ML20236A281
| ML20236A281 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/06/1989 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | NEW ENGLAND COALITION ON NUCLEAR POLLUTION, NRC OFFICE OF THE GENERAL COUNSEL (OGC), PUBLIC SERVICE CO. OF NEW HAMPSHIRE, SEACOAST ANTI-POLLUTION LEAGUE |
| References | |
| CON-#189-8229 CLI-88-10, CLI-89-03, CLI-89-3, OL-1, NUDOCS 8903170025 | |
| Download: ML20236A281 (17) | |
Text
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UNITED STATES OF AMERICA
.7,.L T NUCLEAR REGULATORY C0ft11SSION tF COMMISSIONERS:
'89 MR -6 P3 :04 Lando W. Zech, Jr., Chairman Thomas M. Roberts
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Kenneth M. Carr h A' ~
Kenneth C. Rogers James R. Curtiss rwa MAR -6 BB9 PUBLIC SERVICE COMPANY OF
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Docket Nos. 50-443-OL-1
)
50-444-OL-1 (Seabrook Station, Units 1 and 2 )
(Onsite Emergency Planning
)
and Safety Issues)
)
MEMORANDUM AND ORDER
- CLI-89-03 1.
Introductory Overview This memorandum and order responds to motions before the Comission seeking reconsideration of its December 21, 1988 decision on all then pending financial qualification and decommissioning cost matters in this proceeding, Public Service Company of New Hampshire (Seabrook Station, linits 1 and 2), CLI-88-10, 28 NRC __ (Slip op.).
In that decision the Comission did not accept Applicants' decommissioning funding plan as presented, but rather required that before low-power testing could be authorized Applicants fully fund a separate and segregated account with Applicants' Disbursing Agent in the sum of $72.1 million and provide specified additional guarantees to reasonably assure that funds will be available to safely decommission the reactor in the event that a full I
power license is not granted.
In light of this unprecedented and substantial requirement and the absence of any other financial issue with significant safety implications for low-power testing, the Commission further decided in CLI-88-10 not to exercise its discretion to grant the 8903170025 890306 PDR ADOCK 0500 So
requested rule waiver. Thus, no financial qualificat. ion review is currently available in this proceeding. On consideration of the views of the parties, the Commission continues to believe that its decision in CLI-88-10 is sound and comports fully with its responsibilities.
Accordingly, reconsideration is denied.
II. Background and Positions of the Parties A. Background In Public Service Company of New Hampshire, CLI-88-07, 28 NRC 271 (1988), the Comission recognized that the Interveners'I chief financial concern related to the ability to fund safe decommissioning after low power testing in the event full-power operation was not authorized.2 In this light, the Comission in CLI-88-10 established specific financial assurance requirements to provide reasonable assurance of the availability of decommissioning funding in the above circumstances hypothesized by Interveners.
It is evident that by establishing these requirements the Commission provided a level of assurance of availability of funding that equals or exceeds the level of assurance generally required by the decommissioning rule.
That rule, if it applied to the I The Attorney General of Massachusetts (MassAG), Seacoast Anti-Pollution League (SAPL), Town of Hampton (T0H), and New England Coalition on Nuclear Pollution (NECNP) are the Interveners that have moved for reconsideration. We refer to them collectively by that term in this memorandum.
The Commission has never considered-- let alone decided-- that a full power license cannot be issued for Seabrook at some time subsequent to low-power testing.
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)
3 circumstances of this case, would have been satisfied were Applicants to
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l have done no more b.efore receiving any operating license than establish a funding plan and begin periodic payments into an external account.4 B. Position of Interveners By motion of December 27, 1988, MassAG raises two " problems" with 5
CLI-88-10, which SAPL and NECNP adopt by joint motion of January 5, 1989. With respect to the certified rule waiver petition, Interveners find a violation of due process in the Commission's basing its decision on the absence of a significant safety question because the parties were 1
allegedly unaware of that "criterinn". On the decommissioning decision, MassAG complains that the Comission erred in resolving the decommissioning funding natter on the basis of the record. This 3The Commission held in CLI-88-07 that the decommissioning rule did not directly apply to the decommissioning requirements necessary in the circumstances hypothesized by Interveners-4.e., end of plant life after low-power testing.
4The first required payment need not have exceeded $3 million on an annual basis.
See 10 C.F.R. 96 50.75(c)(1)(1) and (e)(1)(ii).
50n February 1, 1989 MassAG filed an additional document denominated
" Reply of the Massachusetts Attorney General to the Responses of the Applicants and Staff to the MassAG's Motion for Reconsideration of CLI-88-10." The regulations provide no automatic right for such a reply, j
and leave has not been sought. To date in the interest of a complete record, the Conunission has accepted all of the pleadings lodged with it by parties and amicus save one which was specifically excluded by CLI-88-10. See Slip op, at 34. However, the parties are abusing the Commission's tolerance by failing to put in initial pleadings all the arguments then available to them.
On threshold review, MassAG's reply l
appears in substantial measure to present such a case.
The matters discussed for the most part not only could have been raised in the original motion for reconsideration, but should have been raised at the time of filing contentions in opposition to Applicants' decommissioning plan. Accordingly, we reject MassAG's " Reply" and counsel the parties to (Footnote Continued) 3
o s
1 complaint focused almost entirely on the alleged error in deciding on the fuel storage costs that would be likely to be involved.in decommissioning.
Seabrook in ' light of allegedly conflicting evidence on the record from Applicants' own expert.6 SAPL, T0H,'and NECNP not only embrace this argument but enlarge it with a broad claim that the procedure followed by' the Commission was insufficient under Section 189a of the Atomic Energy-Act, as'well as under Constitutional requirements for due process.
For support they relied on an alleged lack of notice that the Commission i
l would decide the decommissioning questions on the existing record and without a full-fledged trial of the issues preceded by adequate' discovery and time for preparation.
C. Position of Applicants and Staff On the financial qualifications waiver, Applicants argue that Interveners have not shown that the Comission erred in not finding safety significance in the matter. This being the case, they assert, due process does not require a hearing.
Regarding complaints of violation of Section 189a hearing rights, Applicants make two points:
first, that the matter before the Comission was whether to suspend its rules, a matter of broad discretion, and secondly, that the Comission was operating in the realm of financial qualifications and reasonable assurance of funding (FootnoteContinued) observe more carefully the procedures set forth in 10 C.F.R. Part 2 Subpart G.
OMassAG noted that its motion filed on December 28 was not intended to raise all its concerns given the "potentially immediate impact of CLI-88-10". MassAG's motion at 2 n.1. MassAG did not seek to file any supplementary basis at least until February 1,1989.
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F.
V...
where it has been judicially recognized that the Commission has broad discretion on financial qualifications and "cannot be 'second guess [ed]'
. as to the level of proof the reasonable assurance requires."7 With respect to the cost estimate alleged to conflict with that employed by the Commission, Applicants explain that the scope of the two estimates was not substantially the same.
Applicants say that its earlier cost estimate included costs that were extraneous to the Commission's current inquiry or were otherwise included under separate headinos.
The Staff sees no error in the Comission's exercise'of its discretion not to grant a waiver petition that had been certified to it.
Staff essentially supports Applicants' view of the fuel cost
" discrepancy" and in addition, proffers an affidavit to show that the estimate adopted by the Commission compares favorably with the storage costs incurred in decommissioning other facilities.8 Finally, the staff esserts that the Commission offered the opportunity for a hearing, but no hearing was thereafter reauired given the circumstances.
Staff enumerates the aspects presented by Interveners' contentions and argues that on some Interveners prevailed and on the others they lost as a matter of law or for failure to meet their burden under Commission rules so that none remained to be litigated.
7Applicants Answer to NECNP et. al's Motion for Reconsideration at 3, January 13, 1989, quoting New Enoland Coalition on Nuclear Pollution
- v. NRC, 582 F.2d 87, 93 (1st Cir. 1978).
8The Commission has decided not to accept this affidavit or any affidavit or evidence presented on reconsideration. Reconsideration will be on the basis of the record before the Commission at the time it reached its decision in CLI-88-10.
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'III. Comission Decision A.
Interveners feign surprise that the Comission should care whether there is any safety significance in waiving a rule and complain that they were unaware that they should present this factor in their pleadings.
Their argument is unpersuasive.
It has long been Comission law that a rule waiver would be granted "... 'only in unusual and compelling circumstances.'" Public Service Company of New Hampshire, ALAB-895, 28 NRC 7, 16 (1988) quoting Northern States Power Co., (Monticello Nuclear Generating Plant, Unit 1) CLI-72-31, 5 AEC 25,26 (1972) (Emphasis provided).
Implicit in the " compelling circumstances" standard in an,
agency whose mission is to ensure the public health and safety is that to l
qualify for consideration, a rule waiver petition would need to show that the safety matter at issue, if not " compelling", was at least "significant." Moreover, it has been no secret that the Comission's interest in financial qualifications is focused on any possible relationship to safety. Therefore, absent a showing of safety significance the Comission should have been expected to deny the rule waiver petition.
Interveners appeared to have recognized this because their own petitions to the Commission emphasized the safety importance of not allowing Seabrook to go to low power without the assurance of the availability of funds for safe decommissioning.
In any event, the i
parties did not present any contrary argument on safety significance in their motions for reconsideration. Hence the Commission maintains the view that, hav br provided for decommissioning funding, a rule waiver was not necessary ta address a significant safety problem on its merits.
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B.
When CLI-88-07 invoked'both the reopening requirements and the standards for a late-filed contention, Interveners must have been on notice that they should make an evidentiary case when they presented their contentions and that Applicants' prima facie case would prevail absent evidence to the contrary.
In many areas Applicants and Staff presented the only evidence on point.
In other areas--for example, the contingency factor--the Commission agreed with Interveners' position and Interveners therefore are not prejudiced by the decision procedure.
In still other areas--for example, scope of the decommissioning plan--CLI-88-10 resolved purely legal or policy issues for which no evidentiary hearing is required by law.
This responds to Interveners' general claims of denial of hearing rights and due process.
Interveners' specific claim that the Comission denied them their hearing rights in establishing the amount for spent i
fuel storage costs is also unfounded. The claim here is that MassAG presented on the record conflicting figures, which had been prepared by p
Applicants, of at least $700,000 per month for spent fuel costs, and thus the Commission failed to try a genuine issue of fact. The claim fails for several reasons.
First, parties must clearly identify evidence on which they rely. MassAG tells us that he put the contradictory figures in evidence. Yet nowhere in MassAG's contention or basis on the decommissioning funding plan or in the late-filed contention on financial qualifications, where these figures are reportedly referenced, is there a specific reference to developed figures on spent fuel storage costs.
Certainly, MassAG's own expert offered no figure. Nor is there any statement that would have pointed us clearly in the direction that the MassAG would now have us follow. MassAG now relies on certain 1
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introductory language in papers filed with the Commission in response to CLI-88-07 that "[a]11 of the facts and assertions contained in [his]
petition under 10 C.F.R. 2.758" are " incorporated by reference."9 It is notable that the MassAG's 2.758 petition, as multiply supplemented and.
amended, is a sizable document. Commission practice is clear that a petitioner may not simply incorporate massive documents by reference as the basis for or a statement of his contentions. Tennessee Valley Authority (Browns Ferry Nuclear Plant, Units 1 and 2), LBP-76-10, 3 NRC 209,216 (1976). Such a wholesale incorporation by reference does not serve the purposes of a pleading.
See Commonwealth Edison Company, (Braidwood Nuclear Power Station, Units 1 and 2) 21 NRC 1732.1741 (1985),
rev'd and remanded on other grounds, CLI-86-8, 23 NRC 241 (1986). The Commission expects parties to bear their burden and to clearly identify the matters on which they intend to rely with reference to a specific point. The Commission cannot be faulted for not having searched for a needle that may be in a haystack.
Even were Applicants to have fairly presented contradictory figures for the same element, MassAG could not have relied on the earlier figure without independent corroborating evidence.
Commission law is clear that where a contention is based on a factual underpinning in a document which has been essentially repudiated by the source of that document, the contention may be dismissed unless the intervenor offers another independent source.
Georgia Power Co. (Vogtle Electric Generating Plant, 9See Motion of Massachusetts Attorney General James M. Shannon to Reopen the Record to Consider Evidence Concerning the Joint Applicants' Financial Qualifications to Operate the Seabrook Nuclear Power Station (Footnote Continued) 8
[
l Units 1 and 2) ALAB-872, 26 NRC 127,136 (1987). This is all the more 1
true where, as here, both of the allegedly inconsistent positions were available to Interveners prior to their being required to file their contentions and evidence. At the very least Interveners might have attempted to explain why one particular estimate was the better one.
Finally, the figures relied on by MassAG do not squarely challenge those included in the Commission's determination. The Applicants correctly detail that the $110,000 costs the Commission derived from 1
Table 2 of Section 3 of the Applicants plan in Response to NRC Order CLI-88-07 were solely for costs associated with storing fuel onsite after completion of decontamination and removal of the reactor vessel and associated equipment.
The costs of decommissioning and decontamination, contingency and the like were included as separate items unlike the earlier figures, preferred by MassAG, which were prepared to answer a different question and thus had a different scope.
C.
NECNP, SAPL, and TOH on reconsideration complain that the specifications of the guaranteed prefunded account demanded by the Commission are insufficient. A motion for reconsideration cannot open the door for a new contention. Only SAPL earlier addressed the institutional arrangements for fundino, and SAPL conceded that "if the costs reasonably to be needed are appropriately estimated and prefunded" l
by Applicants, that would be sufficient.
SAPL did not then state any i
l (FootnoteContinued) and to Admit the Attached Late-Filed Contentions Concernina Said l
Financial Qualifications, Attachment 1 (Contention 1).
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q method that must b'e followed to establish 'a prefunded account.10 Thus, SAPL cannot be heard now.to complain that the Comission will; accept a prefunded separate and segregated account so long as it is fully
guaranteed by two financially healthy utility-guarantors. Such an account, although not externally held, is appropriate in these special circumstances and gives SAPL. essentially what it requested.
IV. Conclusion For the foregoing reasons, the Commission adheres to the views it expressed in CLI-88-10.II It is so ORDERED.
Cp F
the Commis on12 3m 0
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V SAMUEL J ILK o
Secretary of e Comission Dated at'l%ek961e, Maryland f
this C?
day of March, 1989.
10!n this context it is of interest that MassAG sought use of the rule to establish the sum to be assured.
That sum MassAG computed to be
$75.484 million, and by happenstance that sum was not significantly different from the amount required by the Comission.
See MassAG James M. Shannon's Late Filed Contentions, Corrected Attachment 1 at 3, November 9,1988.
It is true that MassAG also sought to add costs.
i related' to spent fuel disposal, but were the MassAG correct that the decommissioning rule was applicable to the response to our CLI-88-07 I
order, spent fuel costs would have been by rule excluded.
IIThe terms of this order dispose of all pending motions before the Comission itself on the rule waiver and decommissioning issues.
12Commissioner Roberts was not present for the affirmation of this order, if he had been present he would have approved it.
10 i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of I
I PUBLIC SERVICE COMPANY OF NEW l
Docket No.(s) 50-443/444-OL-1 HAMPSHIRE, ET AL.
1 (Seabrook Station, Units 1 and 2) l I
I CERTIFICATE OF SERVICE I hersby certif y that copies of the f oregoing HEMD. AND ORDER DATED 3/6/89 have been served upon the following persons by U.S. mail, first class, except as otherwise noted and in accordance with the requirements of 10 CFR Sec. 2.712.
Administrative Judge Administrative Judas Alan S. Rosenthal, Chairman Thomas S. Moore Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Administrative Judge Howard A. Wilber Administrative Judge Atomic Safety and Licensing Appeal Peter B. Bloch, Chairman Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Administrative Judge Administrative Law Judge Jerry Harbour Ivan W. Smith 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 Administrative Judge Edwin J. Reis, Esc.
Emmeth A. Luebke Office of the General Counsel 5500 Friendship Boulevard, Apt. 1923N U.S. Nuclear Regulatory Commission Chevy Chase, MD 20815 Washington, DC 20555 Diane Curran Esa.
Thomas G. Dignan, Jr., Esc.
Harmon, Curran & Tousley Ropes & Gray 2001 S Street, N.W., Suite 430 One International Place Washington, DC 20009 Boston, MA 02110
Docket No.(s)50-443/444-OL-1
.NEMO. AND ORDER DATED 3/6/89 Robert A. Backus. Esc.
Paul McEachern Esc.
Backus, Meyer & Solomon Shatnes & McEachern 116 Lowell Street 25 Maplewood Avenue. P.O. Box 360 Manchester, NH 03106 Portsmouth, NH 03801 Gary W. Holmes, Esc.
Charles P. Braham, Esq.
Holmes & Ells McKay, Murphy and Graham 47 Winnacunnet Road 100 Main Street Hampton, NH 03842 Amesbury, MA 01913 Barton Z. Cowan, Eso.
Jane Doughty Eckert, Seamans, Charin & Mellott Seacoast Anti-Pollution League 600 Grant Street. 42 Floor 5 Market Street Pittsburgh, PA 15219 Portsmouth, NH 03801 George W. Watson Esc.
Edward A. Thomas Federal Emergency Management Agency Federal Emergency Management Agency 500 C Street, S.W.
442 J.W. McCormack (POCH) l
. Washington, DC 20472 Boston, MA 02109 George D. Bisbee, Esq.
Suzanne Breiseth Assistant Attorney General Board of Selectmen Office of the Attorney General Town of Hampton Falls 25 Capitol Street Drinkwater Road Concord, NH 03301 Hampton Falls, NH 03044 Carol S. Sneider, Esq.
Matthew T. Brock, Esq.
Assistant Attorney General Assistant Attorney Beneral l
Office of the Attorney General Office of the Attorney General l
One Ashburton Place, 19th Floor One Ashburton Place, 19th Floor Boston, MA 02108 Boston, MA 02108 The Honorable Philip Ahrens, Esq.
Edward J. Markey, Chairman Assistant Attorney General ATTN Linda Correia Office of the Attorney General Subcommittee on Energy Conservation and State House Station. #6 Power Augusta, ME 04333 House Committee on Energy and Commerce Washington, DC 20515 l
I
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A.
Docket No.(s)50-443/444-OL-1 MEMD. AND ORDER DATED 3/6/89 Richard A. Hampe, Esq.
J. P. Nadeau Hampe & McNicholas Board of Selectmen 35 Pleasant Street 10 Central Street Concord, NH 03301 Rye, NH 03870 Allen Lampert William Armstrong Civil Defense Director Civil Defense Director Town of Brentwood Town of Exeter 20 Franklin Street 10 Front Street Exeter, NH 03833 Exeter, NH 03833 Sandra Gavutis, Chairman Calvin A. Canney Board of Selectmen City Manag r RFD #1 Box 1154-City Hall Kensington, NH 03827
-126 Daniel Street Portsmouth, NH 03801 Anne Goodman, Chairman l
Board of Selectmen Board of Selectmen I
13-15 Newmarket Road Town Hall - Friend Street Durham, NH 03824 Aresbury, MA 01913 Peter J. Matthews Mayor of Newburyport Michael Santosuosso, Chairman l
City Hall Board of Selectmen l
Newburyport, MA 01950 South Hampton, NH 03827 R. Scott Hill-Whilton, Esquire Stanley W. Knowles, Chairman Lagoulis, Hill-Whilton & McGuire Board of Selectmen l
79 State Street P.O. Box 710 i
Newburyport,, MA 01950 North Hampton, NH 03862 1
I L
The honoracle l
Gordon J. Humphrey ATTN Janet Colt United States Senate Washington, DC 20510 l
J l
Dated at Rockville, Md. this l
6 day of March 1989 l
Office of the retary of the Commission i
I
j
,=
i UNITED STATES OF AMERICA l
NUCLEAR REGULATORY COMMISSION f
In the Matter of i
I PUBLIC SERVICE COMPANY OF NEW I
Docket No.(s) 50-443/444-OL-1 HAMPSHIRE. ET AL.
I (Seabrook Station, Units 1 and 2) l I
I CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing COMM MEMO & ORDER (CLI-89-03) have been served upnn the following persons by U.S. mail, first class, except as otherwise noted and in accordance with the requirements of 10 CFR Sec. 2.712.
Administrative' Judge Administrative Judge Alan S. Rosenthal, Chairman Thomas S. Moore Atomic Safety and Licensing Appeal Atomic Safety and Licensino Appeal l
Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Administrative Judge Howard A. Wilber Administrative Judge Atomic Safety and Licensing Appeal Peter B. Bloch, Chairman Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Administrative Judge Administrative Law Judge Jerry Harbour Ivan W. Smith 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 Administrative Judge Edwin J. Reis, Esq.
Emmeth A. Luebke Office of the General Counsel 5500 Friendship Boulevard, Apt. 1923N U.S. Nuclear Regulatory Commission Chevy Chase, MD 20815 Washington, DC 20555 Diane Curran, Esq.
Thomas 6. Dignan, Jr., Esc.
Harmon. Curran k Tousley Ropes & Gray 2001 S Street, N.W., Suite 430 One International Place l
Washington, DC 20009 Boston, MA 02110 l
________-_____-___---___-___-__--_w
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Docket No.(s)50-443/444-OL-1 COMM MEMD k ORDER (CLI-89-03)
Robert A. Backus. Esq.
Paul
'McEachern Esc.
Backus, Meyer-& Solomon Shaines t-McEachern 116 Lowell Street 25 Maplewood Avenue, P.O. Box 360 Manchester, NH 03106 Portsmouth, NH 03801
')
Bary W. Holmes, Esa.
Charles P. Graham, Esc.
Holmes & Ells McKay, Murphy and Graham 47 Winnacunnet Road 100 Main Street Hampton, NH 03B42 Amesbury, MA 01913 Barton Z. Cowan, Esc.
Jane Douchty Eckert Seamans, Charin & Mellott Seacoast Anti-Pollution League 600 Grant Street, 42 Floor 5 Market Street Pittsburgh, PA 15219 Portsmouth, NH 03801 George W. Watson, Esa.
Edward A. Thomas Federal Emergency Management Agency Federal Emergency Hansassent Agency 500 C Street, S.W.
442 J.W. McCormack (PDCH)
Washington, DC 20472 Boston, MA 02109 George D. Bisbee, Esc.
Paul A. Fritzsche, Esc.
Assistant Attorney General Office of the Public Advocate Office of the Attorney General State House Station 112 25 Capitol Street Augusta, ME 04333 Concord, NH 03301 Suzanne Breiseth Carol S. Sneider, Esc.
Board of Selectmen Assistant Attorney General Town of Hampton Falls Office of the Attorney General Drinkwater Road One Ashburton Place, 19th Floor Hampton Falls, NH 03844 Boston, MA 02108 Matthew T. Brock, Esq.
Philip Ahrens. Esc.
Assistant Attorney General Assistant Attorney General Office of the Attorney General Office of the Attorney General One Ashburton Place, 19th Floor State House Station, #6 Boston, MA 02100 Augusta, ME 04333
I r'
.s Docket No.(s)S0-443/444-OL-1 COMM MEMO & ORDER (CLI-89-03)
The Hencrable-Edward J. Markey, Chairman Richard A. Hampe. Esc.
l ATTN Linda Correia Hampe & McNicholas Subcommittee on Enercy Conservation and 35 Pleasant Street Power Concord, NH 03301 House Committee on Eneroy and Commerce
)
Washington, DC 20515 j
l J. P. Nadeau Allen Lampert i
Board of Selectmen Civil Defense Director 10 Central Street Town of Brentwood 3
Rye, NH 03870 20 Franklin Street Exeter, NH 03833 William Armstrong Sandra Gavutts. Chairman Civil Defense Director Board of Selectmen Town of Exeter RFD #1 Box 1154 10 Front Street Kensington, NH 03027 Exeter, NH 03833 Calvin A. Canney Anne Boodman, Chairman l
City Manager Board of Selectmen I
City Hall 13-15 Newmarket Road 126 Daniel Street Durham, NH 03824 Portsmouth, NH 03801 Peter J. Matthews Board of Selectmen Mayor of Newburyport Town Hall - Friend Street City Hall Amesbury, MA 01913 Newburyport, MA 01950 R. Scott Hill-Whilton, Esquire Michael Santosuesso, Chairman Lagoulis, Hill-Whilton & McGuire Board of Selectmen 79 State Street South Hampton, NH 03827 Newburyport,, MA 01950 l
Stanley W. Knowles, Chairman Board of Selectmen Beverly Hollingworth P.O. Box 710 209 Winnacunnet Road North Hamoton, NH 03862 Hampton, NH 03B42
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. Docket No.(s)50-443/444-OL-1
-COMM MEMO & ORDER (CL1-89-03) i The Honorable The Honorable Gordon J. Huaphrey Nicholas-
.Marvoules ATTN Janet Coit ATTNs Michael'Greenstein United States Senate 70 Washington-Street Washington, DC 20510 Sales, MA 01970 Dated at Rockville, Md. this
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Off ce of the Secretary of the Ccamission
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