ML20236A293

Forwards New First Page to Applicant Answer in Opposition to Commonwealth of Ma Atty General Motion to Compel Answers to Commonwealth of Ma Second Set of Interrogatories.Supporting Documentation & Certificate of Svc Encl

ML20236A293
Person / Time
Site:	Seabrook
Issue date:	11/30/1988
From:	Elleck K, Selleck K PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	Harbour J, Linenberger G, Smith I Atomic Safety and Licensing Board Panel
Shared Package
ML20236A265	List: ML20236A262 ML20236A269 ML20236A277 ML20236A287 ML20236A293
References
OL, NUDOCS 8903170037
Download: ML20236A293 (22)

Text

- - _ _ _ _ _ _ - .__ .

t ROPES & GRAY 225 FRANKLIN STREET BOSTON, MASSACHUSETTS O2110

,= ==oviosace  % s, %c :%

so asNNeov et.aza ' ' tsLam Nvwesa es so73 moess omav esN tcoi*s%Nsv.,4%,aa.s%+s enoviosNes e i casos fausco .se etn aas 7377 4 sin oza.reat g,+t :: 3

.43:3satsmoo -ein 423 ooos ans.~o ow o o ace:4 tsLECoe'em ' dogs $21 c910 2c2' eae 3Sco .

tggg;oe.go 202 626 3D61 November.30, 1988 FEDERAL EXPRESS i

Ivan Smith, Esq., Chairman Dr. Jerry Harbour Dr. L Gustave Linenberger, Jr.

Atomic Safety.and-Licensing Board U.S. . Nuclear-Regulatory Commission East' West' Towers Building 4350 East' West Highway _

'Bethesda, MD 20814

Dear Administrative Judges:

We enclose.a new first page to Applicants' Answer in; Opposition lto Massachusetts Attorney General's Motion to Compel 1 Answers to Mass AG's Second Set of Interrogatories, which was' filed on November 28, 1988. The new page indicates that the arguments in Applicants' Answer go to Mass AG's Motion to Compel Production of Documente as well as his motion to compel answers to interrogatories.

Very truly yours, I. e.. f  !

t ryn A. Selleck KAStac Enclosure cc: Parties on the Service List 8903170037 890306 3 PDR ADOCK 0500 0

f-

1

[iT W  !

l l, s \

l~

t UNITED STATES OF AMERICA j NUCLEAR REGULATORY COMMISSION l before the ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of ) -Docket Nos. 50-443-OL'

) 50-444-OL' PUBLIC SERVICE COMPANY )

OF NEW HAMPSHIRE, et al. ) (Off-site Emergency

)- Planning Issues)

(Seabrook Station, Units 1 and 2) )

)

APPLICANTS' ANSWER IN OPPOSITION TO MASSACHUSETTS ATTORNEY-GENERAL'S MOTION TO COMPEL ANSWERS TO MASS AG'S SECOND SET OF INTERROGATORIES AND MOTION TO COMPEL PRODUCTION OF DOCUMENTS On November 14, 1988, the Attorney General for the Commonwealth of Massachusetts (" Mass AG") filed

" Massachusetts Attorney General's Motion to Compel Answers by Applicants to Mass AG's Second Set of Interrogatories" (" Mass AG's Motion") and a motion to compel production of documents which contains essentially the same arguments. Mass AG's I motion requests the Board to order Applicants to provide further. answers according to certain Definitions and Instructions set forth in "[ Mass AG's] Second Set of Interrogatories to Applicants on the (SPMC]" (" Mass AG's Interrogatories"). Mass AG's Motion also seeks further answers to Interrogatories 9, 10, 14, 35, 98, 105, and 111.

Applicants respond as follows:

i

[ !. S i December 9, 1988

, BY TELEFAX Jeffrey P. Trout, Esq.

Ropes & Gray 225 Franklin. Street Boston, MA 02110

Dear Jeffrey:

'This letter summarizes the discussions we had on Monday, December 5, 1988, regarding outstanding discovery disputes. _

1. Massachusetts Attorney General's First Set of Interrogatories (October 7, 1988)

The Applicants will answer' interrogatories 4(d) and 6(a).

However, their response need only list the town in which the respective individuals. reside, rather than provide a complete residential address.

The Mass AG' withdraws his motion to compel regarding numbe.r

23. Pending a decision in the NHRERP proceeding, the Mass AG does not now seek a response to interrogatory 56(b).

The parties are not able to reach agreement regarding interrogatories 29, 30, and 55. As such, the Mass AG stands by his motion to. compel with respect to these three interrogatories.  !

EXHIB;T 7

-l 1

l 1

" 'i

2. Massachusetts Attorney General's Second n ' Set of Interrogatories (October 19, 1988). '

l Withirespect to' paragraph-A'of-the Definitions and jd Instructions, the Applicants 1have agreed to include in their i i

sanswers an acknowledgement that relevant-persons to whom.the-interrogatories.were addressed include " agents" of NHY, however that term may be defined.- Inl order to clarify any misunderstanding with respectLto paragraph F, the Mass AG has stated that this instruction'is to.be read in the context of' '

particular interrogatories and is not meant'as an unlimited request for all documents no longer in Applicants' possession.

The Mass AG' withdraws his motion to compel answers to 2 interrogatories 9'and.10. Pending a decision in the NHRERP proceeding, the Mass-AG does not now seek a response to interrogatory 35.

The Applicants will answer interrogatories 14 and 98 providing.the requested addresses by town.

The parties are not able to reach an agreement as to interrogatory 105. As such, the Mass AG does not withdraw his motion to compel with respect to this interrogatory.

3. Massachusetts Attorney General's First Reauest For Production of Documents (October 4, 1988) 4 Request 5 and 8 will be answered by the Applicants, sucject to the same understanding set forth above that the response need only list the address by town.

1 f

i 3

The Applicants.are in the process of determining whether documents responsive to request 16(h) have been produced yet. If such documents have not yet been produced, the Applicants will make such documents available. Applicants understand this request to seek correspondence and records of communication between NHY and/or ORO and the State of New Hampshire insofar as such documents concern any coordination of response effort between ORO J-and the State of New Hampshire.

Because the parties are not able to reach an agreement as to Requests 16(i) and 16(j), the Mass AG-stands by his motion to compel with respect to these requests.

4.

Aeolicants' Second Recuest For Production Of Documents (October 14, 1988)

The Mass AG has agreed to produce the documents requested by the Applicants subject to the understanding that in addition to documents dated after January 1, 1986, responsive documents from the Massachusetts Civil Defense Agency and the Governor's office will include those dated from January 1, 1984 to the present and will concern any emergency in the Seabrook EPZ. Mass AG and Applicants will continue the production of documents in the manner that they have employed to date. Disputes over claims of privilege will be resolved on a document-by-document basis.

5. Aeolicants' Recuest For Admissions to Mass AG (November 15, 1988)

Applicants will reword Request number one as follows:

It is the policy and position of the Commonwealth of Massachusetts to utilize fully every available resource, L

c , i L '

. .9

_.a 1

f public and private, to the extent allowed by the 1c.siof-Massachusetts, and to the extent necessary and/or, j appropriate, to respond to a radiological emergency.

As rewritten, the: Mass AG will admit Request number 1.

With respect to Request number 2, the parties are.in-agreement that a response to Interrogatory 89 of the Applicants' Interrogatories and Request For Production of Documents Concerning.

Contentions;1-26 (October ~11, 1988) will obviate the need to compel an answer to'this request.

Applicants.will reword Request number 7 as follows:

.The following events have occurred in the two zoning litigations concerning Applicants' use of the Haverhill staging Area:

a) in the first litigation, on or about April 7, 1988, Judge John T. Ronan entered the order attached hereto as Exhibit 1; b) subsequent to Judge Ronan's order, the Building Inspector of Haverhill. moved to dismiss his own complaint; and c) in the second litigation, on or about October 31, 1988, Judge John E. Fenton, Jr. entered the Interlocutory l Order attached-hereto as Exhibit 2.

As rewritten, the Mass AG will admit Request number 7.

Applicants will forthwith serve upon Mass AG a new pleading incorporating the two revised requests.

l

6. Annlicants' Recuest For Admissions to Intervanors (November 3, 1988)

The parties are in disagreement regarding Request number 6 ano, that being the case, the Applicants do not withdraw their motion to compel.

1

-s-

7. Aeolicants' Interrogatories and Recuest For l

Production of Documents Concerninc Contentions 1-26. j (October 11, 1986)

The Mass AG will answer Interrogatory 13 with the understanding that responsive documents are those dated or i a

generated after January 1, 1986.

Interrogatory 43 has already been answered by another Intervenor.

TPa lIces AG will answer Interrogatories 137, 142, 143, 144, 145, 152, IJ3 cnd 178 to the extent that knowledge is available.

If the information sought reflects the work of experts, the Mass AG will respond by treating the interrogatory as a request for the-facts and opinions of experts in accordance with Fed. R. Civ. P.

26 (b) (4) ( A) (i) .

The parties have agreed that production of MCDA radiological-emergency plans for Pilgrim, yankee Rowe and Vermont Yankee nuclear plants constitutes a responsive answer to interrogatories 141 and 151. *

8. &nglicants' Interrogatories and Reauest For Production of Documents Concernino Contentions 27-63 (October 14, 1988) l The following interrogatories will be answered by the Mass AG i

to the extent that such knowledge is available. If the information sought reflects the work of experts, the Mass AG will respond by treating the interrogatory as a request for the facts and opinions of experts in accordance with Fed. R. Civ. P.

26 (b) ( 4) ( A) (i) : 1, 2, 3, 6, */ , 8, 12, 14, 23, 25, 26, 29, 31, 32, l _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ -

50,'53,oS5, 67, 67, 70, 73, 79, 80,.84, 87, 89, 90, 92,_103, 104,.

105, 119,.121, 122, 131, 137,-139(d), 142, 143, 147, 148, 154, 162, 170, 175, 187, 264, 266, 267.

The. scope of Interrogatory 144 is state-wide rather than limited to EPZ specific hospitals. Documents reflecting a survey ~

of hospitals will constitute an answer to this interrogatory.

, It is agreed.that, for the following Interrogatories, production of the McDA radiological emergency response plans for 1 Pilgrim,. Yankee Rowe and Vermont Yankee nuclear power plants constitutes a responsive answer: 52, 54, 56, 60, 71, 76, 93,101, 112, 138, 149, 152, 153, 157, 168, 183, and 189.

The parties are not in agreement as to Interrogatory 225.and, that being the case, Applicants do not withdraw their motion to compel an answer.

Very truly yours, i

,f'p -

j f[I X" edohn Traficonte Assistant Attorney General Nuclear Safety-Unit s-Applicants agree that this letter accurately reflects the agreements reached by Mass AG and Applicants regarding the outstanding discovery disputes between them. Applicants further agree that the disputes noted above as being unresolved (a total of 8 out of 106) should now be submitted to the Board for

i w

i--..

g .. ; -

deci'sion,-with or without oral argument at the pleasure of the

-Board.

vn s f%'ir j7 deffrey P. Trout Counsel for Applicants f

2 I

1 I

I.

1-

I December 1#, 1988 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL

)

(Seabrook Station, Units 1 and 2) ) (Off-site Emergency

) Planning Issues)

)

MEMORANDUM (Memorializing Rulings of the Prehearing Conference on Discovery Matters Held December 13, 1988)

A Prehearing Conference was held at the request of Applicants and the Massachus&tts Attorney General (" Mass AG") .-

to address the unresolved dis overy diyputes summarized in J f

,y g k$s4& A6 ' toV M5LF Trafi enteh '.::= _ to effrey Trout dated December 9, b

1956 O

h)Dur ngua' thebeC h Nofh0M course thisd.

Conference, se 7 tak.* t.b s :,a ,, w w .1% y n W +gera,1 g '. % Aoral rulings were madeA At the request-of ther Board, Applicants herein memorialize these rulings./

1. Massachusetts Attorney General's First Set of Interrogatories (October 7, 1988)

Interrogatories 29 and 30 EXHIBIT 8

O

\

{b jxsmembo.nh .,

Applicants are ordered t produce the names of all separated employees who work d "for or on behalf of NHY/ORO as instructors and/or " "4 , responsibility for the training of personnel" at any time on or after September 1987.

Applicants, however, are not required to distinguish between those employees who were terminated and those who were 4 separated for other reasons. Mass AG may contact these S&,s , i i

employees but may not make any inquiries i m wasf relating Y to the circumstances of their rJparation from the NHY ORO. 4 Mass AG.may only inquire into their work as instructors for *E or on behalf of the NHY ORO. ,(s l s

Applicants are to write a letter to the individuals gs l involved, stating that Applicants are supplying Mass AG with Q.

their names pursuant to the Board's Order. The letter should La .

explain that the individuals are not required to talk with ,

s Mass AG and that Mass AG has been instructed not to discuss .

-6 withthemthecircumstancesoftheirtermination{

Interrogatory 55 Mass AG's motion to compel is denied.

2. Massachusetts Attorney General's Second Set of Interrogatories (October 19, 1988) (

Interrogatory 105 A er , 0 , ,) & $j *,- [ g .

TotheextentApplicantshavedocumentsthat) spqeposet rp protective actions based on particular dose reductions, Y ,s Applicants are ordered to identify those documents, The ,i y 911 .

f i jxsmembo.nh rJe>J 9eerd 4 :ined--that his ruling by no means should be taken to mean that such documents would be admissible in evidence.

3. Massachusetts Attorney General's First Request For Production of Documents (October 4, 1988)

Interrogatories 16(i) and (j)

Mass AG's motion to compel is denied. To the e,xtent w t ll Applicants have not already done so, Applicants aefreed--to supply Mass AG with a breakdown, by special needs type, of the number of special population individuals identified by Applicants.

4. Applicants' Second Request For Production of Documents (October 14, 1988)

No dispute.

5. Applicants' Request For Admissions to Mass AG (November 15, 1988)

No dispute.

l

6. Applicants' Request for Admissions to Interveners (Ngvember3, 1988) h, a,14 $ f 15. 5 AM .

Mass -A0 he t requiredeto ans e Requ sp pu er in ,

it present form.

f k^C$

h. .,.r WA New AG mu_ ,

7' dd:::: t.a ad;qu..cy wous I ak 'tJYV m em 'N Mf 49 t/A &

pf state and local m gency pl nnin e- up frerrt. -B F ftfT e '

.the h , Mass AG must present a definite- position on- this l  !.ssue. . ulation by the partiec may be- appropriate ~ Any.

.,such agreement should include a statement of the issues, pd/s a statefent of disagreement. h any- case,- a- eleer statamaa_t ,af, ::h L ..=ca131s-periti;r uildise required l

l before the hearing, possibly in the form of a trial brief.

g Wc cryi1 .h (P e

l l

jxsmembo.nh-

7. Applicants' Interrogatories and Request For Production of Documents Concerning Contentions 1-26 (October 11, 1986)

No dispute.

8. Applicants' Interrogatories and Request For Production of Documents Concerning Contentions 27-63 (October 14, 1988) /

Interrogatory 255 , /, ' iv' ' t ' ' '

Mass AG is ordered to respond to this interrogatory a3

's follows:

/,lgggwy g.gg C (1) If JI Contention 53 is withdrawn $ no further action

/'

is required.

GA (2) -If JI Contention 53 is not withdrawnf Mass AG must inquire of Frank-Ostrander, former Assistant Attorney General, as to whether he had any conversation (s) with the Mayor of Haverhill and, if so, the substance of those conversations. Based upon this inquiry and the inquiries of other Mass AG personnel which are represented to already have been made, Mass AG will respend to the interrogatory.

(3) The Board reserves the right to order further discovery on JI Contention 53.

g- r'

(

jg For Applicants: '

ut Jeffrey P. Trout Counsel for Applicsnts kor.MassAG:.

John Traficonte F Assistant Attorney General Nuclear Safety Unit ,

_4 I

}

l l

jxsmembo.nh order accordingly.

Date:

6

I

. X i. :T' 1988 December E d, DEC 20 Pl2 UNITED STATES OF AMERICA . . . . .

NUCLEAR ~ REGULATORY COMMISSION.

before the-ATOMIC SAFETY AND LICENSING BOARD C6ED DE DEC 2 0 E i

)

In the~ Matter of - )

)

PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. _

, ). 50-444-OL

)

(Seabrook Station, Units 1 and 2) ) (Off-site Emergency

) Planning Issues)

)

MEMORANDUM (Memorializing Rulings of the Prehearing Conference on Discovery Matters Held December 13, 1988)

A Prehearing Conference was held on December 13, 1988 at the request of Applicants ar.d tho' Attorney General for the Commonwealth of Massachusetts '(" Mass AG") to address the unresolved discovery disputes summarized in a letter frem Assistant Attorney General John Traficonte to Applicants' .g Counsel Jeffrey Trout, dated December 9, 1988. During the '

course of this' Conference, several oral rulings were made, which are summarized as follows:

-ci@rw g.

EXHIBIT 9

1. Massachusetts Attorney General's First Set of Interrogatories (October 7, 1988)

Interrogatories 29 and 30.

Applicants are ordered to' produce the names of all separated employees who worked "for or on behalf of NHY/ORO as' instructors and/or (had) responsibility for the training of personnel" at any time on or after September 1987.

Applicants, however, are not required to distinguish between i

those employees who were terminated and those who were separated for other reasons. Mass AG may contact these employees but may not.make any inquiries relating to the l

circumstances of their separation from the NNY ORO. Mass-AG may only inquire into their work as instructors for or on  !

behalf of the NHY ORO.

Applicants are to write a letter to the individuals involved, stating that Applicants are supplying Mass AG with their names pursuant to the. Board's Order. The letter should i

explain that the individuals, are not , required to talk with Mass AG and that Mass AG has been instructed not to discuss

. with them the circumstances of their termination, but that he is free to inquire into their work as instructors. .

Interrogatory 55 Mass AG's motion to compel is denied.

l 4

2.. Massachusetts Attorney General's Second Set of Interrogatories ~(October 19, 1988)

Interrogatory 105 To the-extent Applicants have documents that "compara the projected dose to the population in the event of an accident at Seabrook Station assuming'different protective-action recommendations were made and followed," Applicants are ordered to identify and describe those documents. This

~

ruling should not be taken to mean that such documents would '

be admissible in evidence. ,

. 3. Massachusetts Attorney General's First Request For Production of Documents (October 4, 1988)

Interrogatories 16(i) and (j) ,

Mass AG's motion to compel is denied. To the extent' Applicants have not already done so, Applicants have agreed to supply Mass AG with'a breakdown, by special needs type, of the number of special population individuals identified by Applicants. '

4. Applicants' second Request For Production of Documents (October 14,.1988) 6  !

No dispute. '

5. M icants' Request For Admissions to Mass AG (November i 15, 1988)

No dispute.

6. Applicants' Request for Admissions to Interveners.

(November 3, 1988) ,

Interveners are not required to answer Request Number 6 in its prer.ent form. However, a clear statement of the Commonwealth's position concerning the adequacy of state and i

local non-radiological emergency planning may be required before the hearing, possibly in the form of a trial brief. j

7. Applicants' Interrogatories and Request For' Production-of Documents Concerning Contentions 1-26 (October 11, 1986)

No dispute. .

8. Applicants' Interrogatories and Request For Production of Documents concerning Contentions 27-63-(October 14, 1988) 3 Interrogatory 255 t

Mass AG is ordered to respond to this interrogatory as follows:

(1) If JI Contention 53 is withdrawn or otherwise summarily disposed of, no further action is required.

(2) If JI Contention 53 i.s not wit.hdrawn or otherwise ,

summarily disposed of, Mass AG aust inquire of Frank ,

Ostr Q , former Assistant Attorney General, as to whether he ha conversation (s) with the Mayor of Haverhill and, if so, the substance of those conversations. Based upon this 9 inquiry and the inquiries of other Mass AG personnel which are represented to already have been made, Mass AG will respond to the interrogatory.

~4-

l (3) The Board reserves the right to order further discovery on JI Contention 53.

Order ccordingl cat.. sA,As l O

h

~

I l

l

}

e t

4 1

l l

1

OC(kE TE(:

UNITED STATES OF AMERICA h*f NUCLEAR REGULATORY COMMISSION

TOMIC SAFETY A11D LICENSING BOARD 7 P4

14 3efore the Administrative Judges: ':U lif "U

. 3, DOCHLi % r e ,yp Ivan W. Smith, Chairman E "#R Dr Richard F.. Cole Kenneth A. McCollom

)

In the Matter of ) Docket Mos. 50-443-OL

)- 50-444-OL PUBLIC SERVICE COMPANY ) (Off-Site EP)

OF NEW HAMPSHIRE, ET = AL. )

)

(Seabrook Station, Units 1 and 2) ) March 6, 1989

)

CERTIFICATE OF SERVICE I, John Traficonte, hereby certify that on March 6, 1989, I made service of the MASSACHUSETTS ATTORNEY GENERAL JAMES M.

SHANNON'S OPPOSITION TO APPLICANTS' MOTION FOR SANCTIONS AND CROSS-MOTION FOR PARTICULAR RELIEF with the accompanying Affidavits of John C.

1 Traficonte and Stephen C. Poitrast by first class mail or by Federal Express as indicated by [*], to:

• Ivan W. Smith, Chairman *Kenneth A. McCollom Atomic Safety & Licensing Board 1107 W. Knapp St.

U.S. Nuclear Regulatory Stillwater, OK 74075 Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814

• Dr. Richard F. Cole

• Docketing and Service Atomic Safaty & Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building Washington, DC 20555 4350 East West Highway Bethesda, MD 20814 l

r - - - _ _ _ _ - _ - _ - _A

- - ~~'

@ o. m 3.o -

n. .

lh ,

i 2' y  : H,

. .c :  : js7_(

> ji; ... j- '{-

( R o b e r t [ R L P i e r c e ,'J E s.q ." . -

• ThomaslG.=:Dignan, Jr.~,,Esq.

AtomicfSafety &LLi' censing Board _

~

Katheri~ne Sslleck , - Esq '.'

U.S. Nuclear)Regulatorp: Commissions lRopeSf &.. Gray' _ _

East West"Towersl8uildingL One~ International' Place

'4350 East:WestJHi'ghwayLe Boston,iMA _02110-

, 'Bethesda, MD;!20814. .

Sherwin?E., Turk, Esq.

~

. H .4Jos eph)Flynn , I Esq . .

. Assistant General 1 Counsel U.S.' Nuclear Regulatory ' '

?OfficebofiGeneral-. Counsel

, ' Commission x cFederal) Emergency < Management Office of1the~~GenerallCounsell Agencyc .

15th Floor" 5001C Street;-S.W.. . Il555:Rockville~ Pike" :23

' Washington, DC_ 20472 Rockville, MD-20852' Atomic Safety A~ Licensing ' Robert [A. B'ack us , ' Esq .:

L Appeal" Board' ,

Backus, Meyer'&t Solomo'n_ 60

!U;S. Nuclear? Regulatory ~

116 Lowell Street

Commission. P . O '. Box 5161 Washington',1DC7

20555- Manchester, NH 03106

' Jane Doughty _.

~

AtomicLSafety &JLicensing' Board ~

U.S.JNuclear. Regulatory Commission: Seacoast-Anti-Pollution 1 League-TWashingtonflDCJ 20555 '

.5 MarketiStreet l

'Portsmouth, NH '03801 -

Charles.P. Graham,.Esq..

Barbara St. And re , _ .Esq .

Murphy 1&' Graham Kopelman~& Paige, P.C..

33 LowLStreet 77_ Franklin: Street

?Newburyport,1 MAL 01950 Boston,1MA '02110 Judith H.fMizner, Esq. R.-Scott' Hill-Whilton,.Esq. q.

k }l~ , < .

v G_eorgeJDanalBisbee, Esq..  ; Phill'ip1Ahrens, . Esq.

AssistantlAttorney' General- Assistant.? Attorney General' Loffice-of1the' Attorney General Department of.the; Attorney 25 CapitolTStreet: General ~ -

.l'i s ,

Conco r d , -- NH 03301 Augusta,'iME y

04333:

Sandr a L Ga vu tis ,f. Chai rpe rsonl Calvin A.'Canney'

) Board of* Selectmen City / Manager -. :I RFD~1, Boxtll54 '. City Hall-

': Rte.r'107-l

'Kensington, NH- 03827.

126'. Daniel Street "y L.

Portsmouth, NH 03801- '

Gary W. Holmes, Esq.' 'RichardiA. Hampe,1 Esq. -

Holmes & Ellis. Hampei &'- McNichola s.

47 Winnacunnet Road 35-Pleasant Street Hampton, NH 03842' Concord,'NH' 03301

. Robert-Carrigg,-Chairman J.P.-'Nadeau

'B o a'r d ' o f. S e l e c t m e n Selectmen's Office Town Office 10 Central Road Atlantic Avenue ..

Rye, NH 03870-North Hampton,LNH '03862 .

. William S. Lord- James H. Carpenter, Alter'nate

Board of Selectmen. TechnicalTMember.

Town Hall - Frlend Street.

t-Amesbury, MA . Atomic Safety &-Licensing  !

01913 Board Panel  !

U.S. . Nuclear ' Regulatory Commission .

Washington,-lDC 20555~

' JAMES M. SHANNON ATTORNEY GENERAL-COMMONWEALTH OF MASSACHUSETTS

(.;- y j hn Trariconte Chief,. Nuclear Safety Unit ,;

Department of the Attorney General'

.dne Ashburton Place

" Bostor., MA. 02108-1698 (617) 727-2200 i

; DATED

.. March 6, 1989 1

s .

1 J n -- - --