ML20205D805

Town of Hampton & New England Coalition on Nuclear Pollution Reply to Responses of Staff & Applicant to Intervenor Contentions on Graded Exercise.* Certificate of Svc Encl

ML20205D805
Person / Time
Site:	Seabrook
Issue date:	10/21/1988
From:	Brock M HAMPTON, NH, NEW ENGLAND COALITION ON NUCLEAR POLLUTION, SHAINES & MCEACHERN
To:	Atomic Safety and Licensing Board Panel
References
CON-#488-7334 OL, NUDOCS 8810270211
Download: ML20205D805 (15)

Text

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i NUCLEAR REGULATORY COMMISSION IB

'88 OCT 24 P12 :

Before the trn ATOMIC SAFETY AND LICENSING BOARD b6,

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October 21, 1988 l

In the Matter of

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Docket Nos. 50-443-OL i

PUBLIC SERVICE COMPANY OF

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50-444-OL NEW HAMPSHIRE, et al

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Off-Site Emergency l

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Planning (Seabrook Station, Units 1 and 2)

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TOWN OF HAMPTON AND NEW ENGLAND COALITION ON NUCLEAR POLLUTION t

REPLY TO THE RESPONSES OF THE STAFF AND APPLICANTS TO INTERVENORS CONTENTIONS ON GRADED EXERCISE NOW COME the Town of Hampton (hereinafter "TOH") and New England i

Coalition on Nuclear Pollution (hereinafter "NECNP") and hereby reply to the responses of the Staff and Applicants to certain contentions f

submitted by TOH/NECNP on the graded exercise conducted on June 28 and 29, 1988, as follows:

r T.Q11/,lifCNP EX 1 The scope of the June 28-09, if88 Exercise of the New Hampshire l

Radiological Emergency !<esponsa Plan (NHRERP), was so limited that it cou)d not and did not yield valid or meaningful results regarding the capability to implement that plan, as required by 10 C.F.R. 150.47(a)(1) and (a) (2), in that it did not hiclu(:e demonstrations or evaluations of emergency response caphbilities of nany persons and entities relied upon to 1:nplcnent th NHRERP.

In addition, the i

exclusion of these eatities from the Exercise precludes a finding that i

the Exercise evaluated major portions of' emergency response capabilities, as required by 10 C.F.R. 5 50. 47 (b) (14 )

and 10 C.F.R.

l Part 50, Appendix E(F) (1).

Other than limited participation by Stato i

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of New Hampshire personnel, the najority of the organizations, entities, and individuals relied upon in the NHRERP for implementation of that plan did not participate in the Exercise.

Thus, the Exercise did not address the willingness, availability, training, equipment, capability, or adequacy of performance of the entities and individuals identified in Bases a to g below, each of which is necessary to implement the portions of the NHRERP referenced therein.

Accordingly, the NHRERP is fundamentally flawed.

BASES:

(a)

None of the teachers relied upon under the NHRERP to implement protective actions for school children, S1q, e.g.,

NilRERP Vol. 18A, Appendix F, participated in the Exercise.

Necessarily, the Exercise failed to meet a primary objective to demonstrate the ability and resources necessary to adequately protect students ir an emergency.

Exercise Report, p.

172.

Since hundreds of teachers through their representatives, and by petition, have already provided evidence in this proceeding of their intent npl to implement the NHRERP, failure to test for the availability and participation of New Hampshire teachers represents a fundamental flaw in the NHRERP.

(b)

Gince none of the New Hampshire teachers participated in the Exercise, FEMA could not observe any adequate demonstration of the organizational ability or resources necessary to offect an early dismissal, sheltering, or evacuation, of the school children, even though this demonstration was one of the Exercise objectives.

Exercise Report, p.

172.

Under the NHRERP, early dismissal, sheltering and evacuation are the only, protective actions for school children.

ERA (e.g.) NHRERP Vol. 18A, App.

F.

1-3, F.

1-4.

All of these protective actions assume, and rely upon, teachers for impler.entation.

Id.

Failure to observe or test necessary personnel or procedures to protect students represents a fundamental flaw in the NHRER?,

(c)

During the summer months, Hampton Beach is the mont highly and donsely poy.0.ated area in the Seabrook EPZ, and poses unique and extrene obstacles to emergency planning.

Under the hHRERP, State

[ Police are required to provide all 17 traffic guides to utaff every i' t r a f f i c centrol post lecated within Hampton Beach, and to ansumo responsibility for regulating the bumper to bumper traffic out cf the a

kl Direct Beach area.

Eqn NHRERP, Vol.

6, App. 1: Exhibit 1 to Applicants' Testimony No. 3 (Personnel Rasources), Tablo 3.1-2.

The I

l Exercise did not ;;rovid? for, test or require even a single State j Police officer to staff any of the five traffic control posts located in Hampton Beach, and the Beach, as an area for exercising the Plan, was essentially ignored.

Failure to adequately demonstrate the ability and resources deemed necessary under the NHRERP to evacuate the EPZ's most populated beach area represents a fundamental flaw in the NHRERP.

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(d)

Although at least 45 traffic control guides are to be provided by the New Hampshire State Police to all Towns under the NHRERP, Id. at Tables 3.1-2, 3.1-3, only two troopers actually assumed that function during the Exercise.

Sag, Exhibit 1,

attached.

Accordingly, there is no factual basis to support TEMA's finding that 1

State Police could or did properly "handle beach closing," and the l

time frames for staffing of traffic control points relied on by FEMA are wholly rpeculative.

Sea, Exercise Report, p.

182.

In addition, i

the NHRERP requires State Police to provide 28 traffic guides to staff access control posts within the New Hampshire EPZ.

Volume 6,

pp.

9-j 12.

Only two troopers were actually deployed to staff ACPs during the t

Exercise.

Exhibit 1.

FEMA's conclusion that, by 1530 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br />, State l

Police had adequately shown the capability to deploy all 89 troopers for ACP/TCPs is without foundation.

Exercise Report, p.

182.

Failure to adequately demonstrate the ability and resources necessary to regulate evacuation traffic and EPZ access represents a fundamental i

flaw in the NHRERP.

Exercise Report, p. 182.

I (e)

The Exercise did not provide

for, test, or require simulation, of even a single accident or other traffic impediment in the Hampton Beach area.

Even under non-omergency conditions, traffic accidents and tie-ups, with associated traffic congestion, are routine at Hampton Beach.

The Exercise unreasonably assumed, however, that f

traffic flow remained smooth throughout the beach during the entire

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evacuation.

Failure to adequately demonstrate road clearance e

capabilities and traffic management, under anticipated conditions, in l

the critical pathway along the beach represents a fundamental flaw in j

the NHRERP.

I (f) 15 or 18 (83%) of the bus companies relied upon under the NHRERP for emergency and special needs transportation did not provide any drivers or buses for the Exercise.

Even the three companies who l

did provide resources deployed only 18 regular buses (4%) of the 453 i

required for implementation of the NHRERP.

M3, Exhibit 2 Attached; I

3 Applicants' Direct Testimony No. 2 p.

13, October 21, 1987.

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Exorcise also utilized only of 48 ambulances (2%),

and two of 71 i

special needs buses ( 3 8t ), deemed necessary for irplementation of the Plan.

Sat, Applicants' Direct Testimony No.

2, pp. 13-15, Cetober 21, 1987; Exhibit 2.

The adequacy of transportation recources, particularly bus drivers, has been seriously disputed in these proceedings.

The failure to demonstrate the availability of any meaningful number of those resources represente a fundenental flaw in the NHRERP.

(g)

There is no basis for FEMA's assertion that the State, during the

Exercise, adequately demonstrated or "identified",

sufficient manned vehicles to evacuate the entire EPZ.

See Exercise Report, p. 165.

That identification process apparently consisted only of phone calls to bus companies to restate the number of drivers 3

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specified in each company's letter of agreement.

Apparently, no determination of the number of drivers actually available to drive, was provided by the companica or required by the Exercise.

The failure to demonstrate the actual availability of necessary transportation resources, including at least 96% (435 of 453) of the drivers required to implement the NHRERP, represents a fundamenual flaw in the NHRERP.

Exhibit 2.

R_EPLY TO RESPONSES RE: BASES A AND B:

Reolv to Aonlicants' Posit h Applicants offer no specific objection to Bases A and B beyond the vague claim that the contention is objectionable "on the ground that it is baseless in its generality" and that certain points raised by TOH/NECNP were covered by contentions filed by another Intervenor in this proceeding.

Applicants' claim of undue "generality" in the contention is plainly inaccurate, given the specific deficiencies outlined in each of the proffered bases.

With renpect to Bases A and B, it is hardly a "generality" to identify that none of the New Hampshire teachers 1

l participated in the exercise or that without these teachers, none of

't the rrotective action procedures for school children were reviewed or tnsted.

Applicants claie unat the TOH/NECHP contention is I

• ropetit).ve" of istuus raised by other Intervonorr., while rtaising for discussion an issue of consoiluation, providos absolute)y no legal

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1 basis for exclusion of an otherwise proper contenticn.

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l Recly to Staff's Position i

Citing two cases,1 the Staff opposes admission of Bases A and B f

on grounds that "scho>l personnel are considered to be members of the f

their participation in f

f public as opposed to emergency workers and.

the exercise is not mandatory."

Staff Response, p.87.

The Staff's l

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position, however, represents a misreading of the two cases and

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j contravenes the Commission's requirement for a "full participation" i

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exercise.

10 C.F.R. Part 50, Appendix E, IV.F.1 and !!.4.

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In Shoreham, the first case relied upon by the Staff, the Appeal i

i Board was concerned with the potential for role conflict causing job t

f abandonment among individuals, including teachers.

23 fiRC at p.

150.

The opinion is silent on the extent to which teachers must be involved f

i in a graded exercise to satisfy the commission's mandate "for full l

t participation."

The Appeal Board expressly recognizes, however, that i

where emergency plans rely upon teachers "for assistance in i

f supervising and coordinating" protective actions, Isl. at p.

150, lack of adequate teacher participation in carrying out an emergency plan I

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j l "fetally flaws" the emerguncy tesponn.

In. at p. 151.2 l

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)1 Lonq_lgland Liethtina ca.

(Shoreham !!uclear Power Sr.ation, Unit I

l, 1), ALAB-832, 23 !!RC 235, 153 I;.65 (1986); Ehilfulgighia El e ctr.Lc_C01 i

(Limerich Conorating Station, Units 1 and 2), L3P-85-14, 21 flRC 1219, i

I 1308-9 (1985).

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Whether the potenti41 for teacher rala conflict fatsR y flaws the Applicantu' emergency response plan hinges upon whethor such significant job abandonment might occur as to result in an insufficient number of teachers being available to supervise early dismissal, ovacuation or sheltering activities.

23 tlRC at 151.

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The Shoreham decision therefore expressly acknowledges the critical role that teachers play in an emergency response, where, as in the NHRERP, teachers are relied upon as the first and primary personnel to protect students.

Accordingly, assuming the NHRERP exercise failed to include even i t e a cb.gI, nucessarily the exercise was fatally flawed since it failed to satisfy the mandate for "full participation" of personnel performing essential emergency services i

and failed to adequately "verify the capability to respond to the accident scenario.,3 While the Staff.herefore quibbles over whether or not teachers j

may be deemed "emergency personnel," that characterization is simply I

not dispositive of all "other resources,"4 including teachers, which I

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"Full participation includes testing the major observeble portions of the on-site and of f-site emergency plans and mobilization l

of state, local and licensee personnel and other resources in sufficient numbers to verify the capability to respond to the accident scenario."

10 C.F.R. Part 50, Appendix E, IV.F.1 N.4.

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must participato, and be tested, in an emergency exercise to reasonably assure an adequate response.5/6 only a month ago, the Appeal Board determined that an exercise must include participation by school personnel, and provided further guidance as to the proper scope of a "full participation" exercise:

The regulation involved here,Section IV.4.1 of 10 C.F.R. Part 50, Appendix E, states that ' full participation' is required for the initial emergency exercise to be conducted during the two year period preceding license issuance.

The regulation immediately calls attention to the definition of full participation found in which is as much a part of the Footnote 4 regulation entitled to equal legal effect as if it were in the text.

(Footnote omitted.)

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For this reason, the Staff's reliance upon Pniladelchia Electric gm. is equally flawed.

The Board's opinion cited by the Staff provides utterly no guidance over the proper scope or definition of a l

"full participation" exercise.

Philadelphia Electric Co (Limerick Generating Station, Units 1 and 2), LBP-85-14, 21 NRC 1219, 1308-1309 l

x (1985).

In the cited opinion, the Board was focusing solely on whether teachers would be deemed "emergency workers" for purposea of l

whether they should be issued KI and dosimetry.

Id. at 1309.

The scope of a "full participation" exercise is never discussed, addressed, or defined.

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The Staff has also misinterpreted the cited regulation, which i

provides that an exercise may be conducted "without mandatory public l

participation."

10 C.F.R. Part 50, Appendix E,

Part IV.F.1.

As I

interpreted by the Appeal Board, "all At ('without mandatory public participation') means is that emergency exercises should not involve actual participation by the ceneral nublic, or so-called ' live tests and drills'."

ALAB-900, p.31.

(Emphasis supplied.)

As alleged in l

Bases A and B,

the NHRERP assumes, and rolles upon, teacher participation and assistance to students to implement protective actions.

Unlike members of the general public, therefore, and as recognized by the Appeal

Board, teachers represent a critical component of the planned emergency response for students.

Failure to i

include even a single teacner in the exercise is a blatant and fundamental flaw in the NHRERP.

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a other things, a full participation exercise must test 'the major observable portions' of the on-site and off-site emergency plans and mobilize

' sufficient numbers' of

state, local and licensee / applicant personnel and other resources so as to permit verification of their ' integrated capability' to respond to the particular accident scenario being tested.

(Footnote omitted.)

A further gloss on the meaning of full participation is added in the text:

Such an exerciso should test 'as much of the licensee (applicant), state and local emergency plans as is reasonably achievable without mandatory poblic participation.'

In summary, the adequacy of the scope of a pro-license emergency exercise must. be judged against the NRC's regulatory requirements, not the customary practice of FEMA in designing and conducting such exercises.

The general focus of the NRC's emergency planning requirements is on whether there is reasonable assurance that adequate protective measures can and will be taken in the event of an emergency, i.e.,

whether there is an absence of any fundamental flaws in the emergency plans.

Particularly pertinent among those requirements insofar as emergency exe:cises are concerned is 10 C.F.R. Part 50, Appendix E, Section 4.F.1, the entirety of which (including footnote 4) must be given effect.

That provision requires a pre-license exercise to be ' full participation.'

This means that all

'the major observable portions of the on-site and off-site emergency plans' must be tested in that pre-license exercise; the FEMA objectives can serve as guidance in determining what the major observable elements are.

In addition, a pre-license uxercise includes the mobilization of

state, local and licensee pornonnel

'in sufficient numbers' to verify their ' integrated capability' to assess and to respond to the particular accident scenario being tested.

There is no discute that the notential evacuation of schools within the emercency olannina zone (EPZ)_is a maior element of off-rite emercency planninc.

See FEMA Objectives, No.

19.

See also, 10 C.F.R. 550.47(b)(10).

A sufficient number of school and related personnel musl therefore carticipate in a full carti.gination 8

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exercise so as to nornit verification of their intearated caDability to resDond to the accident 3rdttja rio.

In the Matter of Lona Island Lichtino h

(Shoreham Nuclear Power Station, Unit 1),

ALAB-900 (9/20/88) pp.

17, 25-26, 34-35.

(Emphasis Supplied.)y The Appeal Board, therefore, expressly rejected the position proffered by the staff that "school personnel need not be involved in an emergency exercise." S_%2, Staff Response, p. 71.

This Board should similarly reject the Staff's view, and admit Bases A and B for litigation.

REPLY TO RESPONSES RE: BASES C AND E:

Ren1v to Annlicants' Position Applicants offer no specific objection to Basis C beyond a vague claim of "generalityd and as "repetitive" of contentions proffered by another Intervenor.

As stated, such objections provide no legal support for exclusion of the basis.

The only additional objection proffered by Applicants on Basis E is a bald claim that the failure to test road clearance capabilities and traffic management under anticipated conditions, in the Hampton Beach area, does not amount "to

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7 The Appeal Board decision primarily focused upon the lack of participation of most Shoreham EPZ

achools, as distinct from identifying which "school and related personnel" must participate in an exercise to meet the regulatory standard.

In view of the Appeal Board's recognition of the important role played by teachers in an effective emergency response, however, end the plain meaning of the mandate for "full participation" to test the "major observable portions" of an emergency plan, the NHRERP simply cannot be meaningfully tested unless there is a minimum of teacher participation in the exercise.

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an allegation of fundamental flaw."

This assertion adds nothing of legal content to the Applicants' position, and, as stated in reply to the Staff, is erroneous.

Roolv to Staff's Position In opposition to Bases C and E, the Staff asserts there is "no regulatory basis for requiring that all traf fic control posts be staffed in an exercise." (Emphasis supplied.)

Even conceding this point, the Staff's assertion is irrelevant to, and represents a misreading of, Bases C and E.

Barcs C and E rather are premised upon the Commission's mandate that an exercise test "the naior observable portions" of the emergency plan.

10 C.F.R. Part 50, Appendix E, IV.F.1.

Accordingly, although not AU traffic control posts need be tested in an exercise, the management and staffing of the "major," or most significant, traffic control plans, posts, and personnel with potentially the greatest impact on a prompt and safe evacuation, must be exercised to satisfy Commission regulations.

This the exerciso utterly failed to do.

Even Applicants concede that traffic control posts vary in importance and that "the most important TCPs are considered to be those which have the most potential for expediting the movement of traffic (and this) first function, enhancing roadway capacity, can have a pronounced influence on ETE."

Applicants' Direct Testimony No. 7 (Evacuation Time Estimate and Human Behavior in Emergencies),

November 5,

1987, pp.

67-68.

While therefore recognizing that appropriate and timely staffing of "the most important" or top 10 wuts ucit-ow. e t m at.u

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priority TCPs can significantly influence overall evacuation times, the exercise completely failed to test ADY of the three TCPs that Applicants deem most critical in the entire New Hampshire EPZ.

To understand the rationale underlying the sensitivity runs relating to ETE to the manning of TCPs, however, it is necessary to delineate the various functions of traffic control.

These functions, in decreasing importance, include:

- Enhance roadway capacityt

- Guide evacuees along recommended routest

- Expedite traffic movement;

- Provide assurance to the public;

- Surveillance In general, a TCP performs more than one of these functions.

Some TCPs, however, are designed primarily to perform one of the two most important functions.

The first

function, enhancing roadway capacity, can have a pronounced influence on ETE.

Such tactics are applied sparingly during an evacuation since they can be 4

resource intensive.

These tactics, however, can be effective in reducing ETE when effectively and strategically applied.

The most recent analysis performed with respect to this matter reveals that three TCP locations within the New Hampshire portion of the EPZ have been designed primarily as capacity enhancing:

A-HB-03, A-HB-04 and D-HA-02.

These TCPs will serve to expedite the traffic movement from within the Town of Hampton,

]

including Hampton Beach.

Id. at pp. 67-68.

1 By Applicants' admission, all three of the most critical TCPs in the New Hampshire EPZ are locnted within the Town of Hampton, with two d

of those TCPs situated in Hampton Beach.8 None of these three 8

l A-HB-03 and A-HB-04.

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critical TCPs were involved in, woro managed, or woro staffed, during the emergency exerciso.

The exerciso thorofore failed to test or evaluate this major portion of the NHRERP, which is designed to expedite evacuation of the highest and most densely populated beach area in the EPZ.

FEMA itself highlighted the extremo obstacles posed to an adequate evacuation by the "thousands of beachgoers in the Scabrook EPZ," FEMA Profiled Testimony, NHRERP (9/11/87), pp.

38-39, and has recognized the necessity for an adequate demonstration of the "organizational ability and resourecs necessary to control evacuation traffic."

FEMA Objectivo 20.9 Yet the exercise ignored all of th7 critical TCPs, and ignored the beach area as well.

REPLY TO RESPONSES RE: BASES D.

F AND G:

Roolv to Aeolicants' Position Applicants' position is again vague and deficient.

The only additional objection prof fered by Applicants concerns Basis G, which alleges the exorciso failed to adequately test for the availability of sufficient manned emergency vehicles.

Those capabilities, in FEMA's

view, represent a primary component of the NHRERP strategy to 9

"FEMA objectives can serve as guidance as determining what the major observable elements are" which must be exercised prior to licensing.

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adequately protect the public, as evidenced by FEMA's exercise otsjectives.10 The basis raises a significant and litigable issue.

Renly to Staff's Position The Staff does not object to admission of Bases D, F and G to the extent they allege the exercise was not of sufficient scope in the areas referenced.11 Respectfully submitted, TOWN OF HAMPTON NEW ENGLAND COALITION Oil NUCLEAR POLLUTION t

Dated:

October 21, 1988 By Matthew T.

Brock Shaines & McEachern, P.A.

25 Maplewood Avenue Portsmouth, NH 03801 (603) 436-3110 10 Objective 19.

Demonntrate the ability and resources necessary to implement appropriate protective actions for school children within the plume EPZ.

Objective 20.

Demonstrate the organizational ability and resources necessary to contral evacuation traffic flow and to control access to evacuated and sheltered areas.

11 While accepting Bases D, F and G as drafted, the Staff improperly again seeks to limit TOH only to the referenced bases.

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gE,7TIFICATE OF SERVICE

'88 OCT 24 P12:18 i

I, Matthew T.

Brock, one of the attorneys for the Town of Hampton 1988, M,I,made service of the herein, hereby certify that on October 21, NEW QLAND COALITION ON foregoing document, TOWN OF HAMP' ION AND NUCLEAR POLLUTION REPLY TO THE RESPONSES OF THE STAFFi@ND ' APPLICANTS TO INTERVENORS CONTENTIONS ON GRADED EXERCISE, by depositing copics thereof in the United States Mail, first class postage prepaid for delivery (or, where indicated, by Express Mail, prepaid) addressed to:

• Ivan Smith, Esq., Chairman

• Dr. Jerry Harbour Atomic Safety & Licensing Board Atomic Safety & Licensing Board (Off-Site)

(Off-site)

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comm.

East West Towers Building East West Towers Building 4350 East West Highway 4350 East We:st Highway i

Bethesda, MD 20814 Bethesda, MD 20814 1

• Judge Gustave A.

Linenberger, Jr.

• Atomic Safety & Licensing Atomic Safety & Licensing Board Appeal Board Panel (Off-Site)

U.S.

Nuclear Regulatory Comm.

U.S. Nuclear Regulatory Commission Washington, DC 20555 East West Towers Building 4350 Eact West Highway

• Thomas Dignan, Esq.

Bethesda, MD 20814 George H.

Lewald, Esq.

Kathryn A. Selleck, Esq.

• Adjudicatory File Ropes & Gray Atomic Safety & Licensing Board 225 Frankin Street Panel Docket (2 copies)

Boston, MA 02110 U.S. Nuclear Regulatory Commission Eaut West Towers Building

• Carol S.

Sneider, Esq.

4350 East West Highway Stephen H. Oleskey, Esq.

Bethesda, MD 20814 Allan R.

Fierce, Esq.

Department of the Atty. General

• Stephen E. Merrill, Esq.

One Ashburton Place George Dana Bisbee, Esq.

Boston, MA 02108 Office of the Attorney General State House Annex

• Diane Curran, Esq.

Concord, NH 03301 Andrea C.

Ferster, Esq.

Harmon & Weiss 2001 S Street, N.W., Suite 430 Washington, DC 20009-1125

• Sherwin E. Turk, Esq.

Office of General Counsel U.S. Nuclear Regulatory Commission

• Richard R.

Donovan 15th Flaor - One White Flint North Federal Emergency Mget. Agency 11555 Rockville Pike Federal Regional Center i

Rockville, MD 20852 130 228th Street, S.W.

Bothell, Washington 98021-9796 I

Philip Ahrens, Esq.

Robert A.

Backus, Esq.

Assistant Attorney General Backus, Meyer & Solomon Office of the Attorney General 111 Lowell Street State House, Station 6 Hanchester, NH 03105 Augusta, ME 04333 Janc Doughty Michard A.

Hampe, Esq.

Seacoast Anti-Pollution League Hampe and McNicholas 5 Market Street 15 Pleasant Street Portsmouth, NH 03801 Concord, NH 03301 William S.

Lord, Chairman Charles P. Graham, Esq.

Board of Selectman Murphy & Graham Town of Amesbury 33 Low Street Town Hall, Friend Street Newburyport, MA 01950 Amesbury, MA 01913 R. Scott Hill-Whilton

!!. Joseph Flynn, Esq.

Lagoulis, Clark, Hill-Whilton Office of General Counsel

& McGuire Federal Emergency Mgmt. Agency 79 State Street 500 C Street, S.W.

Newburyport, MA 01950 Washington, DC 20472 Ashod N. Amirian, Esquire Judith H. Mizner, Esq.

376 Main Street 79 State Street Haverhill, MA 01830 2nd Floor Newburyport, MA 01950 Senator Gordon J. Humphrey Senator Gordon J. Humphrey U.S.

Senate One Eagle Square, Suite 507 washington, DC 20510 Concord, NH 03301

( Ka- ' '

Tom Burack)

(Attn:

Herb Boynton)

Leonard Kopelman, Esquire

• Robert R.

Pierce, Esq.

Barbara J. Saint Andre, Esquire Atomic Safety & Licensing Board Kopelman & Paige, P.C.

Panel 77 Franklin Street U.S. Nuclear Regulatory Comm.

Boston, MA 02110 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Beverly Hollingworth 209 Winnacunnet Road Hampton, NH 03842 5'T's s

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Matthew T.

Brock

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