ML20206C414
| ML20206C414 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/14/1988 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#488-7496 OL-1, NUDOCS 8811160266 | |
| Download: ML20206C414 (21) | |
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Novembe8(if/fI988 UNITED STATES OF AMERICA *S8 NOV 15 P4 :04 before the rn;;,
NUCLEAR REGULATORY COMMISSION g# ,
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In the Matter of )
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PUBLIC SERVICE COMPANY ) Docket Nos. 50-443-OL-1 OF NEW HAMPSHIRE, at A1 ) , 50-444-OL-1
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(Seabrook Station, Units 1 ) (Onsite Emergency and 2) ) Planning and Safety
) Issues)
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APPLICANTS' RESPONSE TO MOTIONS TO REOPEN THE RECORD TO CONSIDER FINANCIAL QUALIFICATION ISSUES PRIOR TO PERMITTING IhW POWER OPERATION STATEMENT OF THE CASE On September 22, 1988, the Commission issued an Order 1 in connection with its consideration of a pending certified petition for waiver of certain aspects of its financial qualification rules. Therein the Commission stated that:
"the unique and unusual circumstances of (the SeabrogA) case, requires that before low power may be authorized, applicants provide reasonable assurance that adequate funds will be available ro that safe decommissioning will be reasonably assured in the event low power operation 1
Public Service q,qpoany of New Hamechire (Seabrook Station, Units 1 and 2), CLI-88-07, 28 NRC (Sept. 22, 1988), hereinafter cited to the Slip 0 pinion.
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4 has occurred and a full power license is not granted for Seabrook Unit 1.n2 <
In light of the foregoing, the Commission directed the Applicants to "provide the basis on which a finding of the necessary reasonable assurance . . . might be made."3 Applicants were requested to provide, within thirty days:
"adequate documentation of their plan and appropriate commitments under that plan to provide reasonable assurance that adequate funding for decommissioning will be available in the event - full power license is not granted for seabrook Unit 1."4 The Commission went on to state:
I "The procedural posture of L.nis case refl'ets that the record is closed for the consideration of new issues and litigation on this issue may only be pursued if a motion to reopen is granted and at least one late-filed contention is admitted. . . . (W)ithin ten (10) days after service of applicants' filing the parties muut file, wit ~n the Commission, any motions and late filed contentions based on applicants' plan to fund the decommissioning of the plant in the event that L fgli power license is not granted.3 on october 20, 1988, the Applicants filad, under oath, the 2CLI-88-07 at 2.
3 14 4CLI-88-07 at 3.
! 5 1d. (Enphasis added).
1 l
e documentation which had been requested by the Commission.6 In response to this filing, a total of five motions to reopen were filed, all under date of November 2, 1988. (These motions will hereinafter be referred to collectively as "The Motionn"). Two motions were filed by the Attorney General of the Commonwealth of Massachusetts (Mass. AG);7 the others by New England Coalition on Nuclear Pollution (NECNP),8 Town of 6
Letter NYN 88142 Brown to USNRC (Oct. 20, 1988) attaching THE PIAN IN RESPONSE TO NRC ORDER CLI-88-07 Prepared by New Hamoshire Yankee (October, 1988).
(Hereinafter sometimes referred to as "The Plan").
7 Motion of Massachusetts Attorney General James M.
Shannon Under 10 C.F.R. 2.734 to Reocen the Record to Consider Evidence Concernina the Joint Aeolicants' Decommissionino Plan for the Seabrook Nuclear Power Station an1_to Admit the Attached Late Filed Contentions Concerning Said Decommisgionina Plan (Nov. 2, 1988) (hereinafter referred to and cited as "Mass. AG #1 Motion"); Motion of Massachusetts Attorney General James M. Shannon,to Reopen the Record to Consider Evidence Concernina the Joint Aeolicants' Financial Oualifications to Ooerate the Seabrook Nuclear Power Station and to Admit the Attached Late-riled Contentigns Concernina Said_ Financial Oualifications (Nov. 2, 1988) (hereinafter referred to and cited as "Mass. AG #2 Motion"). Mass. AG f 2 Motion does not seek admission of contentions "based on applicar.ts' plan," CLI-88-07 at 3, and, therefore, was not authorized by the Commission's Order.
Nevertheless, we address it herein and feel it should be denied for the same reasons as set forth with respect to all of The Motions.
8 New Encland Coalition on Nuclear Pollution's Coritentions on Aeolicants ' Dgcommissionino Plan. Motion for Stav of Low cover Oceration. and Motion to Reocen the Record (hereinafter referred to an "NECNI Motion").
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Hampton (TOH),9 and Seacoast Anti-Pollution League (SAPL) .10 As contemplated by the Commission's Order,11 Applicants herein respond in opposition to The Motions insofar as they are motions to reopen.12 ARGUMEh"r I. THE MOTIONS TO REOPEN DO NOT COMPLY WITH THE PROVISIONS OF 10 CFR I 2.734 Introduction The criteria for granting a motion to reopen a closed evidentiary record are set forth in 10 CFR 5 2.734. The required showing is that the motion be timely, address a 9
Town of Hamoton Motion to Admit Late-Filed _ Contention and Reocen the Record on Aeolicants' Financial Ot:alification to Decommission Seabrook Statien (Nov. 2, 1988) (hereinafter referred to as "TOH Motion").
10 Seacoast Anti-Pollution Leacus's ContDilqns_ on ADolicants' Plan in Respgn_se to NRC Order CLI-88-07 (Nov. 2, a
1988) (hereinafter referred to as "SAPL Motion").
11"All oppositions to any such motion must ba filed within ten (10) deys of service of the motion." CLI-88-07 at 3.
12 Applicants note that the NECNP Motion contains a motion for a stay. The short, plain and dispositive response to this motion is that it does not even begin to comply with the provlaions of 10 CFR I 2.788 and should, therefore, be denied summarily. Kansas Gas and Electric C2A (Wolf Creek Generating Station, Unit No. 1), ALAB-412, 5 NRC 1415, 1417 (1977). AC.RQId, Public Service Comoany__of New Hamoshing (Seabrook Station, Units 1 and 2), CLI-77-27, 6 NRC 715 (1977).
sianificant safety issue, and "demonstrate that a materially different result would be or would have been likely had the newly proffered evidence been considered initially."13 The burden of satisfying each of the criteria is upon the moving party, and it is, indeed, a heavy one.14 The regulation further requires that the motion be accompanied by affidavits which set forth the factual or technical basis for the claim that the criteria discussed
! above have been satisfied.15 With respect to these affidavits, the regulation provides that:
"Affidavits must be given by competent individuals with knowledge of the facts alleged, or by experts in the disciplines appropriate to the issues raised.
Evidence contained in the affidavits must meet the admissibility standards set forth in 5 2.743(c). Each of the t
criteria must be separately addressed, with a specific explanation of why it is met.n16 Finally, where, as here, the reopening is for the purpose of raising a late filed contention, the motion "must 13 10 CFR I 2.734(a).
14 3.g., Louisiana Power and Licht Co. (Waterford ateam Electric Station, Unit 3), A LA B-7 8 6, 20 NRC 1087, 1090 (1984); Pacific Gas and Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 and 2), A LAB-7 56, 18 NRC 1340, 1344 (1983); Louisiana Power and Licht Co. (Waterford Steam Electric Station, Unit 3), ALAB-753, 18 NRC 1321, 1324 (1983).
15 10 CFR $ 2.734(b).
16 10 CFR 5 2.743(b).
I
b also satisfy the requirements for nontimely contentions in 5
- 2. 714 (a) (1) (i) through (v) . "17 Thus, in order to have its motion allowed, each movant must prevail as to each of five matters (1) timeliness, (2) safety significance of the issue sought to be raised, (3) difference in result, (4) propriety of the affidavits, and (5) the balancing test with respect to the "five factors" under 10 CFR 5 2.714 (a) (1) . We address each of these matters below.
A. Timeliness.
Given the fact that the Commission authorized The Motions, they are clearly, insofar as they challenge The Plan, timely.
B. There has Been no Adequate Showing as to the Safety Significance of the Issues Sought to be Litigated.
The regulation requires that the novant demonstrate that the motion "addresses a significane safety or environmental t issue."18 Not every safety issue is "significant" for
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purposes of resolving a motion to reopen. It has been I squarely held, for example, that in cases where reopening is sought on the ground of quality assurance deficiencies, the 17 10 CFR 5 2.734(d).
18 10 CFR $ 2.734 (a) (2) .
O mere showing that a quality assurance program had deficiencies in execution is not enought rather it must be shown that there are, in fact, errors which endanger plant operation or that there has been a wholesale breakdown of quality assurance such as to raise a legitimate doubt as to i the plant's capability of being operated safely.19 In short the safety problem must be real and of a nature that it presents a real and present danger to the public. !
In The Motions four arguments are made for the proposition that what is involved is a significant safety issue. The two Mass AG Motions acke reference to statements by this Commission made in the issuancc accompanying the recent decommissioning rule.20 These all are statements to the effect that a failure to plan for decommissioning could [
result in significant safety impacts and hazards in the future at sites which are not decommissioned. These statements do not constitute allegations of any clear and present danger to the public. Second, it is argued that high level waste (HLW) is, in and of itself, dangerous and therefore unless there is a good decommissioning plan in 19 Pacific Gas and Electric Comnany (Diablo Canyon l
' Nuclear Power Plant, Unita 1 and 2), ALAB-775, 19 NRC 1361, '
1366 (1984); Pacific Gas and Electric Comeany (Diablo Canyon i Nuclvtr Power Plant, Units 1 and 2), ALAB-756, 18 NRC 1340, [
1344 (1983) 20 Magat_AG #1 Motion at 4; Mass. AG #2 Motion at 6-7.
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place, there would be future dangers.21 This too is not an allegation of a clear and present danger. Third, it is argued that there may be long term storage of the contaminated fuel and reactor parts at the site.22 Even if this were true, and it is not, the storage on site for a long time of the radioactive products of low power testing present no threat to the health and safety of the public. Fourth, it is argued that the existence on the site of the radioactive materials resulting from testing would be a hazard to those with unrestricted access to the site.23 The complete answer is that as long as there are hazardous materials on the site, there will be no unrestricted access. In s.Nort, even assuming the contentions had merit, and in fact that the Applicants were short of funds to decommission the facility after low power testing, there will not be any present threat
) to the health and safety of the public. The radioactive material vill remain on site and under the regulation of this agency.
Prescinding from all of the foregoing, it will be recalled that 10 CFR $ 2.734(b) requires an affidavit which sets forth "the factual and/or technical basis for the 21 Mass AG #2 Motion at 7.
22 ,NECNP Motion at lot IQH Motion at 4.
23SAPL Motion at 2.
i movants claim that the criteria of paragraph (a) (including the paragraph (a)(2) criterion of significant safety issue) are met. One will peruse such affidavits as were filed with The Motions in vain for any statements in support of the I concept that there is a significant safety issue. The '
affidavits are confined to quarreling with the statements, conclusions, and assumptions in The Plan.
i c'. There has been no Adequate Showing as to the Difference in Result !
criterion When the Commission codified the rule with respect to :
reopening closed evidentiary records, 10 CFR I 2.734, it paid I particular attention to the "materially different result" '
criterion codified in subparagraph (3) of subsection (a) of the rule. The Commission noted that theretofore there had been articulated in the case law two differently worded l I
l standardas the so-called "might have been reached" standard 6
and the "would have been reached" standard.24 The Commission went on to say i "The actual inquiry to be performed falls between the two standards. The 'vould' standard may be read to imply that an ultimate conclusion must be reached j before all evidence is considered. The :
'might' standard implies that reopening !
could be ordered even where a board is !
j uncertain whether or not the new evidence i I !
24
' Criteria for Reopening Records in Formal Licensing I Proceedings, 51 Fed. Reg. 19535, 19536-37 (May 30, 1986). I t
r i
O is important. The inquiry should be, and has been, the likelihood that a different result will be reached if the information is considered. 133 3.g., Union Electric Comnany (Callaway Plant, Unit 1) , ALAB-750, 18 NRC 1205, 1209 (1983).
Accordingly, the Commission is modifying the standard of I 2.734(a)(3) to require that a materially different result would be or would have been likely had the newlyproff!3 initially."
red evidence been considered In each of The Motions, this criterion is handled by argument in the motion itself to the effect that, assuming the novant is right, the low power decision earlier rendered would have come out differently. Wa are unadvised of any
- reason why an outcome adverse to the Applicants is likely.
1 Moreover, once again, the criterion simply is not addressed in the affidavits filed.
- D. The Affidavits, to the Extent They 4
Exist at All, do not satisfy the Requirements of the Regulation.
As noted earlier, the regulation governing motions to reopen require that the motion be accompanied by .n affidavit l which gives the factual or technical basis for the claim that the criteria of 10 CFR 52.734(a) have been satisfied.
Moreover, it is required that the affidavit be by competent individuals with knowledge of the facts alleged or by experts in the disciplines appropriate to the issues raised. The 251d. at 19537.
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NECNP Motion is accompanied by no affidavit, and, therefora should be summarily denied for that reason. The TOH Motion is accompanied by an affidavit of its lawyer. He does not (
purport.to give a basis for TOH's belief that the criteria of 10 CFR I 2.734(a) are satisfied,t rather, he purports, in a wholly conclusory way, to set out "the factual and/or [
technical bases for TCH's lace flied concencion.n26 Thus, on its face, it does not comply with the regulation. SAPL has filed an affidavit. However, there is no statement of qualifications of the affiant accompanying it which could tell the reader if the affiant is competent to give the testimony she purports to give, rurthermore, as indicated h above, the affidavit appears to address the contention, not i the criteria of the regulation. Finally, Mass AG does have I sffidavits attached to both of his motions, and the p
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i qualifications of the affiants are set forth. However,
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{ again, the bases addressed in the affidavits are the bases for the contentions made, not the bases for the belief of the h Mass. AG that the criteria of 10 CFR 5 2.734(a) are f l
satisfied.
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26 Brock Affidavit 1 3. (Emphasis added).
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a b
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E. Satisfaction of the "Five Factors" Test
- 1. Discussion of the Factors
- l. Good Cause, if any, for Failure to Flie on Time Concededly, the motions were filed in accordance with the Commission's schedule. They are timely as noted earlier.
- 11. Availabliity of other Means to Frotect recitioners' Interest.
The Applicants would concede that this (and the fourth factor) favor the movants, as is usually the case. However,
"[t]his factor, like the closely related fourth factor (the extent to which other parties will represent petitioners' interest) is accorded less weight, under established Commission precedent, than factors one, three, and five."27 27 Commonwealth Edison comnany (Braidwood Nuclear Power Station, Units 1 and 2), CLI-86-8, 23 NRC 241, 245 (1986),
citina with amoroval, South Carolina Electric and Gas Co.
(Virgil C. Summer Nuclear Station, Unit 1), ALAB-642, 13 NRC 381, 895 (1981).
a I
i 111. The Escent to Which the Petitioner *s Participation t
May Reasonably se Espected [
to Assist in Destioping a Sound Record.
Comm.ission "case law establishes both the importance of ;
this third factor in the evaluation of late-filed contentions ,
and the necessity of the moving party to demonstrate that it has special expertise on the subjects which it seeks to a raise. (citation) The Appeal Po; ts has said: 'When a 1 i petitioner addresses this criterion it should set out with as f
much particularity as possible the precise issues it plans to i cover, identify its prospective witnesses, and summarize
(
their proposed testimony'."28 {'
The Motions name no witnesses definitively.29 The ,
j Motions do allude in a general fashion to possible subjects t of testimony. This is hardly a compliance with.the concept f
j of summarising the to:itimony. !
I t 28er- ,nwsmith Edison ca===nv (Braidwood Nuclear Power I Station, Units 1 and 2), CLI-84-8, 23 NRC 241, 246 (1986), !
citira with annroval, Missisminni Power and Lich3_Eg4 (Grand Gulf Nuclear Station, Units 1 and 2), ALAB-704, 16 NRC 1725, j 1730 (1982).
29 In Mass. AG Motion #1, it is stated that there will be testimony from att MHB witness, and it will encompass subjects such as those in the attached Strouss Affidavit.
Motion 81 at 7 & n.1, We are not told what the subjects Mass. AG will, in fact, be or if Mr. Strauss is the witness. SAPL says that apossibly" a certain named individual will testify.
q Nothing is said about his qualifications. SAPL Motion at 5.
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iv. The Extent to Which the i Petitioner *s Interest Will Be Represented by Existing Parties.
As indicated above, this factor always favors the ;
petitioner but is entitled to less weight than bambers 1, 3, and 5.
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- v. The En: Which the Petitions, s Participation Will Broeden the Issues or Delay the Proceeding.
The injection of a new issue will obviously delay any
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proceeding. In this case, it also will delay the issuance of
.y low power testing authority. Obviously it will also broaden the proceeding, as certain of the Intervenors, themselves, concede.30 f
- 2. Dalance of Factors The only one of the weightier factors which weighs in ravor of the Movants is the timeliness factor. The showing P
with respuct to the most important of the five factors, contribution to the rccord, is wcefully inadequate. The delay factor weighs heavily againct the movt~nts. The balance i
of factors weighs against the movants.
1 P i 4
r 4- 30 E.g., NECNP Motion at 12.
.- ._. , . . . . . -_-_-. - . _ - . _ _ -. - - ___ . - = - -
O.
II. ALL OF THE MOTIOFS APPEAR TO PROCEED FROM AN ERRUNEOUS INTERPRETATION OF THE COMMISSION'S ORDER.
Prescinding from the failure of the movants to make their' case in conformity with the requirements of 10 CFR 52.734 as shown above, it is also apparent that the motions, in the main, proceed from an erroneous interpretation of the Commission's Order in CLI-88-07. Virtually all the proposed contentions seek to take issue with The Plan as though it was a final decommissioning plan to be measured against the particulars of the recently issued decommissioning rule. No such assignment was given to the Applicanto in CLI-88-07.
What the Commission directed was the filing of a funding plan, not a final decommissioning plan.31 Because there are no regulatory criteria for the amount of funding to be planned for after nothing but low power testing has been accomplished, it was necessary for the Applicants to develop, through the use of conservative assumptions, a dollar amount to be targeted as the required funding to be supplied to decommission Seabrook in thu hypothetical event that no commercial operating license was ever forthcoming after low power testing was conducted. Financially conservative assumptions (such as the possible use of foreign reprocessing) were utilized throughout and no ane really 31 Comoare 10 CFR 5 50.75(b) with 10 CFR 5 50.75(f) .
)
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P quarrels with the number developed based on the' assumptions used.
Despite the foregoing, the movants dwell on The Plan's details with claims to the effect that this or that underlying assumption is erroneous; complaints as to the lack of a specified High Level Waste Storage facility in The Plan;32 complaints that no calculations have been done in conformity with 10 CFR 5 50.75(c);33 arguments that insufficient time has been allowed for regulatory approvals;34 and concerns about ALARA.35 This is not what the commission intended when it issued CLI-88-07. This is evidenced by the limitation of thirty days in the order. '
Such a period could not possibly provide sufficient time to develop finalized contracts for matters such as low level waste storage.36 It is time to develop a plan of sufficient 32 The minor volume of high level waste remaining after reprocessing the fuel is hardly of a magnitude as te sause any great concern insofar as disposal is concerned in any event.
33 The formulas appearing in that section assume 40 years of operations and its associated much greater scope and amount of contamination.
34 Arguments made without reference to the fact that in many cases slippage of the approval time will have no effect on overall schedule completion.
3! T minimis problem for low power testing.
36' be noted that the Statement of Considerations which acwompanied the new decc=missioning rule reflect that adequate low level waste facilities currently exist. 53 Fed.
Reg. 24018, 24040 (June 27, 1988).
detail to generate a reasonable estimate and funding plan upon which a finding of reasonable assurance can be based; in short, to do what the commission ordered done: provide a basis for finding that in the hvoethetical case of issuance of a low power license never followed by a commercial operating license, there exists retscnablo assurance that there would be funds to underwrite such additional termination costs as would have been caused by the low nower ooeration so as to permit the sit' to be released for unrestricted use. The $21.1 million figure derived from the analysis set forth in The Plan is a reasonable figure for the postulated task at hand, and the means of generating, and, if required, segregating, those funds are realizable. No more was required under the commission's order.
O h.
1 CONCLUSION The motions to reopen fail under two of the thrsa 10 CFR 5 2.734(a) criteria; they do not meet the requirements of 10 CFR 5 2.734(b); they also fail the requirements of 10 CFR S 2.734(d) which incorporates the "five factors' test; and they proceed from an erroneous reading of the Commission's order.
The Motions should be denied.
Respectfully submitted,
))
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Thdma's fDTgaan, Jr.
C George'M. Lewald Kathryn A. Selleck Jeffrey P. Trout Jay Bradford Smith i Ropes & Gray 225 Franklin Street i Boston, MA 02110 .
(617) 423-6100 Counsel for Applicants s
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CERTIFICATE OF SERVICE '
I, Thomas G. Dignan, Jr., one of the attorneys f0 W Applicants herein, hereby certify that on November 14, 984,,15 P 4 .04 I made service of the within document by depositing copies thereof with Federal Express, prepaid, for delivery tor (or: t
'g where indicated, by depositing in the United States ma'11D'f;. ag. .
first class, postage paid, addressed to):
Alan S. Rosenthal, Chairman Howard A. Wilber Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Appeal Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory ccamission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethosda, MD 20814 Thomas S. Moore Mr. Richard R. Donovan Atomic Safety and Licensing Federal Emergency Management Appeal Panel Agency U.S. Nuclear Regulatory Federal Regional Center Commission 130 228th Street, S.W.
East West Towers Building Bothell, WA 98021-9796 4350 East West Highway Bethesda, MD 20814 Administrative Judge Sheldon J. Robert Carrigg, Chairman Wolfe, Esquire, Chairman Board of Selectmen Atomic Safety and Licensing Town Office Board Panel Atlantic Avenue U.S. Nuclear Regulatory North Hampton, NH 03862 Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Emmeth A. Diane Curran, Esquire Luebke Andrea C. Ferster, Esquire 4515 Willard Avenue Harmon & Weiss Chevy Chase, MD 20815 Suite 430 2001 S Street, N.W.
Washington, DC 20009 Dr. Jerry Harbour Stephen E. Merrill, ELquire Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee, Esquire U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Hignway concord, NH 03301-6397 Bethesda, MD 20814
.v; ~
Adjudicatory File Atomic Safety and Licensing Sherwin E. Turk, Esquire Board Panel Docket (2 copies) Office of General Counsel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission e East West Towers Building One White Flint North, 15th Fl.
4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852 y
- Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Panol Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 .
Manchester, NH 03105 Philip Ahrens, Esquire Mr. J. P. Nadeau AP.Miatant Attorney General Selectman's Office
- Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S. Sneider, Esquire Matthew T. Brock, Esquire Assistant Attorney General 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 s Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 ' Box 1154 City Hall Route 107 _26 Daniel Street Kensington, NH 03827 Portsmouth. NH 0381
- Senator Gordon J. Humphrey R. Scott His.1-Whilton, Esquire U.S. Senate Lagoulis, Clark, Hill-Washington, DC 20510 Whilton & McGuire (Attn: Tom Durack) 79 State Straat Newburyport, NJ s1950
- Senator Gordon J. Humphrey One Eagle Square, Suite 507 Concord, NH 03301 !
(Attn Herb Boynton) '
Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 1
10 Front Street Amesbury, M?. 01913 Exeter, NH 03833 ;
i
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 Harpe and McNicholas 47 Winnacunnet Road 35 Pleasant Streat Hampton, NH 03841 Concord, NH 03301 Judith H. Mirner, Esquire 79 State Street, 2nd Floor Newburyport, MA 01950 Lando W. Zech, Jr., Chairman Tnomas M. Roberts, Commissioner U.S. Nuclear Regulatory U.S. Nu;1 ear Regulatory Commission Commission One White Flint North One White Flint North 11555 Rockville Pike 11655 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 Kenneth M. Carr, James R. Curtiss, Commissioner Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Ono White Flint North One White Flint North 11555 Rockville Pike 11555 Rockville Pika Rockville, MD 20852 Rockville, MD 20852 Kenneth C. Rogers, William C. Parler, Esquiro Commissioner General Counsel U.S. Nuclear Regulatory Office of the General Counsel Commission One White Flint North One White Flint North 11555 Rockville Pike 11555 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 Marjorie Nordlinger, Esquire Deputy General Counsel Office of the General Counsel One White Flint North 11555 Rockville Pike Rockville, MD 20852 W3 M Thomas Tl. Dig @ ., Jr.
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