of Mass AG to comply with the letter and spirit of the "aard's Memorandum and Order (Protectina
- Infor, 1 Froa Public Disclosuttl, ASLBP No. 82-471-02-OL (March 23, 1988) ext.ending the Protective Order approved and ordered on February 17, 1988, Memorandum and Order (Revisina Schedule and Acorovino Protective Order), ASLBP No. 82-471-8810270171 gajop4 hDR ADOCK 0500o443 3
PDR h
02-OL, requiring Mass AG to withhold designated information from public disclosure.
BACKGROUND On September 18, 1987 Applicants filed with the Nuclear Regulatory Commission its SPMC from which certain information j
had been redacted.
In its decision of November 25, 1987, the Nuclear Regulatory Commission held that the SPMC satisfied the commission's policy concerns about adequate emergency planning for Massachusetts communities within the Seabrook I
Station EPZ prior to authorization of low power operation of Seabrook Station.
Public Service comoany of New Hamoshire (Seabrook Station, Units 1 and 2), CLI-87-13, 26 NRC 400, 404 (1987).
The Commission noted, inter alia, however, that "as a condition of low power operation, the Licensees must provide to the Staff and FEMA any of the deleted information that the Staff and FEMA deem necessary for the detailed full-power review of the emergency plan."
Id. at 405.
The commission also contemplated the need for a protective order to prevent unnecessary violations of perscul privacy.
Id.
i In December 1987, Applicants provided t}.e StTff with the 1
information deemed necessary, together with a request that the Staff preserve the confidentiality of the information.
In December 1987 and January 1988, giving further effect to the Commission's Decision, 14. at 406, Applicants offered to make the same information available to Mass AG and other
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.l intervenors in the Seabrook proceedings, under protective order.
(2/10/88 II. 8401).
The offer was not accepted until 4
l February 10, 1988.
(2/10/88 II. 9725).
After discussion among the parties at the hearing and circulation of Applicants' proposed form of protective order, this Board entered a temporary Protective order, which prohibited public j
disclosure of the confidential information.
Memorandum and Order (Revisina Schedule s..a Ancrovina Protective Order),
ASLBP No. 82-471-02-OL (February 18, 1988).
This temporary Protective Order was extended until the beginning of the evidtntiary hearing on the SPMC, or until further order of the Board.
Memorandum and order (Protectina Information From Public Disclosure), ASLBP No. 82-471-02-OL (March 23, 1988).
DISCUSSION Mass AG has exhibited an ongoing disregard of is Protective order and an order of similar tenor issued by the Onsite Board.
Mass AG's first contumacy occurred at the public meeting called by Richard Donovan, FEMA RAC Chairman, to receive the views of the participants and the comments and questions of the general public attending with regard to the General Exercise of the NH and SPMC offsite Response Plans and Preparedness on June 28-29, 1988.
The meeting was held on July 2, 1988, at Portsmouth, N.H.
The format of the public hearing provided, inter A311, for taking written questions from the audience and responding to them at the 3
l f
hearing or subsequently by writing.
A Mass AG authorized f
person was among those at the meeting submitting questions.
f d
i l
several of these questions sought public disclosure of l
t confidential, protected information, which disclosure would l
violate the very reason and purpose of the Board's order.
l Mass AG, through his authorized person, demanded public f
a disclosure of "How many buses were actually involved in j
f t
Massachusetts in the simulated evacuation of schools and
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i L
i special facilities?
(Identify by bus company)" (Transcript t
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of Public Meeting, July 2, 1988, at 169, copy of relevant
(
l pages attached hereto and marked "A".)
Mass AG.31so asked:
"What are the names of the bus companies being relied on in 4
j the plans by ORO but who did not participate in the I
exe rci se?'-
Another of his questions asked for a list of i
J't buses.
(Tr. 170).
Yet another of Mass AG's questions asked i
t j
"What ambulance companies were involved.
(Tr. 174).
l 1
f And still another of his questions sought public revelation of a list of the names and addresses of each ORO member
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assigned to each ORO position for each shift?"
(Tr. 174-175),
l All of the information Mass AG's authorized person i
sought was to be provided to counsel for all active parties under the terms of this Board's Protective Order.
There was j
no call for Mass AG's authorized person to demand a public disclosure for access to the information.
Applicants further f
L 1
note that the public meeting was attendad by individuals with t
no party status in these proceedings, but whose involvement in angry and disruptive public debate has been extensive.
I Applicants' euncern for the confidentiality of service
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providers' names in such a context is particularly grave, f
Applicants, however, rather than seek sanctions for this
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behavior which defied, at least the very spirit of the Protectiva order, took more immediate steps to prevent public disclosure and wrote to counsel for FEMA to alert it that Macs TG's questions sought the divulgement of protected j
information.
(Letter attached hereto and marked "B".)
A I
copy of this letter was duly sent to Mass AG.
Mass AG paid little heed to Applicants' notice.
In a subsequent filing with the Onsite Board, a M6ad AG pleading mado public similar confidential informatioh protected under l
l this Board's order but also protected under a similar j
protective order entered by the Onsite Board.
In his "Request to File Reply of Massachusetts Attorney General to i
Applicants' Answer to Motion to Amend Basis Filed by Massachusetts Attorney General with Respect to Siren contentions," Mass AG included, by attachment, an excerpt of a deposition transcript, the creation and distribution of which had been carefully restricted, and disclosed the name of a private citizen providing a service under the SPMc.
i Applicants were advised that the disclosure was inadvertent i
and that efforto were being made to retrieve the documento.
Instead of moving for sanctions, Applicants accepted the explanation in good faith and simply highlighted this irresponsible conduct in their response to Mass AG's l
l i
pleading.
In that pleading, however, Applicants made it clear that Mass AG's reckless approach of "file what you feel like whenever you feel like it" should not and could not bc I
tolerated.
l On the heels of this notice, Mass AG's author' zed person again, and this time, flagrantly, violated the protective I
I order.
In "Massachusetts Attorney General's Supplemental 1
1 1
Responses to Applicants' First Sat of Interrogatories," Mass i
4 AG has named eight bus companies whose identities were i
clearly within the protection afforded by the order.
With this latest violation, Mass AG, by an authorized person, has rendered the Board's order a nullity in respect of the matter disclosed.
The direct result of Mass AG's flouting the order i
j of this Board is an impairment of Applicants' ability to defend against contentions and bases alleging bus company insufficiency.
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Applicants therefore request that the Board, pursuant to the power granted to it by Section 2.707, dismiss JI Contentions 45, 55 and 58 and their bases to the extent they
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go to the issue of the willingness of the bus companies I
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relied on by the SPMC to respond to a radiological emergency.
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' l l
Egg Statement of Policy on Conduct of Licensina Proceedinas, CLI-81-8, 13 NRC 452 (1981) ("Boards should attempt to tailor j
sanctions to mitigate the harm caused by the failure of a l
party to fulfill its obligations al.d bring about improved i
future cospliance.")
The Commission's Statement of Policy on Conduct of Licensina Proceedinas makes it clear that parties to NRC proceedings may not disregard their obligations with impunity:1 When a participant fails to meet its obligations, a board should consider the imposition of sanctions against the offending party.
A spectrum of sanctions from min 7r to severe is available to the boards to assist in the management of proceedings. For example, the boards could warn the offending party that such conduct will not be tolerated in the future, refuse to consider a filing by the offending party, deny the right to cross-examine or present evidence, dismiss one or more of the party's contentions, imposa appropriate sanctions on counsel for a party, or, in severe cases, dismiss the party from the proceeding.
Id. at 454.
This Board's Order itself discusses a spectrum of sanctions to be imposed for disobedience.
At best, Mass AG has never taken the need for protection of this information, and this Board's order recognizing that 1 Although the commissioner's Poliev Statement is oriented toward imposing sanctions in response to tactics causing delay in a proceeding, boards have not limited their use of sanctions to those circumstances.
Egg Kerr-McGee Chemical coro. (West Chicago Rare Earths Facility), LBP-86-4 23 NRC 75 (1986); Public Service Company of New Hamoshire (Seabrook Stationt Units 1 and 2). LBP-83-20A, 17 NRC 586 (1983), and no such limitation is implied by the regulations.
10 CFR 5 2.707.
l t
l need, seriously.
At worst, it is outright defiance of the Board's Order.
Sanctions are warranted in either event.
i Mass AG's duty does not begin with refraining from deliberate l
disclosure of the protected information.
Mass AG's duty is
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first to guard the protected information from disclosure.
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The Poliev Statement sets forth several factors that a Board must consider in selecting a proper response to a i
party's failure to abide by one of its orders:
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In selecting a sanction, boards should consider the i
relative importance of the unset obligation, its potential for harm to other parties or the orderly conduct of the proceeding, whether its occurrence is an isolated incident or a part of a pattern of behavior, the importance of the safety or environmental concerns
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raised by the party, and all of the circumstances.
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Boards should attempt to tailor sanctions to mitigate t
the harm caused by the failure of a party to fulfill its obligations and bring about improved future compliance.
l Id.
EAA also Commonwealth Edison Co. (Byron Nuclear Power Station, Units 1 and 2), ALAB-678, 15 NRC 1400 (1982)
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(applying Commission's factors): Earr-McGee Chemical Corn.
I (West Chicago Rare Earths Facility), LBP-06-4, 23 NRC 75 j
(1986) (same).
Each of these factors is considered i.: turn.
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1.
Relative Importance of the Unmet Obligation and Potential Harm to Other Parties or Orderly Conduct of the Proceedinc.
As the entering of the Board's Protective Order underscores, the privacy and commercial interests at stake are important.
The disclosure of the names of eight bus i
companies is just the type of problem that the Board sought to prevent.
Disclosure of this important information has, at the very least, jeopardized the Board's ability to conduct an t
orderly proceeding.
The issuance of the Protective Order was designed to prevent the likely harassment of suppliers, l
t (2/10/88 Tr. 9742-43), and to assure that the issue of supplier availability was given a fair hearing.
Now that the f
information has been publicly disclosed, that assurance is no longer possible.
Applicants, to be sure, cannot now point to what, if any, specific effect this public disclosure may have on bus company participation.
Mass AG, however, having publicly disclosed this information and potentially subjecting the companies to harassment, cannot be heard to argue that, should one or more companies withdraw, the SPMC does not provide for an adequate number of buses.
Should any bus company decide te withdraw, given Mass AG's disclosure o; the protected information, it will be impossible to determine definitively whether that withdrawal resulted in whole or in part from harassment and intimidation.
0 l
I t
2.
Pattern v.
Isolated Incident.
i As noted earlier, this latest incident is not the only instance of Mass AG's nullificaticn of the protective order.
i But even if it were, the severity of the violation would warrant the imposition of sanctions.
Mass AG actually states in his pleading that four of the companies cannot provide reasonable assurance, so presumably Mass AG perceives a potential wavering of commitment.
To make his point and then proceed to disclose the names publicly can hardly be argued as no more than simple inadvertence, i
3.
Importance of the Safety or Environmental Issues Raised by the Party.
Mass AG cannot escape imposition of the proposed sanction by arguing the relative importance of the issue of bus company provisions.
EAS commonwealth Edison Co. (Byron Nuclear Power Station, Units 1 and 2), ALAB-678, 15 NRC 1400 (1982) ("Here, where there is little but the bare contentions i
upon which to rely, this factor is of much lesser weight and l
not at all decisive.")
As a practical matter, however, sufficient numbers of buses will be available.
When the issue of services to be supplied under the SPMC is no longer an impediment to l
licensing of Seabrook Station, suppliers of services are unlikely to encounter harassment and intimidation.
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n 4.
Consideration of All the circyngkap,q13 Given the importance of preserving the confidential nature of the information, the repeated and apparent disregard of Board orders, the lack of a real impact on
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safety, and the adverso effect on the Board's ability to conduct an orderly proceeding, the sanction of dismissal of I
JI Contentions 45, 55 and 58 and their bases to the extent j
they go to the issue of the willingners of the bus companies relied on by the SpMC to respond to a radiological emergency t
l is warranted and appropriate.
CONCLUSION t
For the reasons stated above, the Board should dismiss E
l JI Contentions 45, 55 and 58 and their bases to the extent l
l they go to the issue of the willingness of the bus companies relied on by the SpMC to respond to a radiological emergency at Seabrook Station.
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l 1
i Respectfully submitted, l
l i
J:w
-l a n !n & E N
s j
Thomas G.
Dignan, Jr.
i George H.
Lewald Kathryn A. Selleck Jeffrey penfield Trout j
Jay Bradford Smith Ropes & Gray 1
i 225 Franklin Street f
ooston, MA 02110 l
(617) 423-6100 l
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l I
I
[ i I
m ATTACHMENT "Aa 169 1
Questiens Not Pead at "eettne 2
Seabrook Public Meetine j
3 JULY 2, 1998 l
l I
4 Name:
Allan Fierce (19) 5 Address:
Mass. Attorney General's Office One Ashburton Place, Room 1901 6
Boston, MA 02108 7
8.
At what time did each bus 8
for school children and special populations 9
arrive at the special host facility?
h) 9.
Hou many buses were actually 11 involved in Massachusetts in the simulated uation w: ::h::1:
- .d
- <ci 4
u facilitien, sId...sify by bus company.)
14 How many would actually be needed if all o
15 six Massachusetts towns were evacuated 16 simultaneously?
17 10.
Will you now tell the public 18 what the host school facility is?
Where is 19 it located?
30 11.
Was the Red Cross actually 21 involved in the exercise in Massachusetts?
22 In what specific way?
Were the congregate 1
23 care centers actually established and fully 24 equipped as part of the exercise?
Who 8 A R REPORTING SERVICE D
L70 1
staffed and ecuipped eacn One?
2 12.
- ;ha t are the names cf the bus
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3 ccmpanies being relied en in the plans by 4
ORO but who did not participate in the
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5 exercise?
6 13.
On which bus routes in 7
Massachusetts did FEMA observe that bus 8
drivers were getting lost or off route?
9 Which buses were involved?
.0 14.
Does FEMA have a list of the 11 buses which participated in the exercise e hnwi n f h -
~ '- h.:.n1 nrise Mi" m:
f y
13 w iez e it wente Can we have a cvpy ur this I
14 list?
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15 Name:
Sandra Fowler Mitchell (20) t 16 Address:
95 Amesbury Road Kensingten, NH 03827 17 15 1.
I have observed the limited 19 ettendan:e here today.
There appears to 20 be a majority of PSNH/NHY employees.
Is 21 this a paid day for these employees?
Z!
2.
What are the aggregate 23 numbers of buses and bus routes in the 24 response plan?
How many actual buses B A R R5 PORTING SERVICE
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L74 I
cc municatien tske place?
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2
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26.
Will you provide us with the
=
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i 3
name, address and phone number of each of t
?
4 your evaluators, indicating for each one 5
what his/her assignment (s) was for the 4
exercise?
l
?
7 27.
Will you provide us with copies l
e of all Status Boards' centents for each heur i
g of the exercise?
i
=
to 28.
What ambulance companies were a
11 involved in the exercise in (a) Mat,achusetts, i*
a acq i '. i i r. M r.' '!. m p t h f r - ara av.
'-a=
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u each company?
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14 Where did each ambulance go and f
l-15 what did it do during the exercise?
t
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14 Were these ambulances and l
17 drivers "on call" for this exercise, no*,1fied la in advance that they would be needed?
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=
t gg 29.
Will FEMA provide us with a 1
20 list of the names and addresses of each ORO l
t member assigned to each ORO position for 21 22 each shift?
If FEMA does not have this 23 information, how can FEMA have reasonable t
l 24 assurance that some ORO workers (or NNY l=
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8 A R WEPORTING $8RVN:I I
175 l
t on-site workers, or others) did not work 2
both shifts to cover for a manpower shortage?
3 e
a 4
30.
Did FEMA record the arrival 3
times of each ORO member on each shift?
4 May we have this information?
7 31.
What specifically was done to
=
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s test the adequacy of the coordination of i
s' 9
PAR's issued by ORO and New Hampshire?
to What records or logs do you have which I
11 document the discussions between CRO I;;
- c.h:: : ane :.w :::. r*hi
' a pi***'q i
t, 13 d*= =^=*cise?
May we have copies vi uneser 14 15 Cements Not Read at Meetino l
I 14 Seabrook Public Meetinq
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i 17 July 2, 1988 i
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14 Name Greg Myers (1) l L
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13 Address:
Donald Street
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Raymond, NM 03077 2
a 21 1.
As a member of NF? Oke, t l
i 23 feel very sure that we deronstratec.nat l
23 evacuation of Massachusetts is feasible /
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1 24 attainable.
We are a professional 1
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5 A R REPOfflNO 88mMG l
f t
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ATTACHMENT "B"
4 ROPES & GRAY 225 FRANKL!N STREET 80STON, MASSACHUSETTS o211o
.N 84 s*NG?CN IN 890v'OENCE so=E Ntoretaza
' Stas Nwwstm 95it's ac*ts omar esN iooiet%%s<6vaNiaavt%wE emov'CENCE. e s o29o3 ftsk Cote i4 L 7:423 237? 417: 433 784L Swit t aco (017) 423 Stol magw.NGTON O C 20o04 (4o3:g3t saco c233>.a noo etutCe t.<aoiss2:4,io TELECom te f 202 626 3648 July 26, 1988 George Watson, Esquire General Counsel Federal Emergency Management Agency 500 C Street S.W.
Washington, D.C.
20472 In the Matter of Public Service company of New Hampshire, et al. (Seabrook Station)
Docket Nos. 50-443-OL, 50-444-OL (Offsite Emercancy Plannina).
Re:
ASLB Protectiva Order Concerning the Identity of Individuals and Organizations Needed to Implement the NKRERP v. Seabrook Emergency Preparedness Exercise Informational Reauests.
Dear George:
It may be that this matter is one which would be more appropriately addressed to Joe Flynn.
However, because of your initial involvement with Full Scale Emergency Preparedness Exercisa for Seabrook St.ation of June 28 and 29, I am taking the liberty of knocking first cn your door for assistance, I
- r. rust you will make any nacosaary referrals.
Following the June 28th and 29th Exercise, as I'm sure you kncv, Richard Donovan, Chairman RAC, FEMA held a noticed public meeting on July 2, 1988 at 7ortsmouth, N.H. to present the views of the participsnts and to receive the comments and questions of tho attending public.
The format of the public hearing provided inttr A1.iu for taking written questions t' rom the audienco and responding to titam at the hearing.
Because of hearing time limitations, FEMA undertook to respond in writing at a later date to all of the questions which remained unanswered.
(Hearing Transcript (Tr.) pp. 71, 152, 160).
It appears from the statements of the Chairman, Richard Donovan, that all of this will be published as a l
l t
Ropco & GRAY George Watson, Esquire July 25, 1988 matter of public record and be put in the public document rooms for inspection.
Among those at the meeting submitting questions was Allan R.
Fierce, Assistant Attorney General for the Commonwealth of Massachusetts, who, as you know, has an appearance as counsel before the Licensing Board in the current Seabrook licensing hearings.
There were fourteen questions on his initial list (Tr. p. 144) to which he added more (Tr. p. 160) and more (Tr. 169 et seq).
Although interestingly he, himself, characterizes his questions addressed at the public meeting as bullying, our concern is not with these but with certain of those that follow in the later sequences.
It is these that are the real troublesome ones in terms of what is sought by the Licensing Board's Protective Order of March 23, 1988, i.e. that the identity of individuals and organizations needed to implement NHRERP not be publically disclosed.
Question 9 asks, "How many buses were actually involved in Massachusetts in the simulated evacuation of schools and special facilities?
(Identify by bus company)"
(Tr. 169).
Question 12 asks, "What are the names of the bus companies being relied on in the plans by ORO but who did not participate in the exercise?"
Question 14 asked for a list of buses.
(Tr. 170).
Question 28 asks "What ambulance companies were involved... "
(Tr. 174).
And Question 29 seeks a list of the namas and addresses of each ORO member assigned to each ORO position for each shift?"
(Tr. 174-175).
Just what Allan Fierce has in mind by seeking public divulgement of these identities we do not know, but clearly under the terms of the Order this very information is to be provided him, albeit under suitable protection.
However, one thing is certain, and that is that these ace the very matters that the Board's order seeks to protect from public disclosure.
Whilo sanctions aro to be provided for violations of the order, it would seem to follow tnat sanctions could be had for causing thu order to ha violated by others.
However<, our interests do not canter on sanctions but in continuing to pr7twct the idsntity of individuals and organi:ations needud to implemant the plan and in giving effect tu t.no enforcement of the Board's order.
It is in this vain that we call to your attention the Licensing Board's Memorandum of April 8, 1988 (copy enclosed) responding to Ms. Jane Doughty's (SAPL) request for clarification concerning the service of information protected by the order:
RoPc0 & GRAY George Watson, Esquire July 25, 1988 Protected information should be deleted from public filings. Do not serve protected information or send i
protected information to the Docketing and Service Branch or to the Atomic Safety and Licensing Board Panel.
Send protected information to each member of this Licensing Board in the manner set out in the order, and one copy to the Atomic Safety and Licensing Appeal Board Chairman, Alan S.
Rosenthal.
It strikes us that the circumstances there are no'.
dissimilar to those now encountered by FEMA, where a commitment has been made to provide information which in turn is protected by the Order.
Howe we but call this to your attention and appreciat' atever assistance of your good offices can be had in this matter.
Enclosed for your convenience, also, are a copy of the Board's (Protective Order) Memorandum of Mcrch 23, 1988 and pertinent transcript pages of the "Full Exercise" public hearing.
Very truly yours,
)
ogg George R. Lewald GHL/rl Enclosures cc:
Allan R.
Fierce, Esq.
Assistant Attorney General Department of the Attorney General One 1.shburton Place, 19th Floor i
Bcston, MA 02108 (W,' enclosures) t d
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!GL8EiE0 UNC
'20 DCT 24 A11 :01 CERTIFICATE OF SERVICE OFFLE
,e Ln I, Jay Bradford Smith, one of the attogneysefor'the'l Applicants herein, hereby certify that on OctobebM0',' 1988, I made service of the within document by depositing copies thereof with Federal Express, prepaid, for delivery to (or, I
where indicated, by depositing in the United States mail, first class postage paid, addressed to):
1 Administrative Judge Ivan W. Smith Robert Carrigg, Chairman l
Chairman, Atomic Safety and Board of Selectmen l
Licensing Board Panel Town Office U.S.
Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Judge Gustave A. Linenberger Diane Curran, Esquire Atomic Safety and Licensing Andrea C.
Ferster, Esquire Board Panel Harmon & Weiss U.S.
Nuclear Regulatory Suite 430 Commission 2001 S Street, N.W.
East West Towers Building Washington, DC 20009 4350 East West Highway Bethesda, MD 20814 Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S.
Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Streat 4350 East West Highway Concord, NH 03301-6397 Bethnsda, MD 20314 l
Adiudicatory File Snerwin E, Turk, Esquire Atomic Safety and Licensing Office of General Counsel Board Panel Docket (2 copies)
U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Comnission East West Towern Building One White Flint North, 15th Fl.
l 4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852
- Atomic Safety and Licensing Robert A.
Backus, Esquire Appeal Board Panel 116 Lowell Street U.S.
Nuclear Regulatory P. O.
Box 516 Commission Manchester, NH 03105 Washington, DC 20555
f.
e Philip Ahrens, Esquire Mr. J.
P.
Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S.
Sneider, Esquire Matthew T.
Brock, Esquire Assistant Attorney General i
Shaines & McEachern Department of the Attorney 25 Maplewood Avenue General P.O.
Box 360 One Ashburton Place, 19th Fl.
Portsmouth, NH 03801 Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801
- Senator Gordon J.
Humphrey R.
Scott Hill-Whilton, Esquire U.S.
Senate Lagoulis, Clark, Hill-Washington, DC 20510 Whilton & McGuire (Attn:
Tom Burack) 79 State Street Newburyport, MA 01950
- Senator Gordon J. Humphrey Leonard Kopelman, Esquire One Eagle Square, Suite 507 Kopelman & Paige, P.C.
Concord, NH 03301 77 Franklin Street (Attn:
Herb Boynton)
Boston, MA 02110 Mr. Thomas F.
Powers, III Mr. William S.
Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Charles P. Graham, Esquire Office of Ganeral Counsel Murphy and Graham Federal Emergency Managelsent 33 Low Street
.Tgency Newburyport, MA 01950 500 C Street, S.W.
Washington, DC 20472 Gary W.
Holmes, Esquire Richard A.
Hampe, Esquire Holmes & Ella Hampn and McNicholas 47 Winnacunnot Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301
-2
Ie Mr. Richard R.
Donovan Judith H. Mizner, Esquire Federal Emergency Management 79 State Street, 2nd Floor Agency Newburyport, MA 01950 Federal Regional Center 130 228th Street, S.W.
Bothell, Washington 98021-9796 l
Ashod N.
Amirian, Esquire 376 Main Street Haverhill, MA 01830 Robert R.
Pierce, Esquire John H.
Frye, III, Alternate Atomic Safety and Licensing Chairman l
Board Panel Atomic Safety and Licensing U.S.
Nuclear Regulatory Board Panel Commission U.S.
Nuclear Regulatory East West Towers Building Commission 4350 East West Highway East West Towers Building Bethesda, MD 20814 4350 East West Highway Bethesda, MD 20814 James H. Carpenter, Alternate Technical Member Atomic Safety and Licensing Board Panel U.S.
Nuclear Regulatory Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814
_t c q /ha. Afe' W Yh Jay Bradford Smith
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