ML20207Q295
| ML20207Q295 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/21/1987 |
| From: | Bellotti F, Bronstein D, Sneider C MASSACHUSETTS, COMMONWEALTH OF |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#187-2269 OL-1, NUDOCS 8701270131 | |
| Download: ML20207Q295 (18) | |
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ukhf[0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commissioners Cli:
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In the Matter of
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PUBLIC SERVICE COMPANY OF NEW
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Docket Nos.
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50-443/444-OL-l (Seabrook Station, Units 1 and 2)
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(On-Site EP)
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January 21, 1987
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ATTORNEY GENERAL FRANCIS X. BELLOTTI'S BRIEF IN SUPPORT OF REVERSAL ALL OF THE ATOMIC SAFETY AND LICENSING APPEAL BOARD'S NOVEMBER 20, 1986 ORDER DENYING THE APPEAL FROM THE ORDER OF THE LICENSING BOARD AUTHORIZING ISSUANCE OF OPERATING LICENSE TO CONDUCT FUEL LOADING AND PRECRITICALITY TESTING In response to the Commission's Order of January 9,
- 1987, Attorney General Francis X.
Bellotti hereby submits this brief advocating reversal of the Atomic Safety and Licensing Appeal Board's November 20, 1986 Decision (ALAB-853) denying his appeal of the Licensing Board's October 7, 1986 Order authorizing issuance of an operating license to conduct fuel loading and precriticality testing.
STATEMENT OF PROCEEDINGS On August 22, 1986, the Applicants in this proceeding moved, pursuant to 10 C.F.R.
S 50.57(c), for authorization to conduct fuel loading and precriticality testing.
On 8701270131 B70121 PDR ADOCK 05000443 G
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September 3, 1986, Attorney General Bellotti filed _his Objection to Applicants' Motion, citing, inter alia, the Applicants' failure to comply with the provision of 10 C.F.R.
S 50.33(g) requiring submission of radiological emergency response plans of all state and local governments within the Seabrook Emergency Planning Zone (EPZ).
In fact, no off-site emergency response plans have yet been submitted for the six Massachusetts communities within the Seabrook EPZ or for the Commonwealth of Massachusetts.
On October 7, 1986, the Licensing Board granted Applicants' motion.
Attorney General Francis X.
Bellotti appealed the Licensing Board's Order to the Appeal Board, contending on appeal that 10 C.F.R.
S 50.33(g) requires submission of the emergency response plans prior to the issuance of any operating license.1/
On November 20, 1986, the Appeal Board denied the Attorney General's appeal, on the ground that section 50.33(g)
"whether read in isolation or const rued consistently with the provisions of section 50.57(c) and 50.47(d)," does not require the submission of off-site radiological response plans prior to
.the issuance of a fuel loading or low-power operating license.
ALAB-853 at 6.
The Attorney General filed before the Commission a Petition for Review of the Appeal Board's decision on December 5, 1986.
On January 9, 1987 the Commission took review of the decision sua sponte to consider the single issue:
"Whether as a matter of law or policy a utility 1/
Intervenor Seacoast Anti-Pollution League (SAPL) joined the Xttorney General's appeal, endorsed his argument on appeal, and raised several additional claims.
On December 8, 1986, the Appeal Board denied SAPL's appeal.
See ALAB-854.
applicant should be required to submit a radiological emergency plan (either a governmental plan or a utility plan) for the entire emergency planning zone (EPZ) for the facility before any operating license may be issued."
Commission's Order, dated January 9, 1987, at 1.
Recognizing that this issue, raised by Attorney General Bellotti in reference to issuance of an operating license to load fuel is equally applicable to low power licensure, the Commission by its Order of January 9 stayed the Director of Nuclear Reactor Regulation from authorizing low power operation until the Commission completes its review of ALAB-853.
Accordingly, this brief addresses both operating licenses for f uel loading and for low-power operation.
ARGUMENT I.
The Decision of the Board Should be Reversed as a Matter of Law.
A.
The Clear Terms of Section 50.33(g) Require the Submission of Off-site Radiological Emergency Response Plans Prior to the Issuance of an Operating License.
Section 50.33(g) requires, as a part of the application process for an operating license for a nuclear power reactor, that:
the applicant shall submit radiological emergency response plans of state and local governmental entities in the United States that are wholly or partially within the plume exposure pathway Emergency Planning Zone (EPZ),
as well as the plans of state governments wholly or partially within the ingestion pathway EPZ. "
I
,e 10 C.F.R.
S 50.33(g).
A fair reading of section 50.33(g) can yield but one meaning for that section:
that it requires the submission of. state and local emergency response plans priot to the issuance of an operating license.
The requirements of section 50.33(g) are mandatory.
As the Shoreham Licensing Board has stated:
[A]n interpretation (requiring the filing of local government offsite emergency plans only if such plans exist] would be contrary to the plain meaning of Section 50.33(g) and in conflict with the overall regulatory scheme of 10 C.F.R. Part 50, which generally sets forth mandatory requirements for the issuance-of a construction permit or an operating license.
Indeed,' Section 50.33 is entitled ' contents of applications; general information;' and begins with the general preamble 'Each application shall state:.'
Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), LBP-83-22, 17 URC 608, 620 (1983).
The Commission in its Statement of Consideration for the final rule made clear the mandatory nature of the section 50.33(g) requirement when it stated, "In order to continue operations or to receive an operating license, an apnlicant/ licensee will be required to submit its emergency plans, as well as state and local governmental response plans, to NRC."
45 Fed. Reg. 55402, at 55403, Col. 1-2 (August 19, 1980).
The Commission's emergency planning regulations, then, essentially establish two conditions for the issuance of an operating license:
(1) as part of the' application process, the submission of emergency response plans as set forth in section 50.33(g); and (2).a determination that such plans are adequate in accordance with the standards set forth at section 50.47 and Part 50, Appendix E.
While the commission's regulations, at section 50.47(c), do make some allowance for the issuance of an operating license in those cases where plans do not meet all the applicable planning standards set forth at S 50.47(b),
nowhere in the Commission's regulations can there be found any basis for allowing issuance of an operating license absent the required submission of state and local response plans.
- Indeed, the commission in its Statement of Consideration for the emergency planning regulations notes that i n deciding whether to permit reactor operation in the face of some deficiencies in the emergency reponse plans, "the commission will examine state plans, local plans, and licensee plans to determine whether features of one plan can compensate for deficiencies in another plan 45 Fed. Reg. at 55403, Col.
1.
Thus the Commission assumes that in all cases state and local plans will be submitted and only makes allowances for issuance of an operating license in those cases where the required state, local, or utility plan may be deficient (and adequate compen-satory measures are taken).
The decision in the Shorehar licensing case, the only NRC decision to construe section 50._
- ),
i s not to the contrary.
See Long Island Lighting Co.,
supra; aff'd, CLI-83-13, 17 NRC 741.
In that case the Licensing Board held only that section 50.33(g) does not require the termination of licensing
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F proceedings in the absence of the submission of a local government sponsored offsite emergency response plan when the utility has submitted an offsite emergency response plan attempting to compensate for the lack of the local-sponsored plan.
Neither that decision nor any of the later Shoreham decisions authorized the issuance of any operating license in the absence of offsite plans.
In the instant case, no offsite plans have been submitted for the six Massachusetts communities within the Seabrook plume exposure pathway EPZ cr for the Commonwealth of Massachusetts, and no plans (utility-sponsored or otherwise) have been submitted to compensate for the lack of Massachusetts state and local plans.
In such circumstances, the Commission's regulations are clear that no operating license may issue.
2.
The Section 50.33(g) Requirement That Off-Site Plans be Submitted Prior to Receipt of Any Operating License, Including One for Fuel Loading and/or Low-Power Testing, is Consistent With The Objectives of Sections 50.47(d) and 50.57(c).
Although the Appeal Board appears to acknowledge that emergency response plans of state and local governments must be submitted prior to the issuance of a full power operating license it errs when it concludes that there is no requirement c
that such plans be submitted prior to the issuance of an operating license to conduct fuel loading or low-power testing.
That conclusion of the Board seems to be based on a determination that a reading of section 50.33 requiring the l
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submission of all emergency response plans prior to low-power licensure.would be inconsistent with the objectives of Regulations 50.57(c) and 50.47(d).
The Commission's regulations, however, make no-distinction between types of operating licenses with respect ~ to 4
the Section 50.33(g) requirement of submission of plans.
4 Indeed, section 50.33(g) begins with the words, "If the application is for an operating license, the applicant shall submit (emphasis added).
Nowhere does the regulation condition or limit the words " operating license" or otherwise suggest that its requirements are applicable only to operating licenses authorizing full power operation.
Indeed, the very fact that the submission of' emergency response plans is a requirement of the operating license application would necessarily mean that such requirement is a prerequisite to the issuance of any license authorizing any level of operation requiring licensure.E!
2/
The Appeal Board attempts to avoid this logic (and thereby undermine the plain meaning of the regulation and the term
" application") based on the following reasoning:
that since an application is "a
'living, breathing' document" subject to amendment at least until full-power licensure there can be no requirement that all the emergency planning components of an-application be submitted until prior to the issuance of a full power license.
ALAB-853 at 7.
That proposition, however, defies logic.
It is one thing to allow an application (including emergency response plans) to be amended after receipt of an operating license for fuel-loading or low power testing; it is quite another not to require that all the components of that application be submitted prior to such low power operation.
Moreover, since an application may be amended even after full-power licensure, see 10 C.F.R.
S 50.71(e), to follow the Appeal Board's reasoning to its logical conclusion would mean that an application would never need to be completed even prior to receipt of a full power license.
t
The provisions of section 50.47(d) are not to the contrary.
That regulation provides, in pertinent part:
Notwithstanding the requirements of paragraphs (a) and (b) of this section, no NRC or FEMA review, findings, or determinations concerning the state of offsite emergency preparedness or the adequacy of and capability to implement state and local offsite emergency response plans are required prior to issuance of an operating license authorizing only fuel loading and/or low power operations (up to 5%
of rated power).
Insofar as emergency planning and preparedness requirements are concerned, a license authorizing fuel loading and/or low power operation may be issued after a finding is made by the NRC that the state of onsite emergency preparedness provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
10 CFR S 50.47(d) (emphasis added).
Section 50.47(d) thus by its express terms obviates only the requirement set forth in SS 50.47(a) and (b) that " review, findings or determinations" be made concerning the adequacy of offsite emergency plans.
It does not eliminate the requirement that such plans be submitted as part of the Section 50.33 application process.
The requirement of plan submission is quite distinct from the requirement that findings be made as to the adequacy of such plans.
This distinction is evidenced by the fact that the two requirements are set forth in two separate regulations --
Section 50.33 and Section 50.47.
The Appeal Board attempts to circumvent this distinction by the mere statement that it does not believe the Commission intended "that offsite emergency planning matters -- including the filing of state or 'ocal emergency plans -- would stand in the way of low-power operation."
ALAB-853 at 11.3/
Despite this assumption of the Appeal Board, there is no regulatory language evidencing such intent on the part of the Commission.
To the contrary, if there were any intention to obviate the requirement that offsite emergency response plans be submitted prior to fuel loading or low-power operation, it would be expressly stated, either in the language of section 50.47(d) or directly in section 50.33.
In the absence of such express language, there can be no basis for not requiring full compliance with that section prior to the issuance of an operating license to conduct fuel loading and precriticality testing.
Nor is this interpretation of section 50.33(g), requiring submission of all off-site emergency response plans prior to the issuance of any operating license, inconsistent with the objectives of section 50.57(c).
As stated by the Appeal Board, "the purpose of section 50.57(c) is to accord an applicant an opportunity to obtain a license authorizing low-power operation 3/
The Appeal Board apparently bases this conclusion at least In part on the Commission's decision in the Shoreham proceeding in which it stated:
"Section 50.47(d) gives unqualified authorization to issue a 2ow power license in the absence of NRC or FEMA approval of an off-site emergency plan, as long as other prerequisites.
are met," ALAB-853 at p.
10, fn. 11, citing Long Island Lighting Co. (Shoreham Nuclear power Station, Unit 1), CLI-83-17, 17 NRC 1032, 1033 (1983).
Attorney General Bellotti, however, is not arguing herein that a fuel loading license may not be issued in the absence of NRC or FEMA approval of plans.
He contends, rather, that consistent with the language of Section 50.33(g), that such a license may not be issued in the absence of plan submission.
Thus the Shoreham decision is not on point.
Lso it can test the facility even if issues unrelated to low-power operations have not yet been resolved."
ALAB-853, at 9.
Yet the regulatory history of this section demonstrates that section 50.57(c) was promulgated as part of a package of regulations designed.to streamline the hearing process.
Its adoption was motivated by a concern that reactor operation was being unduly delayed by lengthy adjudicatory proceedings.
See 37 Fed. Reg. 15127 (July 28, 1972).
It would thus be inconsistent with this regulatory history to interpret section 50.57(c) so as to allow an Applicant to obtain a low power operating license when it has not even completed the application and taken all steps within its own power to set the review process in motion to obtain a full power license to operate.
Under such circumstances, where the Applicant has failed to submit emergency response plans, it is the Applicant, not the review process, that is responsible for any delay in licensure.
Moreover, the review process for the adequacy of emergency response plans including the adjudicatory hearings takes at least several months.
No purpose can be served by allowing fuel loading or low power operation (which typically requires only a matter of a few months) to commence when the review process has not even been triggered by the submission of the state and local government plans required by Section 50.33(g).
Until such time as the requisite plans have been submitted,S/
4/
The Attorney General does not concede that submission of a utility plan for state and local governments would satisfy the section 50.33(g) mandate.
However, the Applicants have not yet taken even this step as to plans for Massachusetts and the six Massachusetts towns within the EPZ. _
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the application is incomplete and the applicants cannot be entitled to begin any form of operation.
II.
As a Matter of Policy, The Commission Should Require The Submission of Off-Site Emergency Response Plans Prior to The Issuance of an Operating License For Fuel Loading or Low-Power Testing.
There is no policy argument that could be made in support of allowing low-power operation prior to submission of off-site emergency plans.
The sole purpose of low-power operation is to test the facility and discover and work out. problems with the reactor.
The testing typically requires only a matter of several months, and after such testing is completed, there is
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little, if any, benefit that can be obtained from further operation at such low levels of power (below 5%).
Given the nature of the review process for emergency plans (requiring FEMA review of plans, a full-scale exercise of the plans and an opportunity for an adjudicatory hearing on the adequacy of such plans), ample time for low power testing would in all cases be provided after plan submission.
Thus no benefit could be gained by allowing such testing prior to plan submission.
On the other hand, no discernible benefit can be derived from such operation unless the reactor eventually receives its full-power license to operate, and indeed, there are economic as well as environmental costs to be considered in the event that low power operation is allowed but not followed by full -
A power operation.
Yet until such point as an applicant has l
complied with at least the application requirements for an operating license, there can be absolutely no presumption that the applicant will ever be entitled to receive a full-power license and there can be no reason for allowing low-power operation.
Thus, as a matter of policy, it makes sense for the Commission to maintain the present distinction in its regulations that requires the Applicant to at least complete the application by submitting all off-site response plans prior to its receipt of a fuel-loading or low-power operating license.
These policy arguments in favor of requiring plan submission prior to low power operation become even stronger when applied to the facts of the Seabrook licensing proceeding.
As the Commission is undoubtedly aware, the Governor of Massachusetts decided last September, in conformance with a position that the Commonwealth has sought to be heard on since the siting of this plant, that he was unable to, and would not, submit emergency response plans for that substantial portion of Seabrook's EPZ that lies within Massachusetts.
The Applicants have sought to circumvent this action of the Governor, that could well prove to be a bar to full power licensure, by filing a Petition seeking an unprecedented exemption from the Commission's emergency planning regulations.
Applicants are se' king to have the plume exposure emergency planning zone around Seabrook reduced from - _ _ _ - _ - _ _ _ _ _ - _ _ _.
ten miles to one mile.
By taking.such measures, the Applicants have, in effect, conceded the great difficulty, and perhaps impossibility, they expect to encounter in obtaining a fullpower operating license under the present emergency planning regulations.
Under such circumstances, where there is no indication that i
this plant will ever be entitled to receive a full power l
license to operate,1! it makes no sense to allow low power testing and the consequent irradiation of fuel and portions of l
the reactor (along with their attendant costs).
Certainly in l
this case if Applicants ever do submit response plans for that portion of the EPZ within Massachusetts, it must be acknowledged that litigation over the adequacy of such plans will necessarily involve many months 5 and therefore that there would be ample time for low power testing after 5/
Certainly there can be no presumption that the extraordinary relief Applicants are seeking will be granted.
Until the Commission rules otherwise, one must rather presume that Applicants will be held to the emergency planning regulations as they now stand.
1/
Similar delays as those involved over the licensing of the Shoreham reactor must be deemed likely for the Seabrook plant.
The Shoreham reactor, although it was authorized to receive its l
low power license in July, 1985, has still not a year and a half later received its full power license to operate and still it remains highly quesLionable whether that plant will ever receive its full power operating license.
i !h-
9 submission of plans.
Where as in this case such significant bars to full power licensure remain, public policy would thus dictate that no low power license be issued.1!
CONCLUSION For all-the foregoing reasons, Attorney General Bellotti respectfully requests that the Commission reverse the Appeal Board's decision, and order that issuance of a low-power license be stayed until the Applicants have submitted all off-site emergency response plans.
Respectfully submitted, FRANCIS X. BELLOTTI A
Ofatd $
k k Ck L By:
Carol S.
Sneider Assistant Attorney General htwdd W cnstn o /cc Donald S.
Bronstein
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Assistant Attorney General Environmental Protection Division Department of the Attorney General One Ashburton Place, Room 1902 Boston, MA 02108 (617) 727-2265 Dated:
January 21, 1987 7/
In this regard, the Attorney General would urge the Commission to reconsider its position taken in the Shoreham licensing case, and refuse to authorize the issuance of a low power license in cases where the off-site plans submitted are not those of the state or local governments, but are, rather, those of the utility.
In such cases, there is posed such a significant bar to full power licensure (as evidenced by the fact that Shoreham has still not received its full power license to operate) that it cannot be in the public interest to allow low-power testing at that stage.
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4 DOLMETEF UNITED STATES OF AMERICA U3NRC NUCLEAR REGULATORY COMMISSION
'87 JAN 22 A10:28 In the Matter of
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0FFIE P.
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GCChETim A ; j_ mr t' E
50 413/444-OL PUBLIC SERVICE COMPANY OF NEW
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Docket No.(s)
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(Seabrook Station, Units 1 and 2)
)
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CERTIFICATE OF SERVICE I, Carol S.
Sneider, hereby certify that on January 21, 1987 I made service of the within documents by mailing copies thereof, postage prepaid, by first class mail, or as indicated by an asterisk, by Federal Express mail, to:
- Lando W.
Zech, Jr., Chairman
- Thomas M.
Roberts Nuclear Regulatory Commission Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555
- James K.
Asselstine
- Frederick M.
Bernthal Nuclear Regulatory Commission Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555
- Kenneth M.
Carr
- Alan S.
Rosenthal, Chairman Nuclear Regulatory Commission Atomic Safety & Licensing Washington, DC 20555 Appeal Board U.S.
Nuclear Regulatory Commission East West Towers Building Third Floor Mailroom 4350 East West Highway Bethesda, MD 20814 Gary J.
Edles Howard A.
Wilber Atomic Safety & Licensing Appeal Atomic Safety & Licensing Appeal Board Board U.S. Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commission East West Towers Building East West Towers Building Third Floor Mailroom Third Floor Mailroom 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814
6
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Sheldon J. Wolfe, Chairperson Helen F. Hoyt, Chairperson Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission East West Towers Building East West Towers Building Third Floor Mailroom Third Floor Mailroom 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Dr. Emmeth A. Luebke Dr. Jerry Harbour Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission East West Towers Building East West Towers Building Third Floor Mailroom Third Floor Mailroom 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 H. Joseph Flynn, Esq.
Stephen E.
Merrill Assistant General Counsel Attorney General Office of General Counsel George Dana Bisbee, Esq.
Federal Emergency Management Assistant Attorney General Agency Office of the Attorney General 500 C Street, S.W.
25 Capitol Street Washington, DC 20472 Concord, NH 03301
- Docketing and Service Paul A.
Fritzsche, Esq.
U.S. Nuclear Regulatory Office of the Public Advocate Commission State House Station 112 Washington, DC.
20555 Augusta, ME 04333
-Roberta C. Pevear Diana P. Randall State Representative 70 Collins Street Town of Hampton Falls Seabrook, NH 03874 Drinkwater Road Hampton Falls, NH 03844 Atomic Safety & Licensing Robert A.
Backus, Esq.
Appeal Board Panel Backus, Meyer & Solomon U.S.
Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 East West Towers Building Manchester, NH 03106 Third Floor Mailroom 4350 East West Highway Bethesda, MD 20814
- Sherwin E. Turk, Esq.
Judith H.
Mizner, Esq.
Office of the Executive Legal Silvergate, Gertner, Baker Director Fine, Good & Mizner U.S. Nuclear Regulatory Comm.
88 Broad Street Tenth Floor Boston, MA 02110 7735 Old Georgetown Road Bethesda, MD 20814 Atomic Safety & Licensing Jane Doughty Board Panel Seacoast Anti-Pollution League U.S.
Nuclear Regulatory 5 Market Street Commission Portsmouth, NH 03801 Washington, DC 20555 Paul McEachern, Esq.
J. P. Nadeau Matthew T.
Brock, Esq.
Board of Selectmen Shaines & McEachern 10 Central Road 25 Maplewood Avenue Rye, NH 03870 P.O. Box 360 Portsmouth, NH 03801 Sandra Gavutis, Chairperson Calvin A. Canney Board of Selectmen City Manager RFD 1, Box 1154 City Hall Rte. 107 126 Daniel Street E.
Kingston, NH 03827 Portsmouth, NH 03801 Senator Gordon J. Humphrey Angelo Machiros, Chairman U.S.
Senate Board of Selectmen Washington, DC 20510 25 High Road i
(Attn: Tom Burack)
Newbury, MA 10950 Senator Gordon J. Humphrey Peter J.
Matthews 1 Pillsbury Street Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton)
Newburyport, MA 01950 Donald E. Chick William Lord Town Manager Board of Selectmen Town of Exeter Town Hall 10 Front Street Friend Street Exeter, NH 03833 Amesbury, MA 01913 Brentwood Board of Selectmen Gary W. Holmes, Esq.
RFD Dalton Road Holmes & Ellis Brentwood, NH 03833 47 Winnacunnet Road Hampton, NH 03841 Philip Ahrens, Esq.
Diane Curran, Esq.
Assistant Attorney General Harmon & Weiss Department of the Attorney Suite 430 General 2001 S Street, N.W.
State House Station #6 Washington, DC 20009 Augusta, ME 04333
- Thomas G.
Dignan, Esq.
Richard A.
Hampe, Esq.
R.
K. Gad III, Esq.
Hampe & McNicholas Ropes & Gray 35 Pleasant Street 225 Franklin Street Concord, NH 03301 Boston, MA 02110 Beverly Hollingworth 209 Winnacunnet Road Edward A. Thomas Hampton, NH 03842 Federal Emergency Management Agency 442 J.W.
McCormack (POCH)
Boston, MA 02109 William Armstrong Civil Defense Director Michael Santosuosso, Chairman Town of Exeter Board of Selectmen 10 Front Street Jewell Street, RFD 2 South Hampton, NH 03827 Exeter, NH 03833 Robert Carrigg, Chairman Anne E. Goodman, Chairperson Board of Selectmen Town Office Board of Selectmen Atlantic Avenue 13-15 Newmarket Road Durham, NH 03824 North Hampton, NH 03862 Allen Lampert Civil Defense Director Charles P. Graham, Esq.
Town of Brentwood McKay, Murphy and Graham 20 Franklin Street Old Post Office Square 100 Main Street Exeter, NH 03833 Amesbury, MA 01913 Rep. Edward J.
Markey Chairman U.S.
House of Representatives Subcommittee on Energy Conservation and Power Room H2-316 House Office Building Annex No. 2 Washington, DC 20515 Attn:
Linda Correia e,
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Carol S.
Sneider Assistant Attorney General I
Environmental Protection Division i
l January 21, 1997 l
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