ML20215J606
| ML20215J606 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/15/1987 |
| From: | Sherwin Turk NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#287-3792 OL, NUDOCS 8706250056 | |
| Download: ML20215J606 (16) | |
Text
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6/15/87 5
D0'Kfiff im@r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'87 JUN 17 PS :47 1
BEFORE THE ATOMIC SAFETY AND LICENSING BNkRDh _
y I.
Pf % 4 In the Matter of
)
)
Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF
)
50-444 OL L
NEW HAMPSHIRE, et al.
)
f
)
Offsite Emergency Planning (Seabrook Station, Units'1 and 2)
)
NRC STAFF'S RESPONSE TO MOTIONS FOR RECONSIDERATION l
FILED BY THE TGWN OF AMESBURY AND THE TOWN OF HAMPTON t
INTRODUCTION On May 18, 1987, the Licensing Board -Issued a Memorandum and Order II setting forth' the basis for its decision of February. 18,'1987, ruling. on the admissibility of contentions addressing Revision 2 of the.
New Hampshire Radiological Emergency Response Plan (RERP). 2_/ Motions seeking reconsideration of that decision were filed on May 26,1987 by the EI and the Town 'of Town of Amesbury, 3/ and on May 27, 1987 by SAPL
-1/
" Memorandum and Order (Providing Basis for and Revision to Board's Rulings on Contentions on Revision 2 of NHRERP)", dated May 18,1987 (" Order").
-2/
" Memorandum and Order (Ruling on Contentions - Revision 2 New Hampshire Radiological Emergency
Response
Plan ),"
dated February 18, 1987.
'3/.
" Town of Amesbury's Motion for Reconsideration," dated May 26, 1987 ("Amesbury").
4/
" Seacoast Anti-Pollution League's Motion for Partial Reconsideration of the Board's February 18, 1987 and May 18, 1987 Orders," dated May 27,1987 ("SAPL").
The Staff will flie a separate response' to SAPL's motion for reconsideration, on June 16, 1987.
8706250056 870615 yc ol j
PDR ADOCK 05000443 J
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e.
Hampton. 5,/
For the reasons set forth below, the Staff opposes the Town of Amesbury's motion for reconsideration and recommends that it be denied.
Hcwever, the Staff supports the Town of Hampton's motion for reconsideration and recommends that it be granted, except as to Revised Contention IV(A)(3).
DISCUSSION A.
Town of Amesbury.
The Town of Amesbury seeks reconsideration of the Board's Orders, insofar as they rejected Amesbury Contentions 7 and 8 (dealing with the lack of planning in Massachusetts).
Amesbury contends that a balancing of the five factors set forth in 10 C.F.R. 2.714(a) (1 ) favors the admission of these contentions (Amesbury at 1-3); and it further asserts that its contentions deal not with
" deficiencies" in Massachusetts
- planning, but with Massachusetts' more profound policy of
' "n on-pa r tic i pat ion / non-imp lemen tat ion".
In this regard, Amesbury asserts that the Board erroneously relied on the " realism" theory in disposing of its Contentions 7 and 8 (Id. at 3).
As the Licensing Board noted (Order at 5-6), the Staff agreed with Amesbury that a balancing of the five factors in 10 C.F.R. 2.714(a)(1) favored the admission of Amesbury Contentions 7 and 8, although the Staff opposed the admission of those contentions.
The Staff indicated its view that Contention 8 was inadmissible for falling to meet the basis and specificity requirements of 10 C.F.R. 2.714, while both Contentions 7
-5/
" Town of Hampton Motion for Reconsideration and Clarification of May 18, 1987 Memorandum and Order," dated May 27,1987 ("Hampten").
and 8 were. inappropriate for litigation in connection with the New Hampshire RERP. b For these reasons, as more fully set forth in the Staff's. Response of December 19, 1986, the Staff opposes Amesbury's motion for reconsideration and recommends that it be denied.
B.
Town of Hampton.
The Town of Hampton seeks reconsideration of several different aspects of the Licensing Board's Order of May 18, 1987.
The Staff supports Hampton's motion as to each of these matters other than Contention IV(A)(3), for the following reasons.
1.
Exclusion of Original Bases.
The Town objects to the Board's exclusion of the original bases for Contentions ill and IV, which had been provided by Hampton in support of those contentions in its filing of May 23, 1986 (Hampton at 2-5).
The Board justified this action with respect to Contention 111 by stating that the Town's "reincorporation" of its original bases in its supplemental filing of October 31, 1936, " failed to provide sufficient notice to opposing parties lust what it intends to litigate in respect to the previous bases" (Order of May 18,1987, at 14).
With respect to Contention IV, the Board barred the reincorporation of the original basis upon finding " considerable overlap and apparent duplication" between those bases and the bases for the revised contention (ld., at 20-21).
-6/
Amesbury's Contention 7 addressed the overall adequacy of the KLD ETE, as an " integrated" document, given tht. lack of participation in emergency planning by Massachusetts.
That contention did not assert, however, that K LD's time estimates for evacuating New Hampshire portions of the EPZ were flawed because of Massachusetts' non-pa rticipation.
For this reason, the contention was inappropriate for litigation in connection with the New Hampshire RERP (Staff Response at 5-6).
9
_4 The Licensing Board is incorrect in its belief that Hampton's reassertion of its initial bases for these contentions precludes the other parties from knowing what the Town intends to litigate, indeed, no such assertion was ever made in response to Hampton's revised contentions by either the Applicants U or the Staff. U To the contrary, the Staff has assembled a iist of contentions for use in this litigation by itself and the Federal Emergency Management Agency (FEMA),
which specifically includes the original bases provided by Hampton in support of these contentions.
Hampton's reincorporation of its original bases into its revised contentions dbes not preclude the Staff (or, presumably, the Applicants) from understanding the issues that are to be litigated in this proceeding. b Further, with respect to the Board's concern for overlap
-7/
See " Applicants' Answer to Contentions of the Town of Hampton to New Hampshire Radiological Emergency Response Plan Revision 2",
dated November 14, 1986; and " Applicants' Answer to Town of Hampton Supplement to Memorandum on 10 C.F.R. 2.714(a)(1) and Contentions of the Town of Hampton to New Harrpshire Radiological Emergency Response Plan Revision 2,"
dated December 1,
1986.
-8/
See "NRC Staff's Response to Town of Hampton's Memorandum on 10
'CF.R. 62.714(a)(1) and Contentions on NHRERP Revision.
2," dated November 17, 1986; and "NRC Staff's Response to Town of Hampton's First and Second Supplements to its Memorandum and Contentions on NHRERP Revision 2,"
dated December 5,1986.
As the Board will recall, no ruling on the admissibility of Hampton's original ETE contention (Contention lii) had been made before Hampton filed its revised Contention Ill.
Accordingly, in responding to Hampton's l
revised contentions, the Staff addressed only the new bases offered by Hampton in support of its contentions, and specifically incorpor-ated by reference its response to Hampton's original contentions.
I 9/
As the Town points out (Hampton at 4), if the publication of Revision 2 to the RERP has cured any of the inadequacies which were asserted in Hampton's original bases, the proper vehicle for removing those matters from litigation would be the filing of summary disposition motions.
As the Board is aware, many such motions have already been filed by the Applicants.
and duplication, those problems can be addressed by the parties in the course of preparing their testimony on the merits of the contention.
2.
Exclusion of Basis item (C)(7) From Contention 111.
Hampton objects to the Board's exclusion from Revised-Contention ill, of supplemental basis item (C)(7), flied on November 19, 1987 (Hampton at 5-6).
This item had asserted that KLD failed to provide sufficient loformation to permit a critique of its ETE, and that Hampton 1
anticipated "upon receipt of discovery additional unreasonable assumptions, unsupported data, and other flaws and defects in the KLD ETE will become apparent," including certain specified matters which Hampton asserted constituted errors in the KLD ETE.
In excluding this matter, the Board stated that Hampton had six months to review the KLD ETE documents and to frame contentions,
and that
" generalized ed contentions are not to be admitted and subsequently ' fleshed out' during discovery." b The Licensing Board is correct in noting that vague and generalized contentions should not be admitted subject to being " fleshed out" later during discovery.
Nonethciess, basis item (C)(7) did not simply seek to present a generalized concern, with the hope that discovery _ would enable it to develop an acceptable contention.
Rather, as the Staff noted in responding to this item, "the basis provided by Hampton is sufficiently specific to permit admission of this issue for iltigation at this time, notwithstanding Hampton's assertion that it intends to " flesh out" this
-10/ Order of May 18, 1987, at 14., citing Duke Power Co. (Catawba Nuclear Station, Units 1 and 2), ALAB-647,16 NRC 460, 467 (1982).
-l For 'this reason, the Staff ll Issue upon _ conducting discovery."
supported the incorporation of this item into Hampton Contention Ill.
At this time, the Board'should grant Hampton's motion for reconsid-eration of' this matter and admit for_ litigation the specific examples of deficiencies in the KLD ETE which Hampton provided in basis item (C)(7)
As it did previously, however, and as Hampton now suggests (Hampton at 6) the Board should exclucie from this item Hampton's I
assertion that it hopes to demonstrate additional deficiencies in the KLD ETE upon receipt of discovery, for the reasons stated in the Board's Order of May 18, 1987.
3 t
3.
Exclusion of Contention IV(C).
Hampton objects to the exclusion from litigation of Revised Contention IV(C), concerning the estimated size of the "special needs" population.
In this contention, Hampton had asserted that the State's estimate is unsupported by the small (2%) r'eturn rate of the State's s ps : il needs survey cards; which the State itself apparently recognized in arbitrarily increasing its estimate by 50%; Hampton further asserted that the State's estimate resulted in a number which the FEMA Regional Assistance Committee found to be statistically unjustified. E in determining to exclude this contention, the Board noted that it had previously granted summary disposit!on of other contentions related to the
)
11/ "NRC Staff's Response to Town of Hampton's First and Second Supplements to its Memorandum and Contentions on NHRERP
~
Revision 2," dated December 5,1986, at 3-4.
12/ " Memorandum on 10 CFR 62.714(a)(1) and Contentions of the Town of Hampton to New Hampshire Radiological Emergency Response Plan
]
Revision 2," dated October 31,1936, at 20-21.
1
i State's "special needs survey", and that the reasons underlying its prior summary disposition ruling
" apply here" (Order of May 18,
- 1987, at 19). EI J
The Licensing Board should reconsider its determination to exclude this matter from litigation.
As the Board wlIl reali, when it granted summary disposition of the prior "special needs survey" contentions, E l
the Board relied upon the Affidavit of Richard Strome, attached to the Applicants' summary disposition motion, which descrited the State's initial survey of special needs in March 1986 and indicated that such surveys would be conducted annually. El The Staff and FEMA opposed the summary disposition of this issue, stating, in part, that " FEMA and the RAC have found that additional work must be done to identify the special needs populatforis" and that the State's procedure of mailing out postcards to EPZ residents "is neither sufficiently comprehensive nor has kt been j
l
\\
-13/ The Staff had not opposed tne admission of this issue for litigation.
See "NRC Staff's Response to Town of Harnpton's Memorandum on 10
)
UFR 62.714(a)(1) and Contentions en NHRERP Revision 2,"
dated November 17,1986, at 4-5.
-14/ See " Memorandum and Order (Ruling on Summary Disposition Motions of Applicants and State of New Hampshire and Establishing a Date for Filing of Late-Filed Contentions Arising Out of Revision 2 of the j
New Hampshire Radiological Emergency Respon,e Pla n,"
dated November 4, 1986, at 17.
The prior contentions which related, in
- part, to the "special needs" population were South Hampton Contention 8, NECNP Contention N H LP 4, SAPL 18, and SAPL 25, 4
-15/ " Affidavit of Richard H.
Strome (Contention South Hampton-0, NECNP Contention N H LP-4, and Contentions SAPL 18 and 25),"
attached to " Applicants' Motion for Partial Summary Disposition of South Hampton Contention No. 8, NECNP Contention NilLP-4 and SAPL Contentions 18 and 25," dated May 20, 1936.
~
.me-.
4
- ft -
- Implemented." $
The Board discounted that _ view, in part on _ tho
- grounds that "nothing in the Thomas Affidavit of June 11, 1986 reflects whether the survey of special needs of residents within the NH e.mergency planning zone conducted in March 1986 was considered by FEMA" (Order of November 4, 1986, at 16).
The Board found that the State's Civil Defense Director "has made a strcng beginning and has provided for future measures that will prefect [ sic) the identification of pers.cns v:ho at some later date fall into the category of a special needs person "
The Board then
- ruled, as a matter of law that "any additional requirements would fall into the category of dextraordinary measures' not required by the regulations of this Commission." id., at 1G-17.
).
The Staff submits that even if the Board was correct in granting summary. disposition of the prior conte.ntions to the extent that they addressed the special needs survey, the Borad's rationale does not support the rejection of Hamptca Contention IVfC).
This contention does more than challenge the procedure utilized by the State to identify the special needs population.
Rather, it goes further, and challenges the reliability of the survey results and of the State's determination to Increase those results by 50%, given the small response received.
In addition, the contention asserts that the State's " arbitrary" decision to increase the results by 50t demonstrates that the State, too, recognizes the unreliabliity of the survey results, and it cites FEMA's determination 16/ See " Affidavit of Edward A. Thomac," at 4, attached to "NRC Staff's
~
Xii~swer to Motions for Summary Disposition of Off-site Emergency Manning Contentions," dated June 11, 1986.
e,.
_9 that the. State's estimate is statistice!!y unsupported. EI Finally', while the Board ~may have been unaware of FEMA's views as to the adequacy of the State's special needs survey at the time it issued its ruling en summary disposition, FEMA has now provided its _ views on this matter, noting that the State's "special needs" estimate is flawed; this view would likely preclude a finding thet there is no genuine issue of material fact with respect to this contention. EI Acccrdingly, the P6ard should reconsider its ruling of May 18,1987,. and permit this issue to proceed to litigation.
4.
[ Partial] Exclusion of Contention IVIA)(3).
Hampton objests to the Licensing Board's exclusion of Hampton Revised Contention IV(A)(3), on the grounds that letters of agreed.ent with individual Teamsters Union members should be required.
In this regard, the Board rejected "that portion of Basis (A) that alleges that
-t7/ The Board should be aware' that thir, contention is bolstered by FEM A's recently expreosed view that 16adeqyacies exist in thei NHRERP's estin. ate of the special needs population.
See " Current i
FEMA Position on Admitted Contentions on New. HampshTre Plans for Seabrook," at 17-18, attached as " Appendix A" to " Response of the Federai _ Emergency Manageite.nt Agency to Massachusetts Attorney General James M.
Shannon's Off-Site Emergency Preparedness Interrogatories and Request for Production of Documents to FEMA i
(Set No. 2'y," dated June 4,1987 (hereinafter referred to as " FEMA Position").
-18/ The Staff notes tha~t the standard for the acceptance of contentions is much lower than the summary disposition standard recited in the text, 6ad requires cnly that the centention satisfy the basis and specificity requirements of 10 _ C4 F.R.
62.714, and that the other criteria for contentions, as expressed in the Peach Bottom decision, not be violated.
See Philadelphia Electrl.: Co. (Peach Bottom Atomic Power Station, Units 2' and 3), ALAB-216, 8 AEC 13, 20 (1974). In this regard, the Staff notes that Hampton Contention IV(C) satisfies the basis and specificity regulrements, and nothing in Peach Bottom
)
would preclude the admission of this contention,
~,
agreement letters with individual members of the Teamster's Union are required" (Order ~of May 18,1987, at 19; emphasis added).
The Board correctly e5cludeo Hampton's assertion that individual lettera of agreement are necessary for tha Teamsters Union members, on the-grounds that
.N UREG-0654 requires letters of agreement for' organizations, and not for individual emergency response workerr,.
At the same time, the Board permitted other issues relating to the Teamsters Union agreement to continue to be litigated w; thin the scope of Revised Contention IV( A)(3). N Further, the Board 4 ruling that indiWdva.t l
letters of agreement 5re not necessary did noi dispose of Hampton's' general concern as to whether sufficient numbers of the. Teamsters members w!Il be available to perform their back-up role.
In this regard, FEMA recefitly expressed concerns similar to some of those raised by the Town of Hampton, EI which matters presumably will continte to be lit %ated.
Thus, Hampton's motCon hr reconsideration challenging the
. Board's lirsited determination to exclude from Revised Contention IV(A)(3)
-19/ The asserted need for individual letters of agreement with the Teamster's U~nion members constituted only one portion of Revised Contenilon IV(A)(3).
Other portions of this contention raised concerns as to whether the Teamsters members "are in fact adequately trained to drive the school buses and emergency vehicles for the mobility impa! red to properly effectuate an evacuation," and as to "how these backup drivers promptly will be notified and coordinated with available buses."
See " Memorandum on 10 CFR 62.714(a)(1) and Conttntions of theTown of Hampton to New Hampshire Radiological. Emergency Response Plan Revision 2," filed October 31,1986, at 19.
-20/ FEMA Position, at 15-16.
See also, " Affidavit of Edward A. Thomas In Opposition to Certain Motions for Summary Disposition," at 5, attached to "NRC Staff's Answer to Motions for Summary Disposit!on l
of Off-Site Emergency Planning Contentions," dated April 15, 1987.
n.
-l I
j the assertion that Individual, letters of agreement are required, should be L denied.
-)
5, Exclusion of Supplemental Desis for Contention Vill.
H.ampton seeks reconsideration of the Board's exclusion cf its supplemental basis for Contention Vill (Hampton at 8-9).
Hampt9n's
-)
supplemental basis for this contention had asserted that the State failed j
J to mcke adequate provisions for Yesidents of the Seacoast Health Center locateri in Hempton, NH. E1/
In determinirig to exclude this supplemental f
9 basis from ~ litigation, the Licensing Board identified two defects therein:
(a) the_ basis alleg'.ng absurdity of the State's assumption of how long it may take to load a certain number of elderly or infirm pereons on a bus is rot within the scope.of the contention, evet as reworded, and (b) the basis alleging reliance upon an unspecified
" technical assessment to order staff and resid)nts of the !!ome to shelter while the general populat!on evacuates is overly vague and does not. assert
- S specifically.what TOH seeks to litigates Order ot~ May 18,1987, at 27.
The first defect identifled by the Board doas not exist.
Revis~ed Cohtention Vill includes an assertion that NHRERP Pevision 2 " falls to i
demonstrate that adequate protective responses can be impicmented," and the Supplemental Basis specifh: ally challenges as ('absprd" the State's assumption that 40 residents of special facilities sueh as this ode "may be b5arded on an eveciaation bus, yvith personal bdongings, medica!
supp!!es.,.and ralated items, within 10 minutes. i.2I The Licensing Board i
-21/ See "Mem'oPandum on 10 CFR $2.714(a)(1) and CoFitentions of the Wwn of Hampton to New Hampshire Radiciagical Emergmey Response Plan Revision 2," deted October 31,1988, at 28-30.
J2/
Id., et 29.
m
U l. ' '
I i.
should reconsider its ruling as to this item and admit the identified issue
. for litigation.
c.
The second defect identified, by the Board concerns Hac,pton's reference to an " unspecified ' technical assessment' of the sheltering capabilites of the Scacoast Health Center,". upon which the State will rely in recommending a protective action response for the Lecoast Health 2,1/
The Board found the Supplemental ' Bas 8s ' fo this regard to Center.
be " overly vague" and that it failed.to " assert specifical!y what.
[Hampton] seeks to litigate" w!th resp 6ct to this " unspecified. technical as sess unt.
The" Staff notes that neither it nor the App!! cants objected to the admission of the Supplemental Basis on grounds of vagueness or lack of specificity, b Rather, Hampton challenged the State't, reliance upon a technical assessment, which Hampton charged the State had failed-to ideretify properly.
In other words, this basis ityn may be redd to acsert that NHRERP Revision 2 fa!!s to provide adequate information to support a future determination by the State to order sheltering for Seacoast Health Center residents and staff.
This presents an admissible issue, albeit one which might later have been ruled out by summary
. 23/
Id., at 29-30.
24/ See " Applicants' Answer' to Contentions of the Town of Hampton to FRw Hampshire Radiological Emergency Response Plan Revision 2,"
~~-
dated Novembe 14, - 1986, at 6-7 (opposing admission of the Supplemental Babis as an untimely expansion of Hampton's Contention Vlli); and "NRC Staff's Response to Town of Hampton's Memorandum on 10 CFR 52.714(a)(1) and Contentions on NHRERP Revision 2,"
date"J November 17, 1986, at 4-5 (supporting the revision of Contention Vlli, limited to the basc*, contained in the Supplemental Basis and other issues previously admitted by the Board).
l t
I disposition.
Accordingly, reconsideration should be granied as to this item.
CONCLUSION For the reasons set forth above, the Licensing Board should deny the Town of Amesbury's motion for reconsideration.
Further, however, the Board should grsnt the Town of Hampton's motion for reconsideration j
l oxcept as to its Contention IV(A)(3).
1 1
Respectfully submitted, 1
s hdAUIIL,
i
~
Sherwin E. Turk Senior Supervisory Trial Attorney Dated at Bethesda, Maryland th.is 15th day of June,1987 I
i
(
. _ - - _ _ - _ _ _ _ ~ - _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ - _ - _ _ _ - -
1 DOL KE T U MB UlllTED STATES OF AMERICA h
NUCLEAR REGULATORY COMMISSION
'87 JUN 17 P5 :47 l
BEFORE THE ATOMIC SAFETY AND LICENSING BOXhDL$l In the Matter of
)
)
Docket Nos. 50-443 OL PUDLIC SERVICE COMPANY OF
)
50-444 OL l
NEW HAMPSHIRE, et al.
)
Off-site Emergency Planning
)
(Seabrook Station, Unitt 1 and 2)
)
CERTIFICATE OF SERVICE l hereby certify that copies of "NRC STAFF'S RESPONSE TO MOTIONS FOR RECONSIDERATION FILED BY THE TOWN OF AMESDURY AND THE TOWN OF HAMPTON" in the above-captioned proceeding have been served on the fo!!owing by deposit in the United States mall, first class or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Corr, mission's internal mail systcm, this 13th day of June,1987.
i Helen Hoyt, Esq., Chairman
- Gustave A. Linenberger, Jr.*
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. Jerry Harbour
- Ms. Carol Sneider, Esq.
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuc! car Regulatory Commission One Ashburton Place,19th Floor Washington, DC 20555 Boston, MA 02108 l
Beverly Ho.llingworth Richard A. Hampe, Esq.
209 Winnacunnet Road New Hampshire Civil Defense Agency Hampton, blH 03842 107 Pleasant Street Concord, NH 03301 i
Sandra Gavutis, Chairman Calvin A. Canney, City Manager Board of Selectmen City Hall RFD 1 Box 1154 126 Daniel Street Ke isington, NH 03827 Portsmouth, NH 03801 q
l
l,
Stephen E; Merrill Paul McErchern, Esq.
i' Attorney General Matthew T. Brock, Esq.
George Dana B,isbee Sha;nes 6 McEachern ~
Assistant Attorney General 25 Maplewood Avenue Office of the Attnrney Cereral P.O. Boy 360 25 Capitol Street Portsmouth, NH 03801 Concorc', NH 03301 RobePta C. Pevear j
Angle Machiros, Chairman State Represents &ive Goard of Selectmen Town of Hampton Falls 25 High Road Drinkwater Rocd Newbury, MA 09150 Hampton Falls, NH 03844 Allen Lampert Mr. Robert J. Harrison Civil Defense Director President and Chief Executive Officer Town of Brentwood Public Service Co. of New Hampshire 20 FrankHn Street P.O. Box 330 E>,eter, NH 03833 Manchester, NH 03105 Charles P. Graham, Esq.
Robert A. Backus, Esq.
j McKay, Murphy and Graham Backus, Meyer 6 Solomon l
100 Main Street 116 Lowell Street j
Amesbury, MA 01913 Manchester, NH 03106 Diane Curran, Esq.
Philip Ahren, Esq.
Harmon & Weiss Assistant Attorney General 2001 S Street, NW Office of the Attorney General Suite 430 State House Station #6 i
Washington, DC 20009 Augusta, ME 04333 Edward A. Thomas Thomas G. Dignan Jr., Esq.
Federal Emergency Management Agency Ropes & Gray 442 J.W. McCormack (POCH) 225 Franklin Street Boston, MA 02109 Boston, MA 02110 H.J. Flynn, Esq.
William Armstrong Assistant General Counsel Civil Defense Director Federal Emergency Management Agency Town of Exeter 500 C Street, SW 10 Front Street Washington, DC 20472 Exeter, NH 03833 Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel
- Board
- U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission
)
Washington, DC 20555 Washington, DC 20555
{
L
. y Jane Doughty Docketing and Service Section*
Seacoast Anti-Pollu-tion League Office of the Secretary
,x..
5 MaFket Street U.S. Nuclear Regulatory Commission Portsmouth, N}l' 03801 Washington, DC 20555 Maynard L. Young, Chairman William S. Lord
. Board of Selectmen Board of Selectmen a
10 Central P0ad Town Hall Friend Street South Hampton,' NH 03287 Amesbury, MA 01913 Michael Santosuosso, Chairman Peter J. Matthews, Mayor -
Board of Selectmen City Hall South fiampton, NH 03287 Newburyport, MN 09150' f,4r.. Robert Carrigg, Chairman Judith H. Mirner, Esq.
. Bocrd of Selectmen Silvergl ate, Gertner, Baker Town Office Fine and Good Atlantic Avenue 88 Broad Street North Hampton, NH 03862 Boston, MA 02119 R. K. Gad til, Esq.
Mrs. Anne E. Goodman, Chairman Ropes & Gray Board of Selectmen 225 Franklin Street 13-15 Newmarket Road Boston, MN 02110 Durham, NH 03824 Gsry W. Hohes, Esq.
tionorable Gordon J. Humphrey Holmes & Ellis
< United States Senate
' 47 Winnacunnet Road 531 Hart Ser. ate Office Building Hampton, NH 03842 Washington, DC 20510 YG Sherwin E. Turk Senior Supervisory Trial Attorney L