ML20205R382
| ML20205R382 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/03/1987 |
| From: | Backus R BACKUS, MEYER & SOLOMON, HAMPTON, NH, MASSACHUSETTS, COMMONWEALTH OF, NEW ENGLAND COALITION ON NUCLEAR POLLUTION, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#287-2999 OL, NUDOCS 8704060331 | |
| Download: ML20205R382 (22) | |
Text
9 ff UNITED STATES OF AMERICA DOLKETED NUCLEAR REGULATORY COMMISSION USNRC ATOMIC SAFETY AND LICENSING APPEAL BOARD gg Before Administrative Judges:
Alan S.
Rosenthal, Chairman GFFICE OF SELL.iAiJ Gary J. Edles 00CKEilNG ' 'knVICf.
Howard A. Wilber BR A NC$1 b j/ )!-d d-l In the Matter of
)
Docket Nos. 50-443-OL PUBLIC SERVICE COMPANY
)
OF NEW HAMPSHIRE, et al ) (ASLBP No. 82-471-02-OL)
(Seabrook Station, Unit 1 )
(Offsite Emergency Planning)
JOINT INTERVENOR APPEAL BY MOTION FOR DIRECTED CERTIFICATION NOW COME the Commonwealth of Massachusetts, the Town of Hampton, the Seacoast Anti-Pollution League (SAPL) and the New England Coalition on Nuclear Pollution (NECNP) and jointly move for directed certification of the ASLB 's Memorandum and Order of March 20, served on March 23, and received by counsel for SAPL on March 25, denying their most recent Motion for Modification of the 7.SLB 's schedule for litigating off-site emergency planning contentions on the New Hampshire Radiological Response Plans (NHRERP).
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This Motion is based on the premise, as demonstrated below, that the Board 's schedule is so compressed that it will deny the parties to this proceeding a fair hearing, contrary to both the provisions of 10CFR S2.718 which states that "A presiding officer has the duty to conduct a f air and impartial hearing according to law...",
and the United States
' Constitution.
This Appeal Board 's prompt intercession is essential to assure the parties to this proceeding are provided with the minimum opportunity to prepare for and to participate at a hearing in a complex area in a manner consistent with the Commission's rules and due process.
A.
Standard for Directed Certification This Appeal Board has already noted that it will consider a scheduling order when "The schedule deprives the complaining party of its right to due process."
ALAB 858, Slip Opinion, page 6.
That is the case here, as the following will demonstrate.
B.
The Order Below The Joint Intervenor 's complaint is the Scheduling Order entered by the ASLB on January 9,1987.
That Order has now, by further order dated March 20, been affirmed in its entirety.
The Order in question set up a tightly compressed schedule for litigation of the NHRERP contentions, ending in a hearing "no sooner than May 28, 1987." 1/
1/ This date was later changed to provide for hearings to be held in the Federal Court House in Concord, NH on
. The schedule was to commence with the undertaking of discovery on February 13, when the Board stated that it would rule on the various contentions proferred by the Parties.
However, the Board 's order ruling on contentions did not issue until February 18 or 19 (the Order is dated the 18th, but it says it was served on the 19th), and was not served by express mail (which the Board routinely has required of all the parties to meet deadlines) and hence was not received by some of the parties, SAPL and Massachusetts, until February 23.
The Order, in f act, was not received by the New Hampshire Attorney General until February 24.
As a result, instead of an already miniscule 21 day period for preparing and filing discovery requests originally contemplated by the Board, the schedule was now compressed, by the Board 's own f ailure to meet its own deadline, to a mere 11 days.2/
1/ (cont) the week of June 1, and the week of June 22, but without change in the other scheduled dates. See Memorandum of Order of Feb. 18, 1987.
2/ It should be noted that not only did the Board, without explanation or apology, fail to meet its own deadline, it ruled on the various contentions in summary fashion, and without supporting opinion.
It went on to state that it would entertain no motions for reconsideration of the dimissed contentions until it had furnished its supporting opinion, which has not yet been furnished.
Thus, the Board
1 The Board 's Order-allowed the following time periods for-the Parties to prepare for litigation on a set lof NHRERP's consisting of some 31 volumes of complex material, covering everything from evacuation time estimates based upon computer models, population density estimates, decontamination centers at four host community facilities, traffic control plans, 4
personnel monitoring issues, and the like i
Starting on February 13....
--21 days for discovery (subsequently reduced to 11 by the Board 's failure to meet its own February 13 deadline )
--Thirteen further days to respond to discovery
--Seven further days for filing of summary disposition
- motions,
--Twenty-one further days for responding to summary summary disposition motions I
--Eleven further days for responding to summary disposition motions.
--Fourteen further days for the Board to rule on~the 2/ (cont) is forcing the parties into a position where the hearing is scheduled in June, without giving the parties any i
indication of why certain contentions were: admitted and others rejected, and without providing any opportunity to file Motions for Reconsideration on the rejected Contentions -
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. summary disposition motions, if the Board meets its own deadline
--Ten further days for simultaneous filing of testimony by all parties
--Eleven further days to the commencement of hearings The total time allowed for the parties to engage in i
discovery and prepare testimony on the NHRERP's on the. basis of the numerous contentions filed, was 108 days, or 151/2 weeks.
3/
C.
Denial of Procedural Richts a.
Backcround Before proceeding to illustrate the astounding 3/ The Board, in a statenent remarkable for its intellectual dishonesty, suggests in its March 20 M:rnorandum and Order " Affirming the New Hampshire Radiological Em-ergency Response Plan (NHRERP) Hearing Schedule in Its Entirety" that "frm Septenber, 1986 to June 1, 1987, when these hearings will begin, hardly could be said to be so brief a period that four months would be needed to couplete discovery." This, of course, ignores the Board's own Order and the Ca mission's regulations (10CFRS2.740(b) (1), which both provide that discovery cmmences only -
when rulings on the admissability of contentions are made. Again, these rulings were not made until February 18 or 19. Though the latest NHRERP's were available in Septenber, these Parties, save Hampton, were at that time fully occupied with t
the preparation for the so-called "on-site hearings" held that month and in early October.
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. procedural injustice of the Board 's January 9 Order, as reaffirmed by its March 20 Order, it is important to place i,
this particular proceeding _ in the context lof the overall issue of Seabrook emergency planning litigation.
The Licensing Board has already forced a wholly premature hearing on a key emergency planning issue.. Over objection of the intervenors, the Licensing Board, since reconstituted with one different judge, but having the same chairperson, required hearings to proceed on the Applicants' Evacuation Time Estimate (ETE) in August of 1983.
Although the Board insisted on litigating the ETE issue at that time,_
at great expense to the parties, and despite the absence of any state or local emergency plans, and again on a very tight-schedule, it never felt any need to decide the issues which it forced into litigation.Those issues have now become moot with the furnishing of the' Revision 2 emergency plans, which plans now include a different ETE.
Today, the Board persists in its unreasonable attempt to force premature litigation of Seabrook emergency planning issues on a piecemeal basis.
The fact is that the Commission's -regulatory guidelines, set forth in NUREG 0654, Rev.1, call for emergency planning to be done on a " fully integrated" basis because "the public can best be protectyd when the response by all parties is fully integrated," (page 23). However,
despite this regulatory guideline and the acknowledged f ac t-that no plans whatsoever are available for the approximately one-third of the plume EPZ in Massachusetts, and despite the
a
- q-fact that, whatever the outcome of'the presently proposed hearings on the NHRERP, rua authorization to issue a license can result, the Board persists in its rush to judgment.
The joint.movants call upon this Appeal Board to
' determine that the entire scheme being pursued by the Licensing Board is intrinsically hostile, biased, and without rational basis.
It hardly need be added that this' proposed schedule does indeed affect the structure of this proceeding in " pervasive manner" within this Board 's prior articulated i
basis for directed certification.
1 There is a second problem with the Board 's precipitous 1
schedule.
The f act is that the NHRERP's provide, as is not i
uncommon, a moving target.
The present NHRERP designated.
1 "Rev.2 "
is the third complete set of plans to have been e
offered by New Hampshire Civil Defense.
Meanwhile,New Hampshire has indicated, in its interrogatory answers, that a further revision is to follow.6/
If the NHRERP is to be revised in an effort to meet the i
contentions filed by these joint intervenors, it is hard to see why the litigation should not now be deferred when there 4
is absolutely no reason to proceed with the litigation now, in view of the undisputed f act that until the issue of j
Massachusetts emergency planning is resolved, either by the Appplicant's Petition for reduction of the EPZ, or by the rule change proposed at 52 Fed. Rec.6980 or by the so-called "Shoreham" approach of having utility plans filed, no license can be authorized as a result of these expedited hearings.
6/ Response.to Interrogatory 37 states: "The revision of the NHRERP will provide the names of the supervisory pool."
l
.4
" b.
Schedule Deficiencies i
Since these movants filed their. " Joint Motion to-l Extend Hearing Schedule" on February 25, and since I
Massachusetts filed _its further " Motion for Reconsideration" on March 2, two important developments have occurred.
- First, the parties have attempted to comply with the compressed I
discovery schedule, and responses to the initial round of discovery have been received.
Second, the Board has denied 4
the Motion to Extend Hearing Schedule, and reaffirmed its
- proposed schedule "in its entirety."
(Memorandum and Order of March 20).
The latter development makes clear that the Motion is ripe.
The former development demonstrates the need for relief, as shown below :
1.
Discoverv Responses Th'e Applicants, FEMA, and the State of New Hampshire have all responded to the discovery requests furnished by these joint movants. Those responses indicate that none of the responding parties, including the Applicants which have the burden of proof, are yet prepared Lto designate which witnesses will be tescifying in the hearings now scheduled for June 1.
4/
4/ Staff identified a potential witness, Thomas Urbanik, but states it cannot describe his testimony because " Staff has not developed a position with respect to the admitted contentions."
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The discovery schedule advanced by the Board in-its January 9 Order did not' provide for any follow up discovery, and did not provide an opportunity for depositions.
Some of the joint movants,in particular the Commonwealth of Massachusetts, would have considered deposing witnesses prior to the hearing, but no provision for depositions was made, although depositions are specifically authorized as a method of discovery by the Commission's Regulations. (10CFR2. 7 40 (a) ).
All of the movants would pursue a second round of interrogatories, in an attempt to follow up on the responses now received from the applicants, FEMA and the State of New Hampshire.
This opportunity has not been afforded.
l Thus, in short, the Board's schedule now affirmed in its entirety, deprives the parties of any meaningful opportunity for discovery.
It is as if the parties were being relegated to the position of reporters at a Presidential news conference.
In short, the Board 's schedule deprives the parties of any meaningful opportunity 1
i j
for discovery, deprives a meaningful opportunity for 1
participation in the hearing required to be provided under S189 of the Atomic Energy Act, and deprives the parties of i
due process of law.
2.
Absence of FEMA and Staff Position The Staff and FEMA have both stated, in discovery responses, that they take no position on the adequacy of the NHRERP.
FEMA states:
" FEMA has not developed a specific position regarding the admitted contentions or subparts."
See FEMA Answer Interrogatory 1.
FEMA's lack of position alone makes the scheduled hearing f
premature, since under 10CFR50.47(a) (2) the NRC is to base its "its findings on a review of the Federal Emergency Management Agency [ FEMA] findings and determinations as to whether state and local plans are adequate...."
No rationale has been provided for proceeding to licensing hearings on plans when the agency with a designated regulatory role in determining the adequacy of those plans has not been able to formulate its own position.
FEMA's position should be available to the parties as part of the hearing process.
To proceed to hearings without a FEMA position will result in one of two unacceptable conclusions.
Either the parties will have been deprived of an opportunity to litigate the contentions in light of FEMA's position, which would deny the full hearing intended by S189 of the Atomic Energy Act or, alternatively, the hearings will again have to be repeated, as premature, as was the case with the 1983
)
hearings on the Applicants' ETE.
)
3.
Inadeouate Time for Preoaration of Testimony The Board 's Order, as reaffirmed in its entirety on March 20, provides for simultaneous filing of testimony by the parties.
Since the Applicants have the burden of proof, and
neither FEMA nor the Staff are prepared to take a position on the contentions admitted by the Board, it is impossible for the intervenors to know what testimony they should address.
The Board 's apparent requirement that all parties (including Applicants, intervenors, FEMA and NRC staff) submit their testimony simultaneously places intervenors, including interested states, in the nearly impossible position of having to submit testimony to rebut that of the Applicants, who have the burden of proof, and presumably that of FEMA, without having first reviewed the Applicant's testimony.
In addition, the Board has not met the facts set forth in an affidavit furnished by a key intervenor witness, Dr.
Thomas Adler (see Dr. Adler's affidavit, attached).
In his af fidavit, Dr. Adler states he will be unable to file testimony before July of 1987, because of the need to review certain computer models available from FEMA.
As to this, the Board cavalierly stated as follows:
"Dr. Adler gives us no insight as to why he will require until July 1987 before filing his testimony since he has been identified as the Town of Hampton's expert witness since November 1986."
i What bearing the disclosure of Dr. Adler's availability as an expert has on his ability to file testimony, when that testimony is based upon the availability of material available from another party,was not explained.
The Joint Intervenors submit it is the Licensing Board j
....-. - -.. ~
4 which has demonstrated an inability to " enlighten."
Dr.
Adler's factual affidavit is both specific and quite
- enlightening.
He specified that he needed access to certain-i-
l, computer runs, which he had "not yet received.
The Board 's premise for rejecting Dr. Adler's need for
. time to prepare his testimony is well without foundation.
The Board would impose on the' parties a duty to expend resources and prepare testimony merely because, in advance of j
knowing what contentions are admitted, dure were available certain " status reports" on the continued revision of the i
l NHRERP.
The bias and hostility _of the Board to these parties could not be more clear.
4.
The Board 's Order Fails-to Comolv with the NRC 's Own Procedural Recuirements The Board 's Order specifically rejected ' the l
Massachusetts request, in its March 2 Motion for i.
Reconsideration, that the Board hold a pre-hearing conference as required by 10CFRS2.752 and also denied, while f ailing to acknowledge the argument advanced by Massachusetts,that under the regulations a shortening of the 15 day period between' the filing of testimony and the start of hearing can be wajved only upon the objection of a party.10 CFR 2.743(b)
The 1
l cited regulation provides that, in any event, at least 15 days in advance of the session at 'the hearing at which testimony is to be presented, such testimony shall be filed I
and available to the Board and the parties.
The Board 's i
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. Order leaves only 11 days between the date scheduled for submission of written testimony and the commencement of hearings, and therefore violates the Commission's regulations, which provide for shortening of the required 15 day period only upon the objection of a party.6/ There has been no objection to the minimum 15 day time period, and therefore the schedule, as affirmed in its entirety violates the Commission's Regulations.
The Licensing Board 4
does not even deign to address this issue.
Instead, it concludes its Order with the gratuitous and insulting comment I
that "One must actively prepare the case or be left at the gate when the bell rings."
CONCLUSION This Appeal Board should be aware that the real reason driving the Licensing Board schedule, in'this instance, has even less to do than usual with the normal objective of meeting the Applicants' licensing schedule.
In this case, the real factor driving the Licensing Board schedule is the fact that the Board has found the Federal Court House in Concord, New Hampshire to be available for two weeks in June, and i.s extremely loath to give up access to this federally 7/ Indeed, if all dates are presumed slipped to the extent the Board's own Order on Contentions was delayed, six days, only five days are allowed.
I
secure facility.
It would be well for the Licensing Board, and this Appeal Board, to ask what has caused an agency of-the government that is supposed to protect the people to feel a need to hide out in a federal secure facility.
Indeed, as this Appeal Board will recall, all licensing hearings at the construction permit were held, without incident, in such unsecure and un-federal facilities as the basement of the United Methodist Church in Hampton.
We submit that what is driving the Board to pursue a schedule which blatantly denies the parties basic procedural due process is the same thing that is requiring the Board to seek the seek the security of a federal facility.
The more this Licensing Board, and the other boards serving this agency contribute to the widespread perception that this agency is not a neutral and disinterested tribunal, but an advocate for the Applicants,the more this agency will need to seek secure facilities when it holds hearings which the public perceives to be a fraud and a sham.
The time to start changing this perception is now, and this Appeal Board can contribute to that effort by at 1cng last indicating that this agency does have some indpendence from the Applicant's and is prepared to insure the parties to j
this proceeding of a fair hearing.
If this Board does not act, the continuing erosion of this agency 's credibility, which we believe stands at an all time low, will' continue, with the inevitable result that any revival of nuclear power in the United states will come only over the objection of I4 n
j
. - citizens who no longer believe in their government's ability to protect their interests.
Respectfully submitted,
fh bn Rober6 A. Backus BACKUS, MEYER & SOLOMON 116 Lowell St.
Manchester, NH 03105 603-668-7272 I hereby certify that the enclosed has been sent to all persons on the attached service list by first class, postage prepaid mail.
d'obert
. Backus
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UNITED STATES OF AMERICA NUCLEARREGULATORY COMMISSION Before the ATOMIC SAFEIY AND LICENSING BOARD
)
INTHE MA' ITER OF
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DOCKET NOS.
50-443-OL 50-444-OL PUBLIC SERVICE COMPANY OF )
NEW HAMPSHIRE,et al
)
(Off-site Emergency (Seabrook Station, Units 1
)
PlanningIssues) and 2)
)
1 AFFIDAVIT OF DR. THOMAS J. ADLER My name is nomas J. Adler, and I hereby depose and say as follows:
- 1. I have been retained by the Intervenors in the Seabrook Nuclear Power Plant Licensing proceedmg to review and assess the evacuation time study and traffic management plan co in Volume 6 of the New Hampshire Radiological Emergency Response Plan.
- 2. I have a PhD in Transportation Systems from MIT, taught at Dartmouth College's Thayer School of Engineering in the areas of transportation planning / engineering and computer-based modeling methods, and have extensive experience in planning, analyzing, and evaluating transportation systems at the local, regional, national, and international levels. A brief stateme my professional quahfications is attached hereto.
- 3. I reasonably anticipate that I will be able to complete an adequate technical review and assessment of the evacuation time study and traffic management plan within 3 months from the timeI receive (1) computer-readable and printed listings of allinput files and data used in the IDYNEV runs domented in Volume 6, and (2) paper copies of the actual outputs produced by the sameIDYhTV runs.
- 4. I have yet to receive any of these items, but I am ppued to begin my work as soon as Ireceive them.
- 5. Assuming that I receive all of the items listed above within the next two weeks,I will only have begun to do my work by March 6,1987, the date by which, I am told, the last discovery request is due. I fully anticipate that, once I begin work with the IDYhTV system,I will find that there are other items I will need to obtain to thoroughly assess the reliability of the work teflected in Volume 6. He need for these items may not be apparent until April 15 or even later, depending on when the materials set forth in paragraph 3 above are received. Incorporation of these additional materials into the technical studies could require an additional month of time, beyond the three months estimated in paragraph 3.
- 6. I do not expect to have completed my technical assessment sufficiently by March 19, 1987, in order to offer even preliminary findings to the Intervenors so that they may be able to respond to interrogatories on or before that date. I expect to be able to offer my preliminary findings within two months of receipt of the materials referenced in paragraph 3.
- 7. I will be unable to file my testimony prior to the beginning of July,1987.
- 8. The time estimates presented herein are based on the best information available at this date and assume, in particular, that reasonable access to the IDYNEV model is provided by the applicant or by the Federal Emerge.cy Management Agency (FEMA). Additional time may be necessary if such access is not provided.
Signed under the penalties of perjury this 17th day of February,1987.
7b
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'Ihomas J. Aber
000KETED ADDENDUM TO OUR JOINT INTERVENOR APPEAL USNRC 1
BY MOTION FOR DIRECTED CERTIFICATION g Ant -3 N0:19 Since preparing the enclosed Appeal by motion for Directed GFFICE OF SECit kJY Certification, these joint intervenors have received notice 0pEtwo & SI PVICI-BRANCH further developments which will seriously and adversely impact their ability to respond to the Board 's Schedule for Litigation of the New Hampshire NHRERP.
First, the Applicants have filed motions for summary disposition on all admitted contentions.
The material filed in support of these motions for summary disposition is voluminous (It arrived in a cardboard box measuring more than 6 inches deep.)
Pursuant to the Board 's Order, allowing 21 days for responses opposing or supporting these notions, responses are due by April 16.
In view of the enormous amount of summary disposition materials filed by the Applicants (although the Applicant could not identify any witnesses when they filed their answers to interrogatories on March 19),the joint movants will be forced to expend all available time during the next three weeks preparing affidavits and legal memoranda in opposition to the motions for summary disposition, and will have no time available to proceed with preparation for the hearing now scheduled for June 1.
The second development is the decision of the on-site licensing board, the Wolfe Board, to authorize issuance of a so-called 5% license, subject to certain conditions.
As of this date, the joint movants are not in possession of the Board 's decision, but anticipate appeals of that decision, and depending J
4 a
upon wh' ether or not the Commission acts to vacate the present stay -ordered January 9 that prevents that decision from becoming effective, may require extensive effort on the part of these parties to prepare and file stays pending appeal.
All of the foregoing, in addition to the reasons set forth in the body of this joint appeal, dictates that this Board's intervention is necessary to assure that the rights of the Parties to an adequate and fair hearing is honored.
RELIEF REQUESTED For the reasons stated, the jcint movants pray that this Board Order Directed Certification and provide the following:
1.
Vacation of the present litigation schedule, P
2.
Provision for a pre-hearing conference and compliance, at a minimum, with the Commission's regulations concerning time periods.
3.
Guidance as to an appropriate schedule, to include at a minimum a four month extension of all deadlines, as sought by these movants Joint Motions of February 25, 1987 (attached hereto).
Respectfully submitted s/ Nod @rt"X'. Backus 116 Lowell Street Manchester, NH 03105 603-668-7272 I hereby certify that the enclosed has been sent to all persons on the attached service lisL by first class mail, postage prepaid.
YWM ~
' ROBERT A. BACKUS
~
s and submit more specific discovery requests through follow up interrogatories or depositions, to which Intervenors are entitled in this case.
Duka Enwer Co. LCataEba Enslaar Statinnt Units 1 and 21, LBP-82-ll 6, 16 NRC 1937, 1945(1982).
d.
This Board's failure to amend an unduly restrictive hearing schedule will-constitute legal error which will require a reopening of the hearing in this case.
Entthern Indiana Enblis H2I21s2 cm..(Halllyt Generating Statinnt Euclear-ll, AL AB-2 4 9, 8 AEC 9 80 (197 4),
e.
The public interest will be substantially and adversely affected, and the public will be denied a meaningful opportunity
(
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to participate and remain informed on issues of paramount public safety.
HRE Entamas Eleetrin EnEgI Cm. innnglas Enint Hus12AI Generating Station, Units 1 and 21, ALAB-277, 1 NRC 53 9(1975).
Wherefore, the Town of Hampton respectfullh requests this Board to ORDER that the hearing schedule be extended as follows:
Date Deadlines l
1 l July 6, 1987 Discovery closed (las t discovery request due).
l! July 19,1987 Answers to last interrogatories due I
within 14 days after the close of discovery.
July 26,19 87 Deadline for motions for summary disposition on late-filed Rev.
2 Contentions admitted or for other 5
SHAINES & McE ACHERN -==cnssova$ associato. a**oewes
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contentions as to which circumstan--
ces have changed such that summary l
disposition is now appropriate.
August 16, 1987 Resp _onse opposing or supporting motions due within 20. days.
August 27, 1987 Opposing parties may file responses to new facts and arguments presented.
in statements supporting-motions for summary disposition.
September 11, 1987 Board Order ruling on motions for:
summary disposition.
September 21, 1987 Prefiled testimony due 10 days after Board ruling on motions for summary disposition.
Hearings to commence as soon there-after as scheduling permits.
DATED:
- /I#
Respectfully submitted, SHAINES-&
ACHERN Attorne or the Town of Hamp n
By:
au McEache By:
A\\ <
x Matthew T.
Brock The undersigned further say that they are authorized to submit this joint motion on behalf of all the named petitioners..
j Respectively submitted, All th named petitio Wrs by, d
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A' horized Representative s
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Authorized Representative 6
SH AINES & McEACHERN.==cessoo.a6 associatoe avve==ses i
'T s
CERTIFICA1'E OF SER'VICE AND SERVICEjLIST 3
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O&.C TC.7 t
Jose Asst.Gn.Cnsl.
Helen Hoyt. Chm.
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'i homas Dignan, Esq.
- Fed. ph Flynnhigmt. Agcy.
Admn. Judge Rapes &. Gray
- Emerg, 500 C.St. So. West Atomic Safety & gicg r4 N0:lloston 2s Traxklin St.
Washington, DC 20472 USNRC 1
, ?!A 02110 Washingtoa, DC 20555 0FFICE ? IE..~ eb Y Office of Selectmen Town of Hampton Falls Dr. ' Jerry HarboEMIbHC '
Dockoting & Serv. Sec.*
Admin. Judge Hampton Falls, NH 03844 Atomic Safety & Lie. Erd' O di.e of the Secretary USFRC USNRC Washington, DC 2055'S '
Washington, DC 20r55 Sherwin E. Turk, Esq.
4 Dr. G$tave A. Linenberger
- Jane' Doughty Office of Exec. Legl. Dr.
USNRC j.dmb Judge SAPL Atomic Safety L' Lic. Brd.,
- 5. Marivs t ' St r+ et Washington, D.C.
20555
.USnne Po rt sr.'ou t h, NH 03801 Washington, DC 20555 Phillip Ahrens, Esq.
Paul McFachern, Esq.
George Dani Bisbee, Esq.--
Asst. Atty. General Matthew Brock, Esq.
Attorney Gene'*al's OlF.
State House, Sta. #6 25 Maplewood Ave.
Stste of New Hampshire Augusta, ME 04333 P.O. Box 360 Concoi-d, NH' 03301 Portstrouth, NE 03801 Carol Sneider, Esq., Asst. AG Diane Curran, Esq.
William.S, Lord- '
4 One Ashburton Place, 19th Floor Harmon, Yeiss Board of S?lectnan 2000i'S Streer WW Suite 430 Tonn Hall-Friend St.
Boston, MA 02108 Wnshington, DC 20009 Amedou2% SQ 01913 Richard A. Hampe, Esq.
Maynard YoLng, Chainmn New Hampshire Civil Delense Board of Selectrren Sandra,G;vutik m
Agency 10 Central Road Tmm'or unsington Box IJ5e.
Hampe & McNicholas Rye, NH 03870 35 Pleasant St.
East K; n pton, r'it. 03827 Concord, NH 03301 Judith H. Mizner, Esq.
Edward 'Ihomas Mr. YobeMHarrisca
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Silverglate, Gertner, IBIA
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Pre.s. & Chief Exec. Officer Baker, Fine, Good & Mizner 442 J.W. McCor:mek (P001)
PSO3 88 Broad Street Boston, MA 02109 Boston, MA 02110
- P.O. Box 330 Manchester, NH 03105 A)an Rosenthal, Chainnan 4 Atomic Safety & Lic. Appeal
'f, erta Pevear U
Board Etate Rep.-Town r.! Hanpt Fall W. NRC Drinkwater Boad Washington, DC 20555 11 npton Falls, "P. 03844 '
Gary Edles W-Atomic Safety & Licensint;
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A resi Board F
U.S.NRC Washingcen, EC 20555 Hcward A. Wilber 4
Atomic Safety & Licensing Appeal Ecard U.S. NRC Washington, DC 20555 n
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