ML20236D331
| ML20236D331 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/13/1989 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20236D334 | List: |
| References | |
| CON-#189-8285 CLI-88-10, OL-1, NUDOCS 8903230058 | |
| Download: ML20236D331 (21) | |
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March 13, 1989 l
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'89 HAR 14 P'3 :43 I
UNITED STATES OF AMERICA
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before the OP '.
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i NUCLEAR REGULATORY COMMISSION
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In the Matter of
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PUBLIC SERVICE COMPANY
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Docket Nos. 50-443'-OL-1 OF NEW HAMPSHIRE, 3.t al.
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50-444-OL-1
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(Seabrook Station, Units 1
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(Onsite Emergency and 2)
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Planning and Safety
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Issues)
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APPLICANTS' RESPONSE TO WSECOND MOTION FOR' RECONSIDERATION OF CLI-88-10" BACKGRoDHD Under date of March 3, 1989, the Attorney General of The Commonwealth of Masseahusetts (MAG) has filed another Motion for Reconsideration of the Commission's decision of December 21, 1988, in this proceeding.1 This motion is denominated "Second Motion for Reconsideration" (" Motion")
l and seeks reconsideration of CLI-88-10 as a result of certain i
events which have occurred in the area of low-level wasta l
l 1
Public Service Cn=aany of New Mannshire (Seabrook l
Station, Units 1 and 2), CLI-88-10, 28 NRC f
(Dec. 21, 1988), hereafter referred to as "CLI l l
10" and cited to the slip opinion.
l l
l 8903230058 890313 1
PDR ADOCK 05000443 0
PDR a
1 disposal since issuance of CLI-88-10.
The gravamen of the Motion is to be found in three attachments thereto.
These attachments are (1) an order of the Board of Health and Environmental Control of the State of South Carolina issued February 2, 1989, and purporting to deny access to the Barnwell, South Carolina, low-level waste disposal facility to all generators of low-level waste in the States of Vermont and New Hampshire; (2) a letter of December 19, 1988, from the Manager of the Low-Level Waste Program of the Department of Ecology of the State of Washington to the Governor of New Hampshire purporting to advise the Governor that effective January 1, 1989, access to the Richland, Washington, low-level waste disposal facility will be denied to all generators of low-level radioactive waste in New Hampshire; and (3) a letter of February 17, 1989, from the Executive Director of the Rocky Mountain Low-Level Radioactive Waste Board to the Governor of the State of New Hampshire announcing the convening of a show cause hearing on March 16, 1989, to ascertain whether or not low-level waste generators in the State of New Hampshire should continue to be denied access to the Beatty, Nevada, low-level waste disposal facility.
As to this last missive, MAG apparently has decided the outcome of the hearing is a foregone conclusion.2 l
2 Motion at 2.
a - _ _ _ _ _ _ _ _ _
l 4
s a
i I
All of these attachments were issued pursuant to the provisions of the Low-Level Radioactive Waste Policy Act (the "Act")3 and result from the apparent failure to date of the State of New Hampshire to bring itself into compliance with certain milestones set forth in the Act, which failure, in
~
i turn, authorizes states with low-leve1 waste dicposal facilities to close those facilities to states failing to comply with the milestones.4 On the basis of these attachments, MAG now requests this Commission to reconsider CLI-88-10 on the theory that the l
assumption which MAG claims underlay CLI-88-10 that the low -
level wastes generated by low power operation would be shipped offsite "has proven erroneous."
For the reasons set forth below, the Applicants say that the Motion should be denied.
ARGUMENT In CLI-88-10, this Commission, in explaining what it had required in a previous order 5 stated, inter alia:
3 Act of December 22, 1980, P.L.96-573, 94 Stat.
l 3347, as amended by P.L.99-240, 99 Stat. 1842, 42 U.S.C. 55 2012b at ans.
4 333 Act 5 5.
5 Public Service Comnany of New Mannshire (Seabrook Station, Units 1 and 2), CLI-88-07, 28 NRC 271 (1988).
l
E, l' ',
v l.s "The Commission's order in CLI-88-07 did not require a final decommissioning plan.
The Commission has not determined that-decommissioning will be required after low power but simply that in these. unique circumstances financial projections should be in place to provide reasonable assurance of the availability of funds should commercial operation not occur.
In that light the Commission did not require or expect that the analysis of the costs of decommissioning would include precise information of the kind
'that intervanors seek.
The Commission i
expected' approximate estimates of costs so that a reasonable minimum sua could be determined and then adequate assurance provided for its availability.
l "Thus the Commission does not require the details of the low level waste disposal sites and disposal fees so long as the plan contains reasonable cost estimates for these matters.
Applicants have estimated these costs and included them in their calculations.- No contrary evidence has been offered.
Richard I.
Smith, of Battelle Laboratories, has in a sworn letter provided by Staff demonstrated that Applicants' low level waste disposal cost estimate of $90.00 per cubic foot significantly exceeds his own estimate of $60 per cubic foot based I
on disposal at Barnwell.n6 To the above-quoted statement was appended the following footnote:
" Suggestions that the Applicants need at I
this stage calculate availabilities of i
disposal capacity under limitations l
imposed by Section 5 of the Low-Level Radioactive Waste Policy Act are also off 1
the mark.
That section permits but does not reauire disposal sites to impose I
6 CLI-88-10 at 11 (emphases in original). _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _. _ _ _ _ _ _
j
o 4
l limit.s; moreover, there is transferability of available capacity.
Absent any evidence that waste disposal is unavailable the Commission need not embark on speculation of this nature."7 I
MAG pounces upon this footnote, and argues that "[t] hat I
speculation'has now become a reality,"8 recites the above-described attachments and argues for reconsideration presumably on the theory that the " evidence" the Commission recited as lacking now exists.
To begin with, the " evidence" does not yet exist even within MAG's view of the world.
The cognizant agency with respect to the Seatty, Nevada, site has yet to speak, and Applicants, at least, elect not to indulge in the presumption that the noticed hearing is a sham with a preordained result.
Second, the argument made by MAG overlooks other provisions of the Act which, in essence, require the State of New Hampshire either to get into compliance with the Act and provide low-level waste disposal for waste generated within I
its borders or take title to the waste, snd be responsible for it, as of 1996.
Not only should the Commission presume that New Hampshire will carry out its obligations to the i
I l
7 CLI-88-10 at 11 n.10 (emphases in original).
j 8
Motion at 4.
4 )
1 l
L
l '.
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spirit and letter of the Act,9 but the communication from the New Hampshire Department of Environmental Services to the Rocky Mountain Low Level Waste Board attached hereto and marked "A" demonstrates that the State of New Hampshire is cognizant, of and is working to meet, its obligations under the Act.
j Prescinding from the foregoing, and as a purely legal:
matter, as noted above, there is an unconditional obligation i
on the State of New Hampshire to take title to the waste involved in 1996.
As the Affidavit of George S. Thomas filed herewith demonstrates, there is more than sufficient capacity on the site to store the volume of waste involved until that time at a modest cost.
And since, at that point, the State would, under the Act, be responsible for the waste, it is clear that the amount which the Commission has ordered set aside in CLI-88-10, including a contingency in excess of
$14,000,000, is more than sufficient to cover the obligations of the Seabrook owners in the highly unlikely scenario that the State of New Hampshire reaches 1996 still in default under its legal obligations with respect to low level waste.
9 Public officials are presumed to obey the law.
United States v. chm =4 cal Foundation Inc., 272 U.S.
1, 14-15 (1926).
s l.
t CONCIRSION l-The motion should be denied.
Respectfully submitted, i
f f
Thomas G. Digsn, Jr.
George H. Lewald Kathryn A. Selleck Jeffrey P. Trout Jay Bradford Smith Geoffrey C. Cook Ropes & Gray one International Place Boston, MA 02110-2624 (617) 951-7000 counsel for App 11 cants _ _ _ - _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ - - _..
State of New Hamp1 hire del %RTMENT OF ENVIRON.\\lENTAL SERVICES f~
OFTICE of th COMMISSIONER ti li.aen Drne, P.O. Box 95. Concord, Nil U3301 tiO3 271-3503 ALDEN H. HO%ARD 6uuutanuwe Gk.OkCE A. MOLLlNEAUX 4 4mniwwwmiuma February 24, 1989 Leonard C. Slosky Executive Director Rocky Mountain Low-Level Radioactive l
Waste Board 1675 Broadway, Suite 1400 Denver, Colorado 80202
Dear Mr. Slosky:
This letter is in response to your letters of January 27 and February 17, i
1985 to Governor Gregg and our telephone conversation on February 21, 1989.
(
We are requesting that New Hampshire be reconsidered for a contract for access to the Beatty, Nevada regional low-level radioactive waste disposal facility.
Our reconsideration would be based on the general proposal we submitted on April 8, 1988.
Contractual access Siellar to the egreement you have developed with the State of Rhode Island and the District of Columbia would be the preferred method.
In an attempt to outline New Hampshire's situation I will briefly outilne a chronology of activities we have pursued in an attempt to remain in I
compliance with the Low-Level Waste Policy Act.
i A few months prior to the passage of the LLW Policy Act of 1980, we convened a meeting of legislative representatives from the six New England states to consider cooperative planning.
In early March,1980, with support from Governor King of Massachusetts the first organizational meeting for joint action was held at MIT when New York I
and Pennsylvania joined the group.
In September 1981, under the auspices of the toalition of Northeastern Governors, a Policy Working Group composed of credentialed executive and legislative representatives from 11 Northeastern states began negotiating a draf t conepact.
The document was compleaJ in February 1983 and forwarded to the 11 governors for action.
Only four states ratified the compact--Connecticut, New Jersey, Delaware, and Maryland. Subsequently, de ed hoc cosmittee of Neine New Hampshire, and Venmont discussed a three-state compact, but o..sy New Hampshire passed compact language which met the 1986 milestone.
Our continuous ef forts to meet the 1985 Amendments Act milestones by contracting or compacting have been unsuccessful, n
o
, ass-e
1 Rocky Mountain Low-Level Radioactive Wasto B:ard Page Two February 24, 1989 In April 1988, New Hampshire wrote to the Rocky Mountain Low-Level Radioactive Waste Board req' vesting access under contract to their disposal site. On June 30, 1988 our request was denied.
On December 19, 1988 the State of Washington Department of Ecology advised us that we will be denied access to the regional disposal facility located near Richland, Washington.
We wrote to the State of California on January 9,1989 requesting access under contract to any site they may consider. On February 1,1989 we received notice that their process had not developed enough to accept or deny any proposal.
On February 2, 1989 the State of Nevada Department of Human Resources advised us of denial to the Beatty site.
We are currently developing a proposal requesting contract access to the Texas Low-Level Radioactive Waste Disposal Authority.
I an also including a five-year projection of the volume of low-level radioactive waste which the Division of Public Health Services had developed.
Table I is a list of the companies which have licenses to handle radioactive materials in the state.
While all the licensees have the potential to generate low-level radioactive waste, at the present time the University of New Hampshire, Dartmouth College, and Kollsman Instrument Co.
generate the majority of the low-level radioactive wastes which require disposal.
The other licensees handle primarily sealed sources which are returned to the manufacturer for disposal. While this is the present method of disposing of the majority of the wastes in the state, conditions could change which would increase the volume of New Hampshire low-level radioactive waste requiring disposal at an approved facility.
Table II contains the five-year low-level radioactive waste projections.
It should be noted that the source category utility is the Seabrook Station.
Our p.ojections assume that the Seaprook station would receive a low power license in 1989 and a full-power license in 1990.
While Seabrook. Station would generate low-level radioactive waste during this time period, the Station has the capacity to store the LLRW on-site for at least five years.
Therefore, it is quite probable that the state would not have to deal with the disposal of the low-level radioactive waste generated by the Seabrook Station for the next 5-10 years.
Figure I compares the projected annual accumulative volume of low-level radioactive waste generated in the state to the volume which would have to be shipped out of state for disposal. The large disparity is due to the assumption that the Seabrook Station would store its low-level radioactive waste on-site for this period, s
Rocky Mountain Low-Level Radleactive Waste Board Page Three February 24, 1989 Hopefully this information can be included in the briefing book for the meeting you have scheduled on March 16, 1989 in Montrose, Colorado. I plan to attend your meeting and present the information as part of our request for reconsideration for access.
Sincerely yours, Geor A. Holl eaux Ass tant Come ssioner GAM:bda Enclosures i
TABLE 1 Companies Licensed by the NHDPHS to Handle Radianctive Materials as of February 15, 1989 LICNAME LIL,NUMt LICTYPE ALEZANDRIA POWER iSSOCIATES 3388 D(2)
ANDROSCOGGIN VALLET N0 SPITAL 2688 F - NEDICAL ARNTEC INDUSTRIES 315R D - INDUSTRIAL ATLANTIC TESTING LASS, INC.
2968 D-2 INDUST.LNTD SON SECOURS SALEN HEALTH CENTE 3098 F - NEDICAL CATHOLIC NEDICAL CENTER 1091 F - NEDICAL CHESNItt NEDICAL CENTER 223R F - NEDICAL TEL CHESNItt NEDICAL CENTER 2561 F-NEDICAL CLAROSTAT NFG. COMPANY, INC.
1698 D(2)-INDST.LMfD CONBUSTION ENGINEtt!NG INC.
2098 I STotAGE CONCORD NOSPITAL 2618 F-NEDICAL CONCORD OTOLARYNGOLOGY P.A.
3288 F(2) IN-VITRO CotNELL UNIVENSITY 1991 G-ENVIRONMENTAL COSTELLO,14NASNEY & DEMAPOLI 332R D(2)PotTABLE 3118 F-NEDICAL COTTAGE N0 SPITAL DZIENAN, EDWARD, J.
XXII EASTERN ANALYTICAL INC.
2878 D-2 INDUST.!JTD ELECTROPAC COMPANY, INC.
3192 D-2 INDUST.LMfD 2828 F - NEDICAL ELLIOT N0 SPITAL F - NEDICALJEL 2268 ELLIOT WOSPITAL F - NEDICAL 1388 EXETER NCSPITAL FRISBEE MEN 0tIAL N0 SPITAL 1111 GENINI TECNNICAL SERVICES INC.
3182 D-2 INDUST.1RTD GENERAL ELECTRIC COMPANY 3348 D(2)-SEALD SOUC GOLDBERG-10INO & ASSOC. INC.
316R D-2 INDUST.1ATD GTE PRODUCTS CORPORATION 0098 D-7508 D8C010115 NCA NEALTN SERVICES OF N.N.INC 3048 F - NEDICAL NCA-NEALTN SERVICES OF NN, INC left
,. F - NEDICAL F-2 MID. LNTD NEAD AM NSCE SPECIALTY OF N.N 2938 NEALTN RISE ASSESSNENT DPNS 335R I OTHER D INDUSTRIAL MuttARD FARMS P00LTtY RESEARCN3378 301R F - NEDICAL NUGGINS N0EFITAL 3418 D(2)/III IEL SERVICE, INC.
D(2) INDUST.LNTD 3408 J TRONICS INC.
D 2 INDUST.12TD JANES RIVER CORPORATION 1068 JANES RIVER CORPORATION 2628 D-2 INDUST.LNTD s
Pa&* 1
..e
kl9.95(
I LICNUNS LICTYPE EINSALL CHASE Co., INC.
YYYY ENIGNT CONSULTIM EMIN88tS.
2362 D-2 INDUST.1JITD 80LLSMAN C0., DIV. OF SEQUA 0165 80LL5 NAN CO., DIV 0F SEQUA 2448 0 - INDUSTRIAL LARES StGION GENEBAL HOSPITAL 2588 F - NEDICAL LITTLETON HOSPITAL 263E F - NEDICAL NAM. EAR.WOSE.THR0&T PROF. ASSN
.333R F-2 NED. LNTD.
MANCHESTit WAftt WORES 2608 D-2 INDUST.LNTD NARY WITCHCOCK REN0tIAL NOSP, 1301 F/II Natf MITCHC0CE ND0tIAL NOSP.
1811 F TELETHERAPY NARY HITCNCOCE NEN0tIAL NOSP.
30$R I LEAR IEST MARY NITCNC0CE R$N0tIAL NOSP.
SSSS NATO. DONALD F., P.E.
3238 D-2 INDUST.LNTD NILL 88 ENGINtitIM AND TF. STING 278R D-2 INDUST.LNTD N. N. DOT 145R D-2 INDUST.LJITD N.N. PUSLIC NEALTN LA80tATORY 3258 D-2 INDUST.LNTD W.M. WATER SUPPLT AND 3202 G-WELL LOGGIN N.N.BUttAU OF PUSLIC WORES DOT 273R D-2 INDUST.LNTO N/C DRILLING INC04PotATED 314R D-2 INDUST.LNTD MASWUA NEN0tIAL NOSPITAL 1838 F - NEDICAL NEW ENGLAEA CLINICAL 2148 F-2 NED. LNTD NN OFF 0F ENitGENCY NANAGENDT 1298 I-(1) SEAL SRC.
NotTNEAST TESTIM SElf!CES 2978 D-2 INDUST.LNTD WYI4el CORP. OF AN8tICA 1428 D-2 INDUST.LNTD PATN LAS INC.
2988 F-2 NED. LNTO PERRA WEATNERP300FIM INC.
2068 I - STot&GE USS PItt INDUSTRIts INCORPot&TED 3031 0-2 INDUST.1JETD PRO NED LA808170tf 3021 F-2 NED. IJITD PROCESS ENGINt8 TIM 2998 8-RADIO. IN-PlJff PUBLIC SERVICE COMPANY OF N.B.
3138
,0-2 INDUST.!JffD CAYTNRON CO C/0 CORP SAFETY 3291 D(2)-8845 SS E8800RC8 ANALYSTS INCORPORATED 2798 D-2 INDUST.LNTD RITIER COLLRGE (RENDEL BALL) 1621 I-SfotAGE 80CNRSTER SQUINE CLINIC 2328 I - ALL OTNtt EAND888 ASSOCIATES 1758 D-2 INDUST.LNTD SINFLit WItt AND CASLE COMPANT 1438 D-2 INDUST.LNTD SOILS ENGIWtttIM INC.
2648 D-2 INDUST.tJrTD ST. ANSttJI COLLEGE 1688 I - ACADENIC ST. J08tPN'S NOSPITAL 2091 F-NEDICAL Pete 2 j
i
l LICNUNS Mggfg LI_CNAEE TEMPLE-INLAND INCORPORATED 288R D-2 INDUST.LMfD THOMAS NURPHY N.D. RNA W.M.
336R F(2) MEDICAL TRANSFORMER SERVICE INC.
267R D-2 INDUST.LNTO TRUSTEES OF DARMOUTH COLLEGE 2768 E(1-A)ACAD.TYPA l
UNIVERSITY OF NEW NANPSHIRE 014S E - ACADEMIC UNIVERSITY OF NEW NANPSWIRE 1908 E(1-A)ACAD.TYPA V. A. MEDICAL CENTER 331R F(2) NEDICAL VALLEY REGIONAL N0 SPITAL 257R F - NEDICAL TENEGAS INDUSTRIAL TESTING 0138 D-2 INDUST.!JITD VENEGAS INDUSTRIAL TESTING 217R B-1 RADIO. FIELD VENEGAS INDUSTRIAL TESTING L&B 330R I-CALIBRATION WEEKS NEN0 RIAL N0 SPITAL 265R F - NEDICAL WENTWORTN-D0UGLASS NOSPITAL 0158 I-0TMER-AND NAT WENTWORTM-D0UGLASS N0$PITAL 206R F - NSDICAL l
WNITCONE. FRANK W. CONSTRUC* ION 274R D-2 INDUST.1JtTD 1
WHITE NOUNTAIN NEALTN CENY3R 294R F-2 NED. LNTO a
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TABLE II Five Year Projected Volumes of Low Level Radioactive' Wastes Generated in New Hampshire llII0 1911 1982 1983 I0fet 190s 130$
Ihne-
!ker
! Gene-
! Gear tGear ihne-
!ker i
Sewrce:! rated (l) Espeed! rates (!) Shipped!ratad(l) Dipped! rated (l) Dipped!ratad(!) bippedtrated(l) hi f(ft*3) (ft*3) f(ft*3) (ft*3)'(ft*3) (ft*3)!(ft*3) (ft*3) f(ft*3) (ft*3)l(ft*3) (ft*3)l(ft*3) (ft*3)I
.......[................!......
....t.......
g....
...g.
...g.
412 412 112?
4l2 412t 412 4121 412 412l 412 412l 24'2 1972i f
Acades.1
...l...........!....-...f.....'....J~l-._
I t
i I
t i
1 0
0!
0 04 0
01 0
0t 0
0t 0
0t 0
0I I
l I
Gowers.1 l......
...... l.
l..
i 1
f I
l l
lanet.l 195 1351 250 2501 250 2501 250 2501 250 2501 250 2501 1445 1+46I I
t
..._. l (3).....
!....(4)
......'.-(4).....
.l (4 )
..l. 3%).-
I _(4) --.
t I
t i
I 0
0t 0
Ct 0
0!
0 0t 0
0t 0
01 0
0i i
t
-I an11 call I -
l
!.~.
l...
J i
I I
l l
Ut!! styl 0
0!
200 0? 4000 01 4500 01 4500 0t 4500 4l 17100 4I
_l l............ f...J5).
.J (6)...
..J.. (8)_ J (6).
(6)_._t(5)llt) l t
f I
f I
i
~
10taL i 601 307t It:
X: ? 4662 GC21 5162 4621 5162 6621 5162 GE21 2)(11 3311I l
t
~.......
~.-...-......
el($: (hasts tiported is Class A); (1 ft*3 : 0.021 s*3)
(t) threwgh (6), see attached West.
.u Source: New Hampshire Division of Public Health Services.
Bureau of Itadiological Health k
n M4
ypgfjS:
1)
Refers to low level radioactive waste (LLRW) generation destined for disposal at a licensed LLRW disposal site. Waste volumes which would be disposed of via other means specified in N. H. Rules for the Control of Radiation Part He-P 2023 (e.g., sanitary sewer system, transfer to an authorized recipient, etc.) have not been included in these figures.
Volume includes waste genetated by UNH and Dartmouth College.
Dartmouth's 2) total storage capacity as currently authorized is 240-55 gallon d mas.
'the storage facility is now 84.5% full, leaving room for only 37 additional 55-gallon dmms.
Dartmouth currently generates 40-55 gallon drums of Unless another means of disposal is authorized by this waste per year.
Bureau (e.g., incineration, disposal to local landfill, additional storage space, etc.) Dartmouth will be required to ship all additional waste generated.
Volume includes waste generated by GTE Sylvania, Kollsman Instrument Co..
3)
Loon Mountain.
Volume includes waste predicted to be generated by Kollsman Instmment Co.
4) only.
GTE no longer generating waste, I4cn' Men, was a one time shipment.
Assumes Seabrook Station obtains its low power license in 1989.
5)
Assumes Seabrook Station obtains its full power license in 1990.
6)
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+ h he sNeped 9 h he se wsted N.
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LLJ4W CClass A) be.utiw seeisetten (ase>&ses) g,,,
Mens l
16 f
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- IIII
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ases.
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e j
So m er wasse W D he eMaced G h he grurtted e
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(naskuss)
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uns use asas ases asus asus veer
- h he shissed e h he snroted The Projected Total Volume of Low Level Radioactive Waste Figure 1 Waste Generated in New Hampshire Compared to the Volume Requiring Out of State Disposal between 1988 and 1993 l
l I
p 7,q r, CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr., one of the attornegg QQY the P 3 :43 Applicants herein, hereby certify that on March 13, 1989, I made service of the within document by depositing copies thereof with Federal Express, prepaid, for delivery to (or where[ indicated, by depositing in the United States mail, first class" postage, paid, addressed to) the individuals listed below:
Lando W.
Zech, Jr., Chairman Thomas M. Roberts, Commissioner l
U.S. Nuclear Regulatory U.S. Nuclear Regulatory 1
Commission Commission One White Flint North One White Flint North l
11555 Rockville Pike 11555 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 Kenneth M. Carr, Commissioner James R.
Curtiss, Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission One White Flint North One White Flint North 11555 Rockville Pike 11555 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 Kenneth C. Rogers, Commissioner William C. Parler, Esquire U.S. Nuclear Regulatory General Counsel Commission Office of the General Counsel One White Flint North One White Flint North 11555 Rockville Pike 11555 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 Alan S. Rosenthal, Chairman Howard A. Wilber Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Appeal Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Thomas S. Moore Marjorie Nordlinger, Esquire Atomic Safety and Licensing Office of the General Counsel Appeal Panel One White Flint North U.S. Nuclear Regulatory 11555 Rockville Pike Commission Rockville, MD 20852 East West Towers Building 4350 East West Highway Bethesda, MD 20814
I Administrative Judge Ivan Smith Administrate've Judge Kenneth A.
l Chairman, Atomic Safety and McCollom Licensing Board 1107 West Knapp Street l
U.S.
Nuclear Regulatory Stillwater, OK 74075 Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 l
Administrative Judge Richard F.
Administrative Judge Peter B.
Cole, Atomic Safety and Bloch, Chairman, Atomic Licensing Board Safety and Licensing Board U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, Md 20814 i
Dr. Jerry Harbour-Administrative Judge Emmeth A.
Atomic Safety and Licensing Luebke Board 4515 Willard Avenue U.S. Nuclear Regulatory Chevy Chase, MD 20815 Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 Mr. Richard R. Donovan Diane Curran,' Esquire 1
Federal Emergency Management Andrea C. Forster, Esquire Agency Harmon, Curran & Tousley Federal Regional Center Suite 430 130 228th Street, S.W.
2001 S Street, N.W.
Bothell, WA 98021-9796 Washington, DC 20009 Robert R. Pierce, Esquire John P. Arnold, Esquire Atomic Safety and Licensing Attorney General Board George Dana Bisbee, Esquire U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814 _ _ _ _ _ _ _ - _ _ _ _ - _ _ -
I t
('
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 One White Flint North East West Towers Building 15th Floor 1
4350 East West Highway 11555 Rockville Pike l
Bethesda, MD 20814 Rockville, MD' 20852
- Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street l
l Commission P.O.
Box 516 Washington, DC 20555 Manchester, NH 03105 l
Philip Ahrens, Esquire Mr. J. P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire John Traficonte, Esquire Shaines & McEachern Assistant Attorney General Maplewood Avenue Department of the Attorney P.O.
Box 360 General Portsmouth, NH 03801 One Ashburton Place, 19th Floor Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street i
Kensington, NH 03827 Portsmouth, NH 03801
- Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Hill-Whilton &
Washington, DC 20510 Rotondi (Attn:
Tom Burack) 79 State Street Newburyport, MA 01950 1
- Senator Gordon J. Humphrey Leonard Kopelman, Esquire I
One Eagle Square, Suite.507 Kopelman & Paige, P.C.
Concord, NH 03301 77 Franklin Street (Attn:
Herb Boynton)
Boston, MA 02110 i I
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l Mr. 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 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Harpe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03842 Concord, NH 03301 Judith H. Mizner, Esquire Ashod N. Amirian, Esquire 79 State Street, 2nd Floor 145 South Main Street Newburyport, MA 01950 P.O. Box 38 Bradford, MA 01835 James H. Carpenter, Alternate Robert Carrigg, Chairman Technical Member Board of Selectmen Atomic Safety and Licensing Town Office Board Panel Atlantic Avenue U.S. Nuclear Regulatory North Hampton, NH 03862 Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 Thomas G. DjJyrfft & J r.
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