ML20205R578
| ML20205R578 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/03/1988 |
| From: | Selleck K PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | MASSACHUSETTS, COMMONWEALTH OF |
| References | |
| CON-#488-7455 OL, NUDOCS 8811100070 | |
| Download: ML20205R578 (23) | |
Text
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%7+SS i 4 l . - i :i:
\ tLLATED CUttttt.w>noy
's l November 3, 1988
'68 NOV -8 P 4 .50 UNITED STATES OF AMEhICA ,g,,
NUCLEAR REGUIATORY COMMISSION f$ i k .,
before the ATOMIC SAFETY AND LICENSING BOARD
)
l In the Macter of )
)
PUBLIC SERVIC1; COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) SC-444-OL
)
(Seabrook Station, Units 1 and 2) ) (Off-site Emergency
) Plamiing Issues)
)
APPLICANTS' RESPONSE 10 "(MASS AG'S]
FIRST REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE APPLICANTS REGARDING THE (SPMC]"
Pursuant to 10 C.F.R. I 2.741, Applicants make the following responses to "(Mass AG's) First Request for the Production of Docusents to the Applicants Regarding the (SPMC)."
As to the Place and Manner of Production:
Applicants will produce for the parties' inspection documents as agreet herein on Nove2er 4, 1988 at 10:00 a.m.
at Seabrook Station. Due to the breadth of Mass AG's requests and the number of documents to be produced, Applicants, to facilitate review, will provide a master index by docusent title and request number. It copies are 831110o070 001103 gDR ADOCK 06000443 hs0
t 9
requested, Applicants will provide them with the costs of copying and delivery to be advanced or guaranteed by the requester. Applicants object and move for a protective order holding them safe from Mass AG's specification of the place and manner of production, on several grounds. First, some of the documents are in use by the Applicants at Seabrook Station and are also responsive to production requests or interrogatories of parties other than Mass AG. Second, the documents requested by Mass AG are voluminous in number and the physical and time burdens of producing them in Boston and then returning them to Seabrook are unjustifiable costs in the circumstances. Mass AG has not requested copies, except for two specific catogories, and, without a specific request, Applicants will not make an across the board second copy of all the responsive documents, as the cost would be prohibitive. Third, Mass AG shculd not be heard to request that Applicants deliver anything to Mass AG's premises, inasmuch as Mass AG has refused to pay the bills for delivery costs of the last three productions of exercise documents.
Indeed, Mass AG has not replied to correspondence from i
Applicants' counsel who continue to cover his bills.
As to Mass AG's "Definitions and Instructions":
The documents produced will be those documents in the possession of Public Service Corpany of New Hampshire, New Hampshire Yt.nkee Division at Seabrook Station ("NHY"), and employees and contractors thereof. Applicants object to
s producing documents in the pc,ssession of all of NHY's "agents" and move for a protective order against such production as that term as defined is too broad and any search entailed would be unduly and needlessly burdensome.
Mass AG is incorrect in his assertion that his document requests can be "deemed continuing"; they cannot. Where Applicants have not herein objected to requests on legal grounds, they have responded "Applicants will produce the documents requested." That response is completa. The documents that Applicants will produce are all the responsive documents, not privileged, of which Applicants are aware cn the date of prodttction. Should it appear that a document was not produced that should have been, the omission will of course be speedily remedied. However, Applicants disclaim any obligation to continue to produce documents generated or received after the requested document production has been made. Applicants call attention to the fact that they have often provided copies of new documents to Mass AG which fall in categories Mass AG has previously requested. These special considerations, however, it is to be noted, are voluntary, and Applicants are under no legal obligation to offer them. Ein 10 C.F.R. 5 2.740(e).
Applicants object to the definition of "identify" as including "a description sufficient to identify that document 1
- for purposes et a subpoena duces tecum" as Applicants do not i
express any opinion herein on whether a description is or is t
i l
s l
I
. 1 not sufficient for purposes of a subpoena duces tecum. l i
Applicants object to Mass AG's "Definition and l Instruction" 1 H, which would have Applicants give a detailed description of documents that were once in Applicants' possession that would have been responsive to one of Mass AG's roquests. This unbounded request in irrational; Applicants have no way to detail the notas, drafts, correspondence, and other kinds of documents which once existed but of which Applicants do not maintain registers or copies which would be responsive to Mass AG's extreme, broad requests.
Documents which are responsive to more than one request number will be segregated along with the number of the first request to which they are responsive. I Due to the confidential information contained in certain documents called for by Mass AG's requests, production of these documents will be made under the conditions outlined by the Board and adhered to by the parties in the past.
As to Specific Requests for Production of Documents:
Recuest No. 1 Any and all reports, surveys, studies or analyses done in the preparation of or for and/or in support of the SPMC, including but not limited to the following general issues:
Evacuation Process, Personnel and Training, PAR Generation, Communications / Notification, Legal Issues, Protective Actions For Particular Populations, Evacuation Equipment and Facilities, and Coordination of Governmental Resources and Response.
Aeolicants' Response Applicants object to this request on the ground that it 4
calls for documents that are not "relevant to the subject uatter involved in the proceeding," 10 C.F.R. 5 2.740(a),
that is, documents that are not relevant to the admitted contentions on the SPMC. Furthermore, Applicants object to this interrogatory on the grounds that it is overly broad and unduly burdensome. The part of the request which calls for Eny work of counsel on SPMC legal issues seeks privileged materials to which Mass AG obviously has no right.
Applicants object to searching for or identifying such privileged documents because the request is too broad to begin such a search and because the grounds of the assertion of privilege are plain without any further description.
Moreover, the Board has specifically ruled that discovery not be held on the "legal" contentions. Memorandum and Order (Following Prehearing Conference), ASLBP No. 82-471-02-OL at
- 2. Further, Applicants object to producing certain documents containing confidential information. Objections to two specific categories of confidential information are made in response to Requests No. 5, 8, 9, 16 and incorporated herein.
Without waiving these objections, Applicants will produce those items requested, not privileged or confidential, that pertain to issues in the admitted contentions.
Reauest No. 2 Any and all documents generated or received by NHY concerning the adequacy of the SPMC, including but not limited to internal and external communications.
e Acolicants' Resconse Applicants object to this request on the ground that it calls for documents that are not relevant to the subject matter of this proceeding, to wit, the admitted contentions.
I To the extent this request calls for privileged communications with counsel, Applicants object to the request and also decline to identify such privileged documents.
Without waiving these objections, Applicants will produce those documents requested, not privileged, that pertain to the adequacy of the SPMC insofar as it is called into question by the admitted contentions.
Recuest No. 3 Any and all documents reflecting or constituting communications since January 1, 1987, between NHY and outside potential or actual contractors or service providers, including but not limited to bus companies, ambulance companies, tow truck companies, hospitals, the American Red Cross, radio stations, and equipment vendors, for services or equipment needed to implement the SPMC, whether or not such contacts resulted in an agreement.
Aeolicants' Resconse Applicants object to this request on the ground that it calls for documeu s not relevant to the subject matter of this proceeding, to wit, the admitted contentions.
Applicants further specifically object to so much of this request as calls for the production of documents regarding contacts which dit not result in agreements with potential contractors or service providers, on the ground of irrelevance. Without waiving these objections, Applicants will produce those documents requested which both (1) concern 4
contacts which resulted in agreements with contractors or service providers and (2) pertain to issues in the admitted contentions.
Recuest No. 4 Any and all existing contracts or letters of agreement with outside contractors who are currently being relied upon to supply services or equipment to implement the SPMC.
Aeolicants' Response This request is a subset of the last one; Applicants incorporate here their response to Request No. 3.
Recuest No. 5 All NHY ORO recruitment forms and other application forms completed and submitted by individuals to NHY either directly or through their own employers.
Aeolicants' Resoonse Applicants object to so much of this request as calls for personal information about ORO applicants or members.
This information has only marginal or no relevance to the subject matter of this proceeding, while the privacy interests of those individuals are real and substantial. Egg Bratt v. International Business Machines Corn., 392 Mass.
508, 518, 467 N.E.2d 126 (1984); Mans v. Lebanon School Board, 112 N.H. 160, 290 A.2d 866, 867 (1972). Without waiving their objections, Applicants will produce those documents requested for ORO members, with the personal information not related to employment qualification, and which is of marginal or no relevance to the subject matter of this proceeding, redacted.
9 Recuest No. 6 All documents, hand-outs, memoranda, and other materials used in recruiting PSNH's and NHY's own employees to participate in NHY's ORO.
Aeolicants' Resoonse Applicants will produce those documents requested.
Recuest No. 7 All documents, hand-outs, memoranda, and other materials used in recruiting for NHY's ORO at the Yankee Atomic Electric Company, the New England Electric System, and anywhere else where recruiting was carried out.
Aeolicants' Response Applicants will produce those documents requested.
Recuest No. 8 Any and all listings, rosters and directories of the persons comprising NHY's ORO on or about each of the following dates: December 1, 1987; March 1, 1988; May 1, 1988; June 28, 1988; September 1, 1988; November 1, 1988.
The lists, rosters and directories produced shall contain as much of the following information as is available on each ORO member: the ORO position assigned, the person's day-to-day job title or position at their regular place of employment, the name of their regular employer, their work address and telephone number, their home address and telephone number, and their rates of pay for ORO duties. If such information is not available on lists, rosters, or directories, produce the documents which contain this information, or, if the information is listed only in a computer-readable format, produce a copy of the computer files which contain this information.
Aeolicants' Resoonse To the extent that this request appears to direct Applicants to create documents that do not already exist, Applicants object. Applicants further object to this request to the extent it calls for the home telephone numbers and home addresses of individuals on the ground that such I
o information is of marginal or no relevance to this proceeding and the privacy interests of those individuals are real and substantial.
Egg Bratt v. International Business Machines Coro., 392 Mass. 508, 518, 467 N.E.2d 126 (1984); Mans v. Lebanon School Board, 112 N.H. 160, 290 A.2d 866, 867 (1972). Without waiving these objections, Applicants will produce those documents requested with home telephone numbers and home addresses redacted.
Reauest No. 9 All resumes, job histories, and records of the educational backgrounds of each ORO member on each of the dates listed in the previous request.
Anolicants' Response
't Applicants object to so much of this request as calls for personal information about ORO members. This information has only marginal or no relevence to the subject matter of this proceeding, while the privacy interests of those individuals are real and substantial. Egg Bratt v.
International Buriness Machines Coro., 392 Mass. 508, 518,
., 467 N.E.2d 126 (1984); Mans v. Lebanon School Board, 112 N.H.
160, 290 A.2d 866, 867 (1972). Without waiving their objections, Applicants will produce those documents requested for ORO members with the personal information not related to employment qualification, and which is of marginal or no relevance to the subject matter of this proceeding, redacted.
}
o Recuest No. 10 All documents which set forth or describe the criteria, method and manner in which ORO's applicants are evaluated, selected, and 7ssigned to ORO positions.
Aeolicants' Resconse Applicants will produce those documents requested.
Recuest No. 11 Any and all documents which reflect or constitute the terms and conditions of the relationship each ORO member has with NHY's ORO, including but not limited to employment contracts, letters of agreement, memoranda, or provisions of a personnel manual.
Aeolicants' Resconse Applicants will produce those documents requested.
Recuest No. 12 All documents which reflect whether participation in NHY's ORO is or is not a condition of the employment relationship with PSNH or NHY, or the Yankee Atomic Electric Company, or the New England Electric System.
Aeolicants' Response Applicants will produce those documents requested.
Recuest No. 13 Any and all union contracts or agreements, or correspondence with unions, their agents and representatives which mention or refer to the participation by union members in NHY's ORO.
Aeolicants' Resconse Applicants will produce those documents requested.
Recuest No. 14 Any and all documents which reflect or constitute grievances filed by personnel considered as part of the ORO with their employer and/or unions and which grievances concern in any fashion the employees' participation in NHY's ORO.
Aeolicants' Response Applicants will produce those documents requested.
Recuest No. 15 Any and all letters or memoranda of resignation received from ORO personnel as well as notices o' termination of personnel considered as part of the CRO.
Aeolicants' Resoonse Applicants will produce those documents requested.
Recuest No. 16 All correspondence and other records of communications made after January 1, 1987, and which refer to, pertain to or contain information relevant to emergency response planning for a radiological emergency at Seabrook, or the refusal to engage in such planning, or the assessment of response capability, between New Hampshire Yankee (and/or NHY ORO) and er.an of the following:
- a. the six Massachusetts communities, and any of their current or former officials and employees;
- b. the public schools in the Massachusetts EPZ, and any of their current or former of ficials, administrators, or teachers;
- c. the private schools and day care centers in the Massachusetts portion of the EPZ, and any of their current or former officials, administrators, or teachers;
- d. the nursing homes in the Massachusetts portion of the EPZ, and any of their current or former officials, administrators, and staff;
- e. the hospitals in the Massachusetts portion of the EPZ, and any of their current or former officials, administrators, or staff;
- f. other special facilities (not listed above) in the Massachusetts portion of the EPZ, and any of their current or former officials, administrators, or staff;
- g. agencies, departments, and branches of the
.O Commonwealth of Massachusetts, and any of their current or former of ficials, administrators, or employees;
- h. agencies, departments, or branches of the State of New Hampshire, and any of their current or former officials, administrators, or employees;
- i. individuals in the Massachusetts EPZ who are transit dependent persons or who may be in need of transportation assistance in the event of a radiological emergency at Seabrook ,
Station; !
l
- j. individuals in the Massachusetts EPZ who have l or may have sensory impairments, movement l impairments, or mental / emotional impairments, and organizations and individuals who assist such persons.
Acolicants' Resoonse Applicants object to this request as calling for documents not relevant to the subject matter of this proceeding and also for the reasons that it is overly broad and unduly burdensome. Without waiving these objections, Applicants will produce those documents requested in subparts a-g that pertain to issues in the admitted contentions.
(Applicants do not believe that subpart h requests documents that pertain to issues in the admitted contentions.)
Subparts i and j present a different problem and call for confidential information. Applicants object to producing documents which disclose identities of individuals who have confided the existence of their special needs to Applicants for purposes of special emergency planning for them. Their individual identities are not relevant to this proceeding and s
their privacy interests are real and substantial. Without
, '(
waiving this objection, Applicants will produce those documents requested with the names of special needs individuals redacted.
Recuest No. 17 Any and all documents constituting or reflecting communications between NHY (and/or NHY ORO) and (1) FEMA and (2) the NRC since January 1, 1987, pertaining to (a) the need for a utility-generated plan for the Massachusetts EPZ and how it should be designed and staffed; (b) the SPMC itself and its review by FEMA and the NRC; (c) the RAC review process, including comments, suggestions, recommendations, and concerns of the RAC and responses thereto; (d) requests for further information and responses thereto; (e) changes to the regulations of the NRC and FEMA; (f) and changes to the FEMA /NRC guidance documents, including NUREG-0654.
Aeolicants' Resconse Applicants object to this request on the grounds that it calls for documents not relevant to the subject matter of this proceeding and is overly broad and unduly burdensome.
Without waiving these objections, Applicants will produce those documents requested in subparts a-d that pertain to issues in the admitted contentions. (Applicants do not believe that subparts e-f request documents that pertain to issues in the admitted contentions.)
Reauest No. 18 Any and all communications, including attachments thereto, between NHY and any Federal agency, other than FEMA and the NRC, concerning the SPMC or radiological emergency planning for the Massachusetts portion of the Seabrook EPZ, including but not limited to communications with the White House and the Executive Branch, EPA, DOE, DOI, DOT, FAA, FDA, NOAA, the Defense Department and the U.S. Coast Guard.
Aeolicants' Resconse Applicants object to this request on the grounds that it r
]
l calls for documents not relevant to the subject matter of this proceeding, and is overly broad and unduly burdensome.
Without waiving these objections, Applicants will produce those documents requested which pertain to issues in the admitted Contentions.
Egauest No. 19 Any and all documents generated or received by ORO/NHY concerning the Long Island Lighting company and the Shoreham Nuclear Power Station, other than pleadings and decisions generated in the adjudicatory licensing proceedings before the NRC.
Acolicants' Resconse Applicants object to this request because it calls for documents not relevant to the subject matter of this proceeding, to wit, the admitted contentions.
Recuest No. 20 Any and all documents concerning a proposed Presidential Executive Order which would instruct FEMA to generate and develop emergency plans for nuclear power plants where states refuse to participate in planning.
Aeolicants' Resconse Applicants object to this request because it calls for documents not relevant to t'.4e subject matter of this proceeding, to wit, the admitted contentions.
Reauest No. 21 Any and all documents which ares (a) fully or partially completed NHY ORO Training Instructor Qualification Forms (Attachment 1 to Appendix X); (b) fully or partially completed NHY ORO Required Reading Memos (Attachment 2 to Appendix X); (c) fully or partially completed Training Class Exemption Request Forms (Attachment 3 to Appendix K); (d)
Instructor Guide Materials; (e) NHY ORO Training and Drill Program Attendance Sheets (Attachment 8 to Appendix K); (f) fully or partially completed NHY ORO Training Program e
Feedback Forms (Attachment 9 to Appendix K) ; (g) fully or partially completed Scenario Formats (Attachment 10 to Appendix K with all exhibits) and (h) fully or partially -
completed Emergency Drill / Exercise Improvement Item Tracking Forms (Attachment 11 to Appendix K). "
Aeolicants' Resconse l Applicants will produce thoue documents requested.
Beauest No. 22 Any and all documents reflecting or constituting an evaluation, assessment, or review of the training materials utilized by ORO.
Acolicants' Resconse I
Applicants will produce those documents requented.
Reauest No. 23 Any and all documents which analyze or evaluate in any way any of the training sessions, drills or exercises NHY has conducted for any part of NHY's ORO since December 1, 1987.
Aeolicants' Resoonse !
Applicants object to this request on the ground that it calls for documents not relevant to the subject matter of this proceeding. Without waiving this objection, Applicants will produce those documents requested that pertain to the admitted contentions.
l Reauest No. 24 1
Any and all documents which analyze, evaluate, or review in any way the adequacy of the SPMC or NHY ORO's state of preparedness in the event of a radiological emergency at Seabrook Station, other than the FEMA draft and final reports on the June 1988 Exercise.
Aeolicants' Resoonse i
Applicants object to this request on the grounde that it 4
calls for documents not relevant to the subject matter of
this proceeding, and is overly broad cnd unduly burdensome.
Without waiving these objections, Applicants will produce those documents requested which pertain to issues in the admitted contentions.
Reauest No. 25 The report prepared by the New Hampshire Yankee Emergency Planning Advisory Panel.
Aonlicants' Resoonse Applicants will produce the document requested.
Recuest No. 26 Any and all documents generated or received by NHY since April 1, 1987, which set forth, describe, or assess resources (including personnel) available to the Commonwealth and/or the six Massachusetts EPZ towns in the event of a Seabrook radiological emergency.
Acolicants' Baam nam Applicants will produce those documents requested.
Recuest No. 27 Any and all documents, generated or received by NHY (and/or NHY ORO) since April 1, 1987 that reflect in any fashion the efforts and steps taken, or to be taken, by NHY ORO to identify the resources (including personnel) available to the Commonwealth and/or the six Massachusetts EPZ towns in the event of a Seabrook radiological emergency.
Aeolicants' Resoonse Applicants will produce those documents requested.
Reauest Nqt_11 Any and all documents which NHY ORO has accumulated, assembled or gathered pursuant to NUREG 0654, FEMA-REP-1, Rev. 1, Supp. 1, under Planning Standards and Evaluation Criteria A(2)(b) which states: "The offsite plan shall contain where applicable (by reference to specific acts, codes or statutes) the legal basis for such authorities including thoss that reserve functions to State and local governments."
Aeolicants' Resconse Applicants object to this request on the ground that it appears to call directly for httorney work product and-attorney-client privileged communications. The SPMC itself contains the legal basis to which the administrative guidance refers, and a request for documents beyond that appears to be a brazen request by Mass AG to search Applicants' and their counsel's legal files.
Applicants further object to identifying any such privileged documents as the grounds of the assertion of privilege are plain without any further description.
Applicants would refer Mass AG, however, to the sources compiled in Applicants' motion for summary disposition of JI Contentions 44A and 44B.
Recuest No. 29 Implementing procedures 2.5 of the SPMC list a number of "references," including the "Seabrook Station Evacuation Time Study, August 12, 1986, KLD Associates, Inc." If the evacuation time study referenced is any different from that contained in Volume 6 of the NHRERP, please produce a copy with all changes, amendments, additions, and deletions thereto.
Aeolicants' Response The document dated August 12, 1986 is the same as Volume 6 of NHRERP and thus no copy will be produced.
Reauest No. 30 Any and all documents, including all correspondence from KLD Associates, that evaluate or discuss the adequacy, reliability, or sensitivity of KLD's ETE study when used to determine the ETEs for the Massachusetts EPZ under circumstances that would or might pertain were the SPMC to be implemented.
e Aeolicants' Resoonse Applicants object to this request on the grounds that it calls for documents not relevant to the subject matter of this proceeding, and is overly broad and unduly burdensome.
Without waiving these objections, Applicants will produce those documents requested which pertain to issues in the admitted contentions.
Recuest No. 31 Produco computer readable listings of all input files and data necessary to reproduce: (a) the IDYNEV runs which generated the ETEs set forth on Attachment 4 to Implementing Procedure 2.5 of the SPMC; and (b) any other runs conducted to test the sensitivity of, refine, supplement, update, correct, or revise the ETEs set forth on Attachment 4 to Implementing Procedure 2.5 of the SPMC.
Acolicants' Resoonse Applicants object to this request on the grounds that it calls for documents not relevant to the r.ubject matter of this proceeding, and is overly broad and unduly burdensome.
Without waiving these objections, Applicants will produce those documents requested which pertain to issues in the admitted contentions.
Recuest No. 32 Produce paper copies of the IDYNEV outputs produced in the runs specified in the previous request.
Acolicants' Resoonse Applicants object to this request on the grounds that it calls for documents not relevant to the subject matter of this proceeding, and is overly broad and unduly burdensome.
Without waiving these objections, Applicants will produce 9
those docurints caquested which pertain to issues in the admitted conceptions.
Reauest No. 31 Any and all < 1por'as, analyses, surveys, and studies done since the SF40 wat firat published which concern issues raised in the :ortA**. ions admitted in the SPMC litigation.
u mljcants' Response This request js redundant; Applicants will produce those documents requested under Request No. 1.
E12Vpst No. 3_i Please identify and provide copies of all surveys, studies, or compilatnons performed or relied upon to identify, calculate, or determine any of the SPMc's population figures, including but not limited to, the populations of towns, schools, day care centers, special facilities, hospitals, transit dependent persons, and figures for the beach area population (Salisbury Beach and Plum Island).
Aeolicants' Response Applicants object to this request insofar as it calls upon Applicants to "identify" documents in response to a request to produce documents. Applicants object to this as beyond the proper scope of a document request. If Mass AG intended to style this as an interrogatory, Applicants would have answered, as the rules permit, by producing the very documents of which Mass AG seeks to know the identity.
Applicants further object to this request as calling for documents not relevant to the subject metter of this proceeding, is overly broad, particularly in temporal scope, and is unduly burdensose. Applicants will produce those documents requested that pertain to issues in the admitted
o e
contentions.
As to the specific request to "provide copies,"
Applicants will forthwith arrange to have copied at Mass AG's expense all documents responsive to this request to which objection has not been made.
Reauest No. 35 i
All current versions of the pre-emergency information j which NHY is currently distributing or it6tends in the future '
to distribute within the Massachusetts EPZ.
Aeolicants' Resoonse Applicants will produce those documents requested.
Recuest No. 36 A copy of the Institute of Nuclear Power Operation (INPO) Good Practice EP-804, Emergency Preparedness Training. ,
Acolicants' Resconse Applicants will produca those documents requested.
Motion for Protective Order Applicants move that the Board enter a protective order i that the discovery to which ebjection has been made herein [
not be had. <
By their attorneys,
/
thdmas G. Dignan, Jr.
George H. Lavald Kathryn A. Selleck Jeffrey P. Trout Jay Bradford Smith ;
Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 i
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'88 my -8 P4 :50 CERTIFICATE OF SERVICE
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I, Kathryn A. Selleck, one of the attorneys f.o.tr.the,l- ,
Applicants herein, hereby certify that on November 3, 1988, I made service of the within document by depositing copies thereof with Federal Express, prepaid, for delivery to (or, where indicated, by depositing in the Unit 9d States mail, first class postage paid, addressed to):
Administrative Judge Ivan W. Smith Robert Carrigg, Chairman Chairman, Atomic Safety and Board of Selectmen 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 Hatnon & 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 Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814
- Adjudicatory File Sherwin 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 Commission East West Towers Building One White Flint North, 15th F1.
4350 East West Highway 11555 Rockville Pike l Bethtsda, M0 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 l
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, NE 04333 Paul McEachern, Esquire Carol S. Sneider, Esquire Matthew T. Brock, Esquire Assistant Attorney General 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-Wtshington, 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 e 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 General Counsel Murphy and Graham -
Federal Emergency Management 33 Low Street Agency Newburyport, MA 01950 500 C Street, S.W.
Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street '
Hampton, NH 03841 Concord, NH 03301 i
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i
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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.
Bothull, Washington 98021-9796 Ashod N. Amirian, Esquire 376 Main Strent Haverhill, MA 01830 Robert R. Pierce, Esquire John H. Frye, III, Alternate Atomic Safety and Licensing chairman Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commissior. 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 X/th{yn/A. Selleck
(*= Ordinary U.S. First Class Mail) 3-