ML20207A286
| ML20207A286 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/17/1987 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#287-3211 OL-1, NUDOCS 8704270057 | |
| Download: ML20207A286 (21) | |
Text
P 32 //
e 00CHETED USHRC Dated:
April 17, 1987 367 MH 23 P4 :32 UNITED STATES OF AMERICA GFF"Z ',. :T.4,i NUCLEAR REGULATORY COMMISSION 00Cf! ([
- U before the ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL-1 NEW HAMPSHIRE, et al.
)
50-444-OL-1
)
(On-site Emergency (Seabrook Station, Units 1 and 2) )
Planning Issues)
)
)
APPLICANTS' RESPONSE TO APPLICATIONS FOR STAY OF LICENSING BOARD BOARD ORDER AUTHORIZING GRANT OF AUTHORITY TO ENGAGE IN OPERATION UP TO FIVE PERCENT OF RATED POWER Thomas G. Dignan, Jr.
George H. Lewald Kathryn A.
Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 Counsel for Applicants G704270057 870437
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Page TABLE OF AUTHORITIES ii I.
STATEMENT OF PRIOR PROCEEDINGS AND FACTS 1
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II.
ARGUMENT 4
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Inttaduction......................................
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1.
The Lik 211 hood o f Succe s s.....................
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Irreparable Harm..............................
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3.
Injury to other Parties 12 j
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Public Interest 12 1
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III.
CONCLUSION......................................
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TABLE OF AUTHORITIES Cases Page(s)
Cuomo v. NRC, 772 F.2d 972 (D.C. Cir. 1985) 10 Wisconsin Cas Co. v. FERC, 758 F.2d 669 (D.C. Cir. 1985) 10 Administrative Decisions Alabama Power _Co.
(Joseph M.
Earley Nuclear Plant, Units 1 and 2), CLI-81-27, 14 NRC 795 (1981) 4, 5 Cleveland Electric Illuminating Co. (Perry Nuclear Plant, Units 1 and 2), ALAB-820, 22 NRC 743 (1985) 10 Consolidated Edison Co. of New York, Inc.
(Indian Point Station, Unit 2), ALAB-414, 5 NRC 1425 (1977) 11, 12 Florida Power & Light Co. (St. Lucie Nuclear Power Plant, Unit 2), ALAB-415, 5 NRC 1435 (1977) 9 Kansas Gas & Electric Co. (Wolf Creek Generating Station, Unit 1), ALAB-424, 6 NRC 122 (1977) 10 Long Island Lighting Co. (Shoreham Nuclear Power Station), CLI-85-12, 21 NRC 1587 (1985) 5, 12 Long Island Lighting Co. (Shoreham Nuclear Power Station), CLI-85-1, 21 NRC 275 (1985) 6 Long Island Lighting Co. (Shoreham Nuclear Power Station), CLI-84-9, 19 NRC 1323 (1984) 5, 6, 12 Long Island Lighting Co. (Shoreham Nuclear Power Station), CLI-83-17, 17 NRC 1032 (1983) 6 I I
Louisiana Power and Light Co. (Waterford Steam Electric Station, Unit 3),
ALAB-732, 17 NRC 1076 (1983) 8 i
Metropolitan Edison Co. (Three Mile
!~
Island Nuclear Station, Unit 1), CLI-84-17, 20 NRC 801 (1984) 9 Philadelphia Electric Co. (Limerick Generating Station, Units 1 and 2), ALAB-789, 20 NRC 1443 (1984) 10 Philadelphia Electric Co. (Peach Bottom Atomic Power Station, Units 2 and 3),
ALAB-221, 8 AEC 95 (1974) 5 I
Philadelphia Electric Co. (Peach Bottom Atomic Power Station, Units 2 and 3),
ALAB-158, 6 AEC 999 (1973) 5 Public Service Company of Indiana (Marble l
Hill Nuclear Generating Station, Units 1 and 2), ALAB-437, 6 NRC 630 (1977) 9 Public Service Company of New Hampshire j
(Seabrook Station, Units 1 and 2),
l CLI-87-2, 25 NRC (April 9, 1987) 6 CLI-77-27, 6 NRC 715 (1977) 9 LBP-87-10, 25 NRC (March 25, 1987) 1, 8 ASLB Mem. and Ord., unpublished, (March 25, 1987) 8 1
ASLB Mem. and Ord., unpublished, j
(Sept. 15, 1986) 8 ASLB Mem. and Ord., unpublished, (July 25, 1986) 8 ASLB Mem. and Ord., unpublished, (May 11, 1983) 6 LBP-82-76, 16 NRC 1029 (1982) 6 1.
Toledo Edison Co. (Davis-Besse Nuclear Power Station, Units 1, 2 and 3), ALAB-385, j
5 NRC 621 (1977) 5 Westinghouse Electric Corp. (Export to the Philippines), CLI-80-14, 11 NRC 631 (1980) 9
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4 Wisconsin Electric Power Co. (Point Beach Nuclear Power Plant, Unit 2),
ALAB-58, 4 AEC 951 (1972) 5 Regulations 10 CFR $ 2.734(a)(2) 8 10 CFR $ 2.758 12 10 CFR $ 2.788(e) 2, 4
10 CFR $ 50.33(g) 2, 6
10 CFR $ 50.47(d) 2, 6
i Staff Guidance Materials NUREG-0737, Rev. No. 1 9
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1 1
1
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Dated:
April 17, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING APPEAL BCARD
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL-1 NEW HAMPSHIRE, et al.
)
50-444-OL-1
)
(On-site Emergency (Seabrook Station, Units 1 and 2) )
Planning Issues)
)
)
APPLICANTS' RESPONSE TO APPLICATIONS FOR STAY OF LICENSING BOARD BOARD ORDER AUTHORIZING GRANT OF AUTHORITY TO ENGAGE IN OPERATION UP TO FIVE PERCENT OF RATED POWER STATEMENT OF PRIOR PROCEEDINGS AND FACTS on March 25, 1987, the Licensing Board herein issued a Partial Initial Decision and Order which authorized the Director of Nuclear Reactor Regulation to issue a license permitting operation of Seabrook Station, Unit 1, up to and at 5% of rated power.
Public Service Company of New Hampshire (Seabrook Station, Units 1 and 2), LBP-87-lO, 25 NRC (March 25, 1987).
Notices of Appeal and Applications for Stay of the Licensing Board's Order have been filed with this Appeal Board by the Attorney General of the Commonwealth of Massachusetts (Mass. AG), New England i
1 Coalition on Nuclear Pollution (NECNP), Seacoast Anti-Pollution League (SAPL) and the Town of Hampton (TOH).
By subsequent orders this Appeal Board directed that a single response be filed to all of these applications on or before April 20, 1987, and served in such a manner as to assure receipt thereof on or before April 21, 1987.
As required by the regulations, the Mass. AG Application (hereafter cited "AG App.") addresses each of the four factors listed in 10 CFR $ 2.788(e).
With respect to the likelihood of success on the merits he argues that there are five legal errors which have occurred as to which he is likely to prevail:
(1) The failure of the agency to prepare an environmental impact statement (EIS) addressing low power operations, AG App. at 3-4; (2) failure of the Applicants to comply with the requirements of 10 CFR S 50.33(g), AG App.
2-3; (3) error in the Licensing Board's rejection of two late-filed contentions, AG App. at 5-6; (4) error in the Licensing Board's granting summary disposition of SAPL Supp.
Contention III that the Seabrook EIS' discussion of Class 9 Accidents was deficient; and (5) invalidity of 10 CFR
$ 50.47(d).
As to irreparable injury:
the Attorney General claims irreparable injury by virtue of the fact that operation at low power will create high level waste which will require safeguarding, that such activity commits the site to nuclear long-term waste storage, exposes workers to potentially harmful radiation, results in loss of salvage !
l i
value of fuel and plant components, and results in the loss a
of Mass. AG's "right to have these issues first resolved."
AG App. 8-9.
As to harm to other parties, it is argued that there is no harm to Applicants because full power operation is at least one year away.
AG App.
at 9.
And, finally, as to the public interest factor, it is argued generally that the public interest is contravened by alleged " harm to the environment from low-power operation" and monetary expense, and that "the important issues raised.
demand resolution" prior to low power operation.
AG App. 9-10.
The NECNP Application (NECNP App.) also addresses the four factors.
All of NECNP's points as to likelihood of success are also argued by Mass. AG save one.
Compare NECNP App. 2-8 with AG App.
3-8.
NECNP argues that certain necessary offsite emergency planning elements are not in place in Massachusetts.
NECNP App. at 5.
All of NECNP's points on irreparable harm save two are also argued by Mass.
AG.
Compare NECNP App. 8-9 with AG App.
8-9.
The two additional matters argued by NECNP are that NECNP is allegedly irreparably harmed by the creation of an accident risk and the lack of NEPA analysis for low power operation.
As to harm to other parties, NECNP argues that because full power operation has no " reasonable prospect" there is no harm in staying low power operation.
NECNP App. 9-10.
NECNP makes the same arguments on the public interest factor 3-
as does Mass. AG.
Compare AG App. at 9-10 with NECNP App.
at 10.
SAPL's Application (SAPL App.) also addresses the four factors as required by 10 CFR S 2.788.
As to likelihood of success, SAPL adopts the Mass. AG arguments and further claims a likelihood of success on two other issues:
(1) the failure of the ASLB to require a fully compliant SPDS before nuclear operation and (2) alleged error in the Licensing Board's refusal to call certain Staff witnesses.
SAPL App.
at 2-6.
SAPL claims no irreparable injury in addition to what is already described in connection with the Mass. AG and NECNP Applications.
Compare SAPL App. at 6 with AG App.
at 3-8 and NECNP App.
2-8.
And SAPL makes no arguments on the " harm to other parties" or "public interest" factors not made by Mass. AG.
Compare SAPL App. at 6-7 with Mass. AG App. at 9-10.
The TOH Application adopts the Mass. AG Application and, in addition, notes a vote by TOH not to implement the New Hampshire Emergency Plan.
ARGUMENT l
Introduction The burden of persuasion as to all four of the 10 CFR
$ 2.788 factors is on the movants.
Alabama Power Co.
(Joseph M.
Farley Nuclear Plant, Units 1 and 2), CLI-81-27, t
i 14 NRC 795, 797 (1981).
As seem below, the movants herein
have not satisfied the burden with respect to any of the factors.
1.
The Likelihood of Success As to the likelihood of success factor, it is settled that there must be a greater showing than a possibility of legal error by a Licensing Board.
Philadelphia Electric Co.
(Peach Bottom Atomic Power Station, Units 2 and 3),
ALAB-221, 8 AEC 95, 98 (1974); Philadelphia Electric Co.
l (Peach Bottom Atomic Power Station, Units 2 and 3),
ALAB-158, 6 AEC 999 (1973); Wisconsin Electric Power Co.
(Point Beach Nuclear Power Plant, Unit 2), ALAB-58, 4 AEC 951, 953 (1972).
Mere establishment of possible grounds for appeal is not sufficient.
Toledo Edison Co. (Davis-Besse Nuclear Power Station, Units 1, 2 and 3), ALAB-385, 5 NRC 621, 634 (1977); Alabama Power Co. (Joseph M.
Earley Nuclear Plant, Units 1 and 2), CLI-81-27, 14 NRC 795, 797 (1981).
And if the error alleged is one of fact, for purposes of a stay motion the showing must be that the finding is wholly unsupported by the record, i.e.,
there is no " substantial evidence" to support it.
See ALAB-385, supra, at 629.
With the foregoing principles in mind we address the various points made by the movants.
The Commission has ruled that no separate EIS is required for low power operation.
Long Island Lighting Co. (Shoreham Nuclear Power Station), CLI-85-12, 21 NRC 1587 (1985);
id., CLI-84-9, 19 NRC 1323, 1327 (1984).
This Appeal Board may not declare 10 CFR $ 50.47(d) invalid.
And the Commission has ruled that it gives an unqualified right to a low power license even absent NRC or FEMA approval of offsite emergency plans and without the need for a predictive finding of reasonable assurance that a full power license will eventually issue.
Long Island Lighting Co. (Shoreham Nuclear Power Station),
CLI-85-1, 21 NRC 275, 278 (1985);
id., CLI-84-9, 19 NRC 1323, 1327 (1984); id. CLI-83-17, le NRC 1032, 1034 (1983).
With respect to the 10 CFR $ 50.33(g) issue, the Commission has decided that a plan must be filed.
Public Service Company of New Hamoshire (Seabrook Station, Units 1 and 2 ), CLI-87-2, 25 NRC (April 9, 1987), Slip Op.,
passim.
However, a plan has been filed and the Commission has retained jurisdiction over the issue of whether the problem is now moot.
Id. at n.1.
Thus, this Appeal Board is without jurisdiction over this issue as of this time.
With respect to the treatment of Class 9 accidents in the FES, the issue raised was decided on cross-motions for summary judgment ASLB Mem. and Ord., unpublished, (May 11, 1983) at 10, 30-35.
The contention disposed of was SAPL Supp. III.
That contention as admitted, Public Service I
Company of New Hampshire (Seabrook Station, Units 1 & 2),
LBP-82-76, 16 NRC 1029, 1082 (1982), reads as follows:
"The applicable requirements of the Commission's Interim Policy Statement issued June 13, 1980, 45 Fed. Reg. 40101 on Nuclear Power Plant Accident Considerations Under the National i l
O Environmental Policy Act of 1969 have not been met."1 In an answer to an interrogatory SAPL acknowledged that this contention relates only to the Staff's compliance with the requirements of NEPA as specified in the Commission's Interim Policy Statement referenced in the above-quoted contention.
SAPL's Responses to Applicants' Interrogatories, No. XXV-2 (undated, (approx. 1/13/83)).
See also SAPL's Motion for Summary Disposition (Contention SAPL Supp. III), passim (Feb. 11, 1983).
Thus, even assuming, arquendo, that the EIS for Seabrook did not comply with the CEQ regulations cited by Mass. AG, AG App. at 6, that issue is not available for appeal on this record.
The decision of the Licensing Board granting summary disposition of SAPL Supp. III cited above is thorough and unassailable in law and fact on the issue actually raised in the contention.
With respect to the late-filed contentions on sirens:
Both contentions raised the question of whether, in fact, siren sound levels were adequate in certain areas of the EPZ.
The contentions were not only late filed; hearing them would have required a reopening of the record.
The 1
This was the wording of the contention as reframed by Applicants, Applicants' Response to the Supplement to the Petition for Leave to Intervene and Further Statement of Contentions on Behalf of the Seacoast Anti-Pollution League at 4 (April 26, 1982), and accepted by SAPL, Tr. 136 (May 6, 1982).
Licensing Board decided that such issues did not require opening the record, inter alia, because no significant safety issue was presented.
10 CFR $ 2.734(a)(2).
- See, e.g, ASLB Mem. and Ord., unpublished, (March 25, 1987) at 13.
This ruling is unassailable.
Because it involves measurements against wholly objective criteria, the audibility and operability of sirens is properly a matter t
committed to Staff oversight.
Louisiana Power and Light Co.
(Waterford Steam Electric Station, Unit 3), ALAB-732, 17 NRC 1076, 1104-05 (1983).
NECNP's argument that the Licensing Board erred in not
(
withholding low power operational authority, NECNP App. at 5,
suffers from the same deficiency as the Class 9 accidents issue discussed earlier.
NECNP never raised this issue below.
See NECNP's Opposition to Applicants' Motion for Issuance of Partial Initial Decision Authorizing Low Power Operation, passim (July 2, 1986).
See also ASLB Mem. and Ord., unpublished, (July 25, 1986) at 9.
As to the SPDS issue, there is ample evidence on the record to support the Board's conclusion that waiting until full power operation to include certain parameters in the SPDS did not compromise public health and safety.
LBP-87-10 at 14, 27-46.
SAPL's argument that the Licensing Board improperly reframed the SPDS issue, SAPL App. at 4, conveniently ignores the fact that the reframing took place as the result of a partial grant of a motion for summary disposition.
ASLB Mem. and.
l Ord., unpublished, (Sept. 15, 1986), passim.
Indeed, the Board leaned over backwards to give SAPL the issue it did which arguably was not even within the four corners of the contention.
Finally, NUREG-0737, Supp. No. 1 puts no specific time limit on when an SPDS in full compliance must exist.
As to the witness issue, even assuming the witness had been called and testified as SAPL hoped, i.e.,
that a certain schedule of compliance had not been enforced for no good reason, that would not affect the basic finding that no compromise of public safety is involved and that " reasonable assurance" exists.
2.
Irreparable Harm "The most significant factor in deciding whether to grant a stay request is 'whether the party requesting a stay has shown that it will be irreparably injured unless a stay is granted.'"
Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit 1), CLI-84-17, 20 NRC 801, 804 (1984) quoting Westinghouse Electric Corp. (Export to the Philippines), CLI-80-14, 11 NRC 631, 662 (1980).
If no irreparable injury to the movant is shown, a truly compelling showing must be made on the other three factors.
Florida Power & Light Co. (St. Lucie Nuclear Power Plant, Unit 2), ALAB-415, 5 NRC 1435, 1437 (1977).
It is the crucial factor; without it the chances of obtaining a stay are extremely slight.
E.g.,
Public Service Company of New Hampshire (Seabrook Station, Units 1 and 2), CLI-77-27, i
6 NRC 715, 716 (1977), Public Service Company of Indiana (Marble Hill Nuclear Generating Station, Units 1 and 2),
ALAB-437, 6 NRC 630, 632 (1977).
Speculative assertions of injury are of no consequence:
"'[a] party moving for a stay is required to demonstrate the injury claimed is "both certain and great."'"
Cleveland Electric Illuminating Co.
(Perry Nuclear Plant, Units 1 and 2), ALAB-820, 22 NRC 743, 747 (1985), quoting Cuomo v. NRC, 772 F.2d 972, 976 (D.C.
Cir. 1985), which in turn quoted Wisconsin Gas Co. v. FERC, 758 F.2d 669, 674 (D.C. Cir. 1985).
Measured against the foregoing principles the motions at bar are well short of the mark.
As to the effects of the creation of high-level waste and contamination:
Assuming safeguards will be required for high-level waste, that is not an injury specific to any of the movants separate from society as a whole and, moreover, the amount of such waste which will be generated is infinitesimal in amount compared to what exists already in the nation.
The alleged potential loss of salvage value is a potential injury to the Applicants not the movants.
The same is true of the contention that the site allegedly becomes committed to long-term storage.
All of these potential economic injuries to the Applicants as they affect the ratepaying public are not irreparable injuries cognizable in a stay context.
Philadelphia Electric Co. (Limerick Generating Station, Units 1 and 2), ALAB-789, 20 NRC 1443, 1447 (1984); Kansas Gas & Electric Co. (Wolf Creek Generating Station, Unit 1),
ALAB-424, 6 NRC 122, 128 n.7 (1977).
The argument that contamination will foreclose conversion to other fuels has no force in a PWR context.
The primary side of a PWR plant is not useable for any alternate fuel.
And again, assuming such an effect from contamination, the injury is economic and to the Applicants, not the movants.
The alleged injury in the form of worker exposure is not injury to these movants.
As to the argument that an opportunity to have review of the movants' issues is lost unless a stay issues:
"[ilf meaningful review meant that every petitioner for review were entitled to a stay, the Commission would presumably have provided for one automatically."
Consolidated Edison Co. of New York, Inc.
(Indian Point Station, Unit 2), ALAB-414, 5 NRC 1425, 1433 (1977).
The argument that an accident could happen is presumably an argument that the operation of Seabrook at low power creates a theretofore nonextant risk to the movants.
Creation of a risk is not irreparable injury.
It is not cognizable injury at all.
And any nuclear plant creates an additional risk (as does the putting of a new car on the road).
If this were to be viewed as cognizable irreparable injury, the Commission would have provided for an automatic stay.
It is well settled that the lack of a NEPA analysis O
of low power operation is not a cognizable injury.
See cases cited in EIS discussion, supra 6 1 at p.
5.
3.
Injury to Other Parties The fact that a full power license may not issue for a long time is no reason to stay low power operation, and the loss of the ability to test at the earliest time possible is a deprivation of a real benefit for the Applicants.
See Long Island Lighting Co. (Shoreham Nuclear Power Station),
CLI-85-12, 21 NRC 1587, 1590 (1985).
NECNP's argument that this doctrine should not apply presupposes rulings on Applicants' pending 10 CFR $ 2.758 petition, activities in the current rulemaking proceeding and even an unalterable mindset of the Governor of The Commonwealth of Massachusetts.
This is not permissible.
CLI-84-9, supra, at 1327, 4.
Public Interest It is argued that harm to the environment and unrecoverable expense are injuries to the public interest.
Low power operation has no significant impact on the surrounding environment by releases of effluent during normal operation.
CLI-85-12, supra, at 1590.
The argument that the public interest dictates a stay because the issues on appeal are important lacks any merit.
ALAB-414, supra, at 1433.
The risks to the public from low power operation ar' negligible.
There is an affirmative public interest in 12 -
getting this well-built plant fully tested and thus fully ready for operation as soon as possible.
CONCLUSION The movants have made no substantial showing on any of the four factors.
The applications for stay should be denied.
Respectfully submitted, Thomas C. DGWhan, Jr.
George H. Lewald Kathryn A.
Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 Counsel for Applicants 13 -
COCHETED 0960 CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr., one of the attorneys for GEb AR? 23 P4 :32 Applicants herein, hereby certify that on April 17, 1987, I made service of the within document by mailing copies thereofFederalExpresstothosemarkedwithanasterisk. ppg,XMET,ioil[IN'[
otherwise first class mail, postage prepaid, to:
EE A N;q
- 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 Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814
- Gary J. Edles Mr. Ed Thomas Atomic Safety and Licensing FEMA, Region I Appeal Panel 442 John W. McCormack Post U.S. Nuclear Regulatory Office and Court House Commission Post Office Square East West Towers Building Boston, MA 02109 4350 East West Highway Bethesda, MD 20814 Sheldon J. Wolfe, Chairperson Robert Carrigg, Chairman Atomic Safety and Licensing Board of Selectmen Board Panel Town Office U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 Washington, DC 20555 Dr. Emmeth A. Luebke
- Diane Curran, Esquire Atomic Safety and Licensing Harmon & Weiss Board Panel 2001 S Street, N.W.
U.S. Nuclear Regulatory Suite 430 Commission Washington, DC 20009 Washington, DC 20555 Dr. Jerry Harbour Stephen E. Merrill, Esquire 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 Washington, DC 20555 25 Capitol Street concord, NH 03301-6397
Atomic Safety and Licensing
- Sherwin E. Turk, Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission Tenth Floor 7735 Old Georgetown Road Bethesda, MD 20814 Atomic Safety and Licensing
- Robert A. Backus, Esquire Appeal Board Panel 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 Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333
- Paul McEachern, Esquire
- Carol S.
Sneider, Esquire Matthew T. Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue One Ashburton Place, 19th Floor P.O. Box 360 Boston, MA 02108 Portsmouth, NH 03801 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 Mr. Angie Machiros U.S.
Senate Chairman of the Washington, DC 20510 Board of Selectmen (Attn Tom Burack)
Town of Newbury Newbury, MA 01950 Senator Gordon J. Humphrey Mr. Peter S. Matthews One Eagle Square Suite 507 Mayor concord, NH 03301 City Hall (Attn:
Herb Boynton)
Newburyport, MA 01950 Mr. Thomas F. Powers, III
- Mr. William S.
Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 4
H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 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 Judith H. Mizner, Esquire Charles P. Graham, Esquire Silverglate, Gertner, Baker McKay, Murphy and Graham Fine, Good & Mizner 100 Main Street 88 Broad Street Amesbury, MA 01913 Boston, MA 02110 y"
_M V&/MT_ /
Thomas G.
DigtigFi, Jr.