ML20236A431
| ML20236A431 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/07/1989 |
| From: | Feigenbaum T, Selleck K PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | MASSACHUSETTS, COMMONWEALTH OF |
| References | |
| CON-#189-8259 OL, NUDOCS 8903170191 | |
| Download: ML20236A431 (19) | |
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'gg tg 13 P3 55 March 7, 1989 UNITED ST IS- OF l AMERICA eki.ht ~
NUCLEAR REGULATORY COMMISSION before the-ATOMIC SAFETY AND LICENSING BOARD I /
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In the Matter of )
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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL-NEW HAMPSHIRE, et al. ) 50-444-OL
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(Seabrook Station, Units 1 and 2)
)' (Off-site Emergency
, ) Planning' Issues)
)
APPLICANTS' SUPPLEMENTAL ANSWERS TO INTERVENERS' INTERROGATORIES REGARDING TRANSPORTATION RESOURCES Pursuant to 10 CRF 52.740(e), Applicants supplement
.their responses to "[ Mass AG's] Second Set of Interrogatories to Applicants on the [SPMC]", "[ Mass AG's] First Request for the Production of Documents to the Applicants Regarding the
[SPMC]" and "[TOA's] First Set of Interrogatories . . . to the Applicants on [SPMC]".
- 1. "[ Mass AG's] Second Set of Interrogatories to Applicants on the [SPMC)."
Applicants incorporate here their objections contained in their response to "[ Mass AG's] Second Set of Interrogatories to Applicants on the [SPMC]." Without 8903170291 8903o7 (DR ADOCK 05000443 PDR l
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I waiving the foregoing objections, Applicants further respond below.
Interroaatorv No. 13 Please list the name and address of each of the companies currently being relied upon by ORO to' supply buses and/or vans in the event of a radiological emergency at Seabrook Station, and for each company identify the number of buses and vans which:
(a) will always be immediately available-(with drivers) upon notification by ORO, even if buses have other scheduled assignments; (b) will be available'(with drivers) only after completing a transport job which the company has a prior commitment to driver:
(c) will be available (with drivers) under certain other conditions (please identify).
Acolicants' Resoonse In addition to the names and addresses previously provided, Applicants' state:
Holmes Transportation 22 Myrtle Street Norfolk, MA a) The terms are described in the Agreement, Attachment A hereto.
b) See (a) above.
c) Applicants know of no "certain other conditions."
Interrogatory No. 14 For each bus or van company listed in the prior interrogatory, list the names, addresses, and phone numbers of each driver who has agreed to drive a bus or van into the
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EPZ in the event of a radiological emergency at Seabrook.
For each such driver, list the ORO training courses each has w_-_---___-____-_____
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a t1 taken whether the driver passed the courses, and the dates these courses were taken.
Aeolicants Resoonse Applicants have no new information that is responsive to this request.
- 2. "[ Mass AG's] First Request for the Production of Documents to the Applicants Regarding the [SPMC)."
Applicants incorporate here their objections contained in their response to "[ Mass AG's] First Request for the Production of Documents to the Applicants Regarding the
[SPMC)." Without waiving the foregoing objections, Applicants further respond below.
Fecuest No. 3 Any and all documents reflecting or constituting communications since January 1, 1987, between NHY and outside potential or actual contractors or service providers, including but not limited to bus companies, ambulance companies, tow truck companies, hospitals, the American Red Cross, radio stations, and equipment vendors, for services or equipment needed to implement the SPMC, whether or not such contacts resulted in an agreement.
Aeolicants' Response In addition to the information previosly provided, Applicants provide the Agreement, Attachment A hereto.
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- 3. "[TOA's] First Set of Interrogatories . . . to the l Applicants on [SPMC)." l Applicants incorporate here their objections contained f
in their response to "[TOA's) First Set of Interrogatories
. . . to the Applicants on [SPMC)." Without waiving the foregoing objections, Applicants further respond below.
. t Interrocaterv No. 3-Identify and produce all amended, supplemental or
. additional' letters of agreement' relied upon by Applicants for-personnel, transportation, or other resources-to implement the JSPMC, and not previously served upon Interveners.
.Acolicants' Resoonse In addition to the information previosly provided, Applicants provide the' Agreement, Attachment A hereto.
Interrogatory No. 8 For all towns within the Massachusetts EPZ, including TOA, state.the total number of manned vehicles claimed available for actual use, in a severe, : fast-break emergency, to implement the SPMC: buses, ambulances, special needs vehicles, other vehicles. . Identify'and produce all documents,and. state every fact or opinion upon which you rely.
to support-this answer.
Aeolicants' Resoonse Consistent with NUREG-0654/ FEMA-REP-1, the planning basis is independent of specific accident sequences.
Therefore, the SPMC is not based specifically on a severe, fast break release or on any specific accident sequence; and the interrogatory e.s stated cannot be answered. Disregarding the reference to a " severe, fast break release," the Applicants' response is as follows:
The total numbers of manned vehicles under agreement are:
Buses 571 Ambulances 77 Ambulettes 7 Critical Care Units 2 Wheelchair Vans 93 Wheelchair Buses 1 Road Crews 18 Other Vehicles (station wagons, vans and half buses) 278 L - : .e n ,
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I' Agreements which form.the basis of the above.given-numbers are in. place with the1following companies:--
DATE SIGNED DATED-SIGNEDLBY' COMPANY BY NHY- 'OTHER PARTY' Big:W. Transportation,:Inc. 10/26/87 10/22/87 l Buckingham Bus: Company 10/02/67 08/26/87 Dee. Bus: Company 10/13/87 10/08/87 Fox Bus Lines, Inc. :10/08/87. 10/02/87 Marathon Line/Weybridge Bus: 10/21/87' 09/27/87 Parent Bus Services, Inc. 12/02/87 10/26/87 Park Transportation Co.,-'Inc.- .10/02/87- 09/23/87 Denise,:Inc. 01/02/87 09/30/87 Weagle Bus 1 Company 10/02/87 09/09/87
. Hudson Bus Company --
08/26/87 McGregor-S'mith. Bus Co. 08/26/87 08/20/87 Marlboro/ Hudson Ambulance 10/08/87 10/02/87-Cataldo Ambulance Service 10/02/87 09/23/87 General Ambulance Service 10/02/87 09/15/87 Stavis Ambulance 08/03/87 08/26/87 12/21/87 11/19/87 Rockingham Regional Ambulance 10/22/87 10/16/87 Dereks Ambulance Service 10/02/87 09/30/87 Baystate Ambulance and Hospital Rental Service 01/05/87 12/30/87 BEL Ambulance & Rescue 10/20/87 10/15/87 Medec Ambulance, Inc. 10/29/87 10/15/87
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l Coady's TowingL Service. 10/02/87' '08/24/87 I
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E Federal Auto Repair L10/02/87- 08/28/87. 1
-1 Front'Line' Ambulance 11/30/88 -11/30/88 ,l
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-Holmes Transportation 02/21/89' ~ 02/21/89..
Hampstead Garage- .02/07/89 02/07/89.
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As'to Answers:
h/hf$6 An Ted C. Feigenbaum Vice President,--Engineering, Licensing and Quality Programs l ,': New Hampshire' Yankee. Division'of.
Public: Service Company-of.New l Hampshire.
March.7, 1989-COMMONWEALTH OF MASSACHUSETTS:
Suffolk, ss
.Then appeared before me the above-subscribed Ted C.
Feigenbaum and made oath-that he is.the Vice President,.
Engineering, Licensing.and Quality Programs, of New Hampshire-Yankee Division, authorized to execute the foregoing responses:to-interrogatories on behalf of the Applicants' that he made inquii"f and believes that~the-foregoing answers accurately set forth-information as is available.to the Applicants.
Before.me,
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.My Commission Expires- c. 5/ M As to objections:
ThopsG. Dignan, Jr.
George H. Lewald Kathryn A. Selleck Ropes & Gray One International Place Boston, MA 02110 (617) 951-7000 Counsel for ADolicants
ATTACHMENT A TRANSPORTATION ACRFr.MF.NT CONTRACT NO. MenP-131 This Agreement made as of the day of )fF#N , 1989, by and between the Seabrook Joint Owners, comprised of several utility c6mpanies (as more particularly described in Exhibit A) by and throu5h their agent, New Hampshire Yankee, Division of Public Service company of New Hampshire, with its principal place of business at Seabrook, New Hampshire (" Company") and Holman Transeer_tatien, having its principal place of business at 22 Myrtle St. Norfolk MA 02036 (" Contractor").
WITNE!SETH: ,
SCOPE The Company hereby retains the Contractor to furnish the required manned vehicles as set forth in Schedule A which is attached hereto and forms a part hereof, for the Company's Offsite Emergency Response Plan for the Seabrook Nuclear Power Station. To support said plan, the contractor agrees, promptly after notification of a drill, exercise, or emergency, to make available all requisitioned vehicles and personnel for the Company's use, and will supply fusi, keys, certificates of registration, license places, tags, etc. , so that the vehicles can be placed in use promptly. All Vehicles supplied by the contracter will be in good operational condition and safe and fit for use, and any drivers thereof will be duly licensed as customarily required by the Contractor.
In consideration of the Contractor's agreement and consent as set forth above, the following shall govern all work and service to be furnished hereunder:
MANNED For the furnishing of manned vehicles for drille, exercises and VEHICLES emergencies, the Company will acknowledge receipt of vehicles at tha Company's dispatch point at the time of the requisition. The vehicles will return at the conclusion of their use to the company's dispatch point. A receipt and suryny form for any requisitioned vehicles shall be fillst out and completed by the Company and Contractor prior to vehicle furnishing and upon vehicle return.
The vehicles furnished shall be in good, safe, operational condition and will be utilized only in a reasonable manner under the circumstances. The vehicles will be returned in the same condition, rehsonable wear and tear excepted. Upon their return, all vehiciss shall be checked and inspected by representatives of both the Company and Contractor, noting deficiencies and damages, if any.
Claims for deficiencies and/or damages will not be considered beyond those noted at time of vehicle return. All vehicles will be fueled and completely checked prior ta caparture and refueled and completely checked upon return.
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Tne vehicles and drivers shall be utilised only in the same sanner and for the same pureposes as is performed in the Contractor's normal mode of business. Contractor's drivers shall have received taergency Preparedness Training prior te vehicle operation. This.
training shall be at the company's expense and at a mutually agreed upon time and place. If the contractor's drivers or attendants i.
cecupying the vehicles must have other medical, technical, or ,
d special skills, those skills will be described in schedule C attached herete and made a part of this Agreement.
VEHIC1.E The vehicles shall be furnished for a minimum lease period of four LZMITATION (4) hours.
ANNUA 1. The Company shall pay the Contractor annually for a five ($) year RETAINER period a retainer as set forth in Schedule A to reimburse the
. PRICE Contractor for its administrative costs involved in this agressent.
PRICE For use of all manned vehicles furnished hereunder the Company BASIS shall pay the contractor tho' service rates as sponified in Schedule 5 which is attached hereto and forms a part hereof.
For use of manned vehicles straight. time service rates will be based upon the normal work day, Monday through Friday. Overtise will consist of time worked in excess of the neraal workday or time worked on Saturdays, Sundays and Holidays. Holidays will be these customarily cbserved by the Contractor.
For taargency Preparedness Training, the Company shall pay the contractor the driver's hourly races, as set forth in Schedule B, which includes the base hourly rata, all contractus1 benefits and statutory costs, plus Contracter's administrative cost.
For refueling of vehicles, the Company shall pay the Contractor for fuel, invoiced at cost or alternatively may supply fuel for refueling wherever possible.
The service rates detailed herein are subject to adjustment, to reflect any increase resulting from any negotiated agreements reached with labor Unions representing Contraster's employees, any g e ral rate increase to Contractor's esployees, and any increase in statutory obligations. Contracter sust give Cowpsny immediate notice of all changes' in labor races. All increases are to bs supported and substantiated by documentation and calculation, and shall bosome effective on the date of such increase.
The service rates during the normal work day shall connence when thh requested manned vehicles are available and ready for service.
These rates will terminate at time of vehicle return and immediate checkout, subjoet to the minimum tease period. Ter requests beyond the normal work day or on Saturdays, sundays and/or Holidays, the service rates will commence at time of request and will terminate at time of vehicle return and immediate checkeut.
TERMS or Terms of Payment shall he in accordance with the followings PAYMENT
- 1) The Company shall pay Contractor's annual retainer price pro rata payments in advance on a quarterly basis, provided the contractor submits invoices for the following quarter not earlier than the 1st day of the 3rd month of each quarter, detailing the type and the total number of vehicles being made available to the company, the available vehicles under prior commitment, the available vehicles g,s under prior commitment. {
vehicle yard location, capacity, identification and plate numbers, and the names and social security numbers of the available drivers. Invoices shall be paid on a not thirty (30) day basis after receipt, review and acceptance of invoices.
- 2) The Company shall pay Contractor's vehicle and personnel service rates on a not thirty (30) day basis, provided invoices have been received which substantiate all service details, including, but not limited to, purpose, date, hours of use, vehicle location and identification number.
- 3) All invoices must be submitted to: Accounts Payable Dept..
P.O. Box 700, Seabrook, NH 03874 All invoices must reference the Contract Number.
COMMUNICATION At time of Contract execution, the Contractor shall make available SYSTEM to the Company a continuous, twenty four (24) hour celephone service for the purpose of contacting the contractor in the event of an emergency. This service shall consist of, but shall not be limited to, the telephone numbers and personnel to contact at the contractor's facility, and the names and home telephone numbers of at least three (3) of the Contractor's personnel who can respond to notification at the times the contractor's facility may be closed. In the event of any change in the contacts or telephone numbers, contractor shall immediately notify the company's Director of Energency Preparedness at Seabrook Station.
LESPONSE The company will advise Contractor approximately seventy two (72) 30TIFI. hours prior to requisition for training, drills and/or exercises ATICN and approximately fifteen (15) ainutes for an actual energency.
In the event of an actual emergency, the Contractor will determine and assign for the Company's inusediate use those vehicles committed to by contractor under this agreement. The contractor shall not be, penalized by retainer price reduction in the event the Company's reiguinttion coincides with the time when all vehicles are under Prior couaitaant provided the Cot < tractor has submitted the required vehicle data as set forth in the Terms of Fayment provision.
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8NDD0i!TI- During the period of the company's use of the vehicles or-CATION personnel or both, the Company shall be solely responsible, to the entent not covered by Contractors insurance, for all acts without fault, or negligent acts or omissions of Contractor or its .
Personnel,. and will defend, indennify and hold contractor harmless ;
from and against all loss, damage, bodily injury or death arising out of or in any way connected with the Contractors use wittsut ,
fault, or negligent use of the vehicles .during an alert, scendby i or state of emergency under the offsite Eastgency Response Plan for Seabrook Station. During the period of Company's use i.C et vehicles or personnel or both, the Company shall to solely -
responsible for all loss, damage, bodily injury or death ecused by a nuclear incident.
8NSLTANCE The Contractor shall provide Public 1.iabiYity and Automobile Liability insurance coverage in such am4unts as are normally required to operate its business, and which are acceptable to the Company. I'd * - ' in "---- r t-- d:11 ::;r:: it: in:r:: :: -._-- gf N-2: :d::i ?:in ~nr:, t 'm tri: tin:ri: Om 7, =d
'- y -- 1: - . ' - - 2_ P i:i- *C__ '. Centractor shall provide [
Workers compensation insurance with limits of liability in any state in which Contractor may be required to pay compensation related to performance hereunder. Contractor shall submit to the Cospany evidence of the above insurance coverage (certificate of insurance) ,
and provide for at least thirty (30) days written notice of -
cancellation thereof. For the purposes of this agreement, Contractor's insurance shall be considered primary insurance.
The Company shall provide, on a self insured basis, insurance coverage to the extent Contractor's insurance does not provide recovery of any losses incurred while contractor's vehicles are assigned for the company's use, including Contractor's deductibis amounts, if any, provided such losses have not been caused by intentional misuse or intentionally unlawful act. The company's insurance, for the purposes of this agreement, shall be considered excess insurance.
In addition, in the unlikely event of an actual energency, the company hereby agrees to maintain, for the entire period of use of the vehicles and personnel, insurance coverage in accordance with the requirements established in the Atomic Energy Act of 1954 (as amended). .
The Company and contractor hereby waive any ri5 ht of recovery against each other for loss or injury to property that is protected by insurance, to the extent that coverage is provided by such insurance.
W1 This agreement shall remain in effact for the five (5) year period commencing January 1,1989 and terminating at 12 o' clock sidnight December 31, 1993. Any extension of the aforementioned period shall be mutually agreed upon and shall be expressed in a writing duly signed by both parties.
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At any time after one (1) year after the effective date of this contract, the Company reserves the right to torsinate this Contract upon not lose than ninety (90) days prior written notice to the Contractor specifying the termination date. Should the termination ;
date not coincide with a retainer payment period, the payment shall-then be apportioned between the parties on a daily basis, pro. rata to the date of termination.
ASSIGNMENT The Contracter agrees that it shall not assign this Contract or CONTRACT any portion thereof to any person, partnership, company or corporation not satisfactory to the company, and shall not make such an assigniaent until the prior written permission of the Company has been received. Any such assignment shall be void if made without the Company's prior written permission.
GOVEPJi1NG This agreement shall be governed by the substantive laws of the 7AW State of New Hampshire and all disputes arising under this contract shall be tried in the courts of the State of New Hampshire or the Federal District Courts in New Hampshire.
IN WITNES5 WHERIOT, the pe.rties have signed this Agreement as of the day and year first abova written.
SEA 8R00K JOINT OWNERg By and Throu6h Their Agent New Hampshirs Yankee Division of Public Service company of New Hampshire Sys 8 l
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Holmes Transportation By: d>l T #e*"
Richard Holmes
Title:
Ald/d Y I
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Effective Dates m n. v 1. ione contract No. Mo m .131 __
Contractor Holman TransportaticM I
SCHEDULE A AMMUAL RETAINER FEER ,
. I TOTAL i MANNED VEHICLES CAPACITY ESTIMATE For provi /C@ Buses' 4 $ /fM8 / year / bus S>seS
[/ 98 Cb M 8O N, For provi /l2 Vens 9 $ /@ 8'O / year / van For providing 6$ / year /
For providing 8$ / year /
i Fcr providing 4$ / year /
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contractor No. MoltAP-131 I contractor Holman Transoortatier ; I l
SCHEDUIL_B RERYTCf RATES (To be used when contractor has no publishdd rate schedule)
A. VrnIcLEs Buscs t $ E 00 / Hour Vans t $. /Mour 9$ Har t8 Mour 3$ Hour B. PERSONNEL Drivers t $_ 7*'** / Hour straight Time Drivers e S So oo /Nour overtime (including time worked on saturday Sunday or Holiday)
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Contract No. Morne-1si contractor Melman Trananartation SCMEDULE C REQUIRED DRTVER SKILLS LIST (If none, so state for each category below)
A. MEDICAL ,
None
- 8. TECHNICAL None C. SPECIAL g NONE
EXHIBIT A QWNER AND CWNER'S REPRESENTATIVE This Agreement is bein (collectively the owner") gwhich entered are into by the severs participants under1 the utility companies Agreement fot l Joint ownership, Construction and operation of New Hampshire Nuclear Units, dated May 1,1973, as amended (the " Joint Ownership Agreement") . The rights, obligations, and liabilities of each such utility company with respect tc this Agreement shall be several, in the same proportion as its ownership chare (specified below), and shall be neither joint nor joint-and several.
Utility Ownarshin shara Public Service Company of NH 35.56942% ;
The United Illuminating co. 17.500004 j EUA Power Corp. . 12.13240% l Mass. Municipal Wholesale Electric Co. 11.59340%
Ncw England Power Co. 9.957664 ,
The connecticut Light & Power Co. 4.05985% ,
Canal Electric Co. 3.52317% ! ,
Mcntaup Electric Co. 2.89989% l {
NH Electric Co-operative, Inc. 2.17391% :
Versent Electric Generation & Transmission Co-operative, Inc. o.41259% ,
o.10034%
Tcunton Municipal Lighting Plant Hudson Light & Power Dept. - 0 077378 100.00000%
i Each such participant reserves the right, in connection with a ccuparable assignment of its interest under the Joint ownership Agreement, to assign its interest hereunder, in whole or in part, to any other entity which is or becomes a participant under the Joint ownership Agreement. Any changes in participants or proportions caused by said assignments shall automatically be deemed incorporated into this Agreement.
The owner hereby represents that it has delegated complete responsibility for management of this Agreement and of the Seabrook Project to New Hampshire Yankee Division of Public Service of New Hampshire, as owner's Representative and ayant. Until it receives wriG6 notier, to the contrary, the contracting party shall be entitled to deal only WAth the owner's Representative, except as may otherwise be specified with respect to billing and payments hereunder. Any notice or other communication given or furnished, .or any action taken, by the owner's Representative, making roterence to this Agreement and given, furnished or taken in accordance norewith, shall. be deemed to be notice given or communication furnished or action taken by the Owner. Notwithstanding the foregoing, the parties teknowledge that New Hampshire Yankee Electric Corporation will become the Dvner's Representative in the future and agree that no written notice to the
- entracting party is required when this occurs.
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!stM CERTIFICATE OF SERVICE L
__I, Kathryn A. Selleck, one of the attorneys foh9 yp t 13 P3 :55 Applicants herein, hereby certify that on Merch 7, 1989, I made service of the within document by depositing c_opies:
thereof with Federal Express, prepaid, for delivery 0ttoL '(;or,*J 4C where indicated, by depositing in the United States mail",'
first class postage paid, addressed to):
Administrative Judge Ivan W. Smith Robert Carrigg, Chairman Chairman, Atomic Safety and Board of Selectmen Licensing Board Town Office-U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton,.NH 03862 East West Towers Buildbs?
4350 East West Highway Bethesda, MD 20814 Administrative Judge Richard F. Cole Diane Curran, Esquire Atomic Safety and Licensing Board Andrea C. Ferster, Esquire U.S. Nuclear Regulatory. commission Harmon, Curran & Tousley East West Towers Building Suite 430 4350 East West Highway 2001 S Street, N.W.
Bethesda, MD 20814 Washington, DC 20009 Administrative Judge Kenneth A. John P. Arnold McCollom Attorney General 1107 West Knapp Street George Dana Bisbee Stillwater, OK 74075 Assistant Attorney General Office of the Attorney General 25 Capitol Street Concord, NH 03301-6397 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of General Counsel Board Panel Docket (2 copies) U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Tovers Building One White Flint North, 15th Fl.
4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852
- Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board . 116 Lowell Street U.S. Nuclear Regulatory P. O. Box 516 Commission Manchester, NH 03105 Washington, DC 20555
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> j Philip _Ahrens,'EsquireL 'Mr. J.;P. Nadeau.
E Assistant. Attorney General Selectmen 8s Office Department of'the Attorney flo-Central'Roadi General .
Rye,'NH 03870
- f. Augusta,'ME; 043331 d 4
, Paul McEachern,-Esquire: John Traficonte,< Esquire. .
'Shaines'& McEachern Assistant ~ Attorney:Generali 25'Maplewood: Avenue Department of the Attorney P.O.~ Box 360 General-
-Portsmouth, NH' 03801 One Ashburton Place, 19th-Fl.
. Boston, MA' 02108-
'Mrs. Sandra ~Gavutis ;Mr. Calvin A. Canney.
' Chairman,; Board of Selectmen. City Manager.
. RFD' 1 -- Box 1154 City Hall . .
g Route:107 126 Daniel' Street.
Kensington,'NH' 03827' Portsmouth, NH- 03801
- SenatorLGordon'J.-Humphrey R., Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Hill-Whilton'&'
Washington, DC 20510 .Rotondi
( Attn:: Tom Burack) '
79 State Street Newburyport,cMA '01950
- Senator.Gordon J. Humphrey Leonard Kopelman, Esquire One Eagle Square, Suite 507 Kopelman & Paige, P.C.
Concord, NH 03301 77 Franklin Street (Attn: Herb Boynton) Boston,.MA 02110:
Mr.1 Thomas F. Powers,'III Mr.~ William S. Lord.
Town Manager . Board of Selectmen Town of-Exeter . Town Hall'- Friend' Street-10 Front Street Amesbury, MA .01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Charles P.~ Graham, Esquire
. Office of General Counsel Murphy and Graham Federal Emergency Management 33 Low Street Agency Newburyport, MA 01950 500.C Street, S.W.
Washington, DC 20472 f
Gary W. Holmes, esc 7 ire Richard A. Hampe, Esquire Holmss & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03842 Concord, NH 03301 l'
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Mr. Richard R. : Donovan Judith-H. Mizner, Esquire ~
Federal Emergency Management- 79. State. Street, .2nd' Floor i Agency- Newburyporti MA 01950- :l Federal Regional _ Center 1 130 228th Street, S.W.
Bothell, Washington 98021-9796 Ashod N..Amirian, Esquire 145 South' Main-Street P.O. Box 38 Bradford,:MA 01835 Robert R. Pierce,_ Esquire Atomic' Safety and Licensing Board U.S. Nuclear Regulatory. Commission East' West Towers' Building 4350 East West Highway Bethesda, MD. 20814-James H. Carpenter, Alternate Technical Member-Atomic Safety.and Licensing Board U.S. Nuclear Regulatory Commission-East West Towers-Building 4350 East West Highway Bethesda, MD .20814 s
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KatyrynA.Selleck
(*= Ordinary U.S. First Class Mail)
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