ML20237B660
| ML20237B660 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/07/1987 |
| From: | Berry G NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#487-5071 OL-1, NUDOCS 8712170041 | |
| Download: ML20237B660 (17) | |
Text
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DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'87 DEC -9 P1 :05 BEFORE THE ATOMIC SAFETY AND LICENSING BOARh0CKETNib [.
G BRANCH in the Matter of
)
I
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Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF
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50-444 OL-01 NEW HAMPSHIRE, et al.
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On-site Emergency Planning
)
and Safety Issues j
(Seabrook Station, Units 1 and 2)
)
NRC STAFF RESPONSE TO NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NRC STAFF ON MECNP CONTENTIONS l.V. AND IV l.
INTRODUCTION On November 20, 1987, the New England Coalition on Nuclear Pollution (NECNP) served upon the NRC Staff its first set of interrogatories in which it propounded thirteen interrogatories (several of which contain multiple parts) and requests for the production of documents relating to the two contentions remanded for further litigation l
I by the Appeal Board in ALAB-875.
NECNP has not even attempted to comply with the requirements of 10 C.F.R. 6 2.720(h)(2)(ii),
the 1
Commission's regulation which forbids interrogatories to the Staff in the absence of a finding that the interrogatories are necessary to a proper i
decision in the proceeding and that the answers are not obtainable from any other source.
Neverthess, and without waiving its right to insist upon future compliance with the Commission's Rules of Practice, the Staff has responded to Interrogatories 1,2,3,4,5,6.
The Staff objects to Interrogatories 7 and 13 for the reasons herein. The Staff will submit its 1
8712170041 871207 PDR
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responses to Interrogatories 8 through 12 within the next ten working days.
11.
LEGAL STANDARDS l
Discovery against the Staff rests upon a different footing from that against other parties.
Pennsylvania Power and Light Company (Susquehanna Steam Electric Station, Units 1 and 2), ALAB-613,12 NRC 317, 323 (1980).
This is because, with limited exceptions, final agency records and documents are made available to all members of the public in the NRC's Public Document Room.
See 10 C.F.R. f 2.790.
Since these l
1 documents "should reasonably disclose the basis for the Staff's position,"
l there is little need for formal discovery against the Staff.
Susquehanna, j
supra,12 NRC at 323.
This is the reason underlying the rule exempting the Staff from having to respond to interrogatories in the absence of a finding by the Presiding Officer that " answers to the interrogatories are necessary to a proper decision in the proceeding and that answers to the interrogatories are not reasonably obtainable from any other source [.]"
10 C.F.R. s 2.720(h)(2)(li).
Ill.
RESPONSES Interrogatory 1 Please identify all persons who participated in the preparation of answers to these interrogatories, and identify the portions of your response to which each person contributed.
Answer See Attached Afidavit of Herbert F. Conrad.
Interrogatory 2 What is the Sta ff's position with respect to the adequacy of Applicants' program for inservice inspection of steam generator tubes?
Answer The Staff's position is reflected in the following sections of NUREG-0896, the Safety Evaluation Report (SEP,) related to the operation of the Seabrook Station:
5.4.2.2 Steam Generator Tube inservice inspection 5.4.2.2.1 Compilance with the Standard Review Plans Seabrook Units 1 and 2 were reviewed in accordance with SRP 5.4.2.2 ( N U RE G-0800).
However, the staff review will continue until the plant Technical Specifications governing steam generator tube examinations are completed and are in conformance with the applicable standard Technical Specification.
5.4.2.2.2 Evaluation of the Inspection Program GDC 32 requires, in part, that RCPB components be designed to permit periodic inspection and testing of l
important areas and features to assess their structural I
and leaktight integrity.
The design of all pressure-retalning parts of the steam generators at Seabrook Units 1 and 2 has been cptionally upgraded to meet the ASME Code requirements for ASME Code Class 1 components.
Provisions also have been made to permit inservie inspection of the Class 1
and 2 components, including individual steam generator tubes.
The applicant has committed to following the recommendations of [ Regulatory Guide] 1.83, Revision 1,
" Inservice Inspection of Pressurized Water Peactor Steam Generator Tubes," and NUREG-0452, Standard l
Technical Specifications for Westinghouse Pressurized Water Reactors,"
and to complying with the requirements of ASME Code Section XI with respect to the inspection methods to be used.
The staff finds this commitment acceptable.
5.4.2.2.3 Conclusions Conformance with RG 1.83, NUREG-0452, and the inspection requirements of ASME Code Section XI constitutes an acceptable basis for meeting, in part, the requirements of GDC 32.
(Conrad)
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Interrogatory 3 I
Please identify and produce all documents on which you rely or i
intend to rely during this proceeding to support your position on NECNP contention I.V. (steam generator tube inspection).
This includes but is
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not limited to all documents used in answers to these interrogatories, summary disposition motions,
testimony, and cross-examination of witnesses during hearings.
Answer Documents are referenced in the answers to 6a,b,d, and g.
In addition, the following documents pertaining to the North Annua steam may be used:
REFERENCES I
i 1.
Letter dated September 15,1987, from W. L.
Stewart to Director of Nuclear Reactor Regulation, NRC, Accession NO. 870916239.
2.
Letter dated September 25, 1987, from W.L. Stewart to Director of NRR, NRC Accession No. 8709290377.
3.
VEPCO Report, " North Anna Unit 1 July 15, 1987, Steam Generator Tube Rupture Event Report," September 15, 1987, Revision 1.
(This report is docketed as part of Reference 1 above.)
4 Westinghouse Report WCAP-11601 (Proprietay Version) and WCAP-11602 (Non-Proprietay Version), " North Anna Unit 1 Steam Generator Tube Rupture and Remedlai Actions Technical Evaluation,"
September 1987. NRC Accession No. 8710050087 and 0710050084.
5.
NRC mgmented Inspection Team (AIT) Report Nos. 50-338/87-24 and 50-334/37-24, inspection Conducted July 15-August 14, 1987, NRC Accest'on No. 8709040277.
6.
Westinghouse presentation to NRC staff and VEPCO on August 17, 1987, at Westinghouse Research Center, Pittsburgh.
7.
NRC consultant's report authored by R.G.
Ballinger, " North Anna
- 1, Steam Generator, Row 9,
Column 51 Tube Failure Analysis,"
October 19, 1987.
8.
TPRI Report NP-2957, " Fatigue Performance of Ni-Cr-Fe Alloy 600 Jnder Typical PWR Steam Generator Conditions," March 1983.
9.
USNRC Inspection Report No. 50-338/87-28, August 10-14, 1987, NRC Accession No. 8709090321.
10.
USNRC Inspection Report No. 50-338/87-31, August 31-September 4, 1987.
a
. l l
ll.
- Bates, R.C.
and Clark, W.G., Jr., Transactions of the American Society for Metals, Vol. 62,1969, p. 380.
12.
Smith,
K.N.,
- Watson, P.,
and Tropper T.H.,
"A Stress-Strain Function for the Fatigue of Metals," Journal of Metals, JMLSA, Vol.
5, No. 4, Dec.1970, pp. 767-778.
(Conrad)
Interrogatory 4 i
Please identify all persons on whose factual knowledge, opinions, or I
technical expertise you rely or intend to rely for your position on contention I.V.
Answer Herbert Conrad, Emmett Murphy.
Interrogatory 5 j
l Please identify all persons you may call as witnesses on Contention I
l.V.
Please describe the substance of their testimony; and identify and describe any documents and the portions thereof that they may rely on j
for their testimony, f
Answer The Staff may call the following persons to testify on its behalf:
Herbert F. Conrad, Emmett Murphy.
The testimony of the Staff witness or witnesses will relate to the Staff's position with respect to NECNP contention IV.
Copies of statements of profc'ral qualifications of Staff witnesses will be made available to NECNP.
Interrogatory 6 l
On November 9,
1987, according to the attached article from Nuciconics Weak (November 12, 1987), the Staff and the Commissioners met to discuss the problem of steam generator tube breaks that are not detectable by eddy current testing or tube inspection.
Please answer the following questions regarding the issues discussed in that meetina:
a)
Describe the type and manufacturer of leakage detection equipment that the NRC considers may be inadequate to detect steam generator tube leaks.
b)
Describe all changes to leakage detection equipment and procedures that are under consideration by the NRC Staff.
In what l
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regulations or guidance documents are these procedures and types of equipment referenced? Please identify all portions of NRC regulations and guidance documents for which changes are under consideration, c)
The Nucleonics Week article identifies five plants that are
" susceptible" to the North Anna tube rupture failure mechanism.
Please identify the 12 additional plants that the NRC considers may also be i
susceptible.
What are the reasons for considering these plants to be I
potentially susceptible?
d)
Has the Staff considered whether the Seabrook plant is also susceptible to steam generator tube rupture?
If not, does the Staff plan to undertake such consideration?
e)
If the Staff does not plan to evaluate the susceptibility of the Seabrook plant, what are the reasons for its decision?
f)
If the Seabrook plant is considered susceptible, what are the reasons for this determination?
g)
Please identify and provide copies of all documents relating to the Staff's evaluation of the need for additional equipment or procedures for the detection of steam generator tube leaks at nuclear power plants.
h)
When did the Staff's evaluation begin?
On what date did the Staff conclude that current equipment and/or procedures might not be adequate to detect steam generator tube leaks?
When and how was this conclusion communicated to licensees and license applicants?
When and how was it communicated to Applicants?
i)
To what levels is the NRC considering lowering the limit on leaks inside steam generators? What are the reasons _ for considering this change?
Answer a)
The acceptance requirements for leakage detection equipment are described in Section 5.2.4.
" Reactor Coolant Pressure l
Boundary Leakage Detection," NUREG-0800, USNRC Standard Review Plan.
The criteria are based on general design criteria and regulatory
]
guides.
The design of the system is acceptable if the integrated design of the system is in accordance with General Design Criterion 2 and 30,10 CFR 50, Appendix A and Regulatory Guides 1.29 and 1.45.
Specific types and manufactures of leakage detection equipment are not addressed.
t-b)
The Staff is considering the issuance of an NRC Bulletin informing licensees of the Staffs conclusions regarding the North Anna steam generator tube rupture.
This bulletin may request enhanced primary-to-secondary leakage monitoring.
At the present time, however no official Staff position has been adopted.
When and if adopted the position will be stated in the NRC Bulletin and will be available to the public.
c) The 12 additional plants are:
Beaver Valley 1 and 2 Farley 1 and 2 Cook 1 and 2 j
Prarie Island 1 and 2 Salem 2 Diablo Canyon 1 and 2
{
Ginna 1 San Onofre 1 These plants were identified by Westinghouse Electric Company based on its knowledge of operating conditions and configurations and a conservational stability ratio analysis.
The other criteria for inclusion on the list is that the steam generators have carbon steel top tube support Plates having drilled holes, which may be susceptible to the corrosion process known as " denting."
" Denting" refers to the growth of the iron oxide corrosion product in the annulles between the tube and the drilled hole to the extent that the tube is gripped or physically squeezed causing deformation.
d)
The Seabrook plant is not considered to be susceptible to the fluid flow induced vibration fatigue failure mechanism that caused the North Anna steam generator tube rupture, because it does not have
l 1 j carbon steel top support plates with drilled holes.
As stated in i
N U REG-0896, Safety Evaluation Report related to the operation of Seabrook Station Units 1 and 2 at Section 5.4.2.1 1
Steam Generator Materials:
"The tube support will be manufactured from. ferritic stainless steel material, which has been shown in 4
laboratory tests to be corrosion resistant to the operating environment.
The tube support plants will be designed and manufactured with broached rather than drilled holes.
The broached-hole design promotes high-velocity flow along the tube, sweeping impurities away from the support plates locations."
'Our present understanding of the failure mechanism at North Anna is l
that the stresses in the steam generator tubes will not be high enough to
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cause the fatigue crack failure without the clamping action of the corrosion product buildup in the annatus between a drilled hole in the top l
support plate and the tube caused by the " denting" process previously i
discussed in the answer to 6(a).
This is prevented from happening in the Seabrook steam generators in three ways:
1.
Highly corrosion-resistant ferritic stainless steel is used instead of susceptible carbon steel for the tube support plate material, thus preventing the formation of the iron oxide corrosion product.
2.
An improved support plate design is used.
The quatrefoil tube support plate hole design features four lobes and tube support lands.
The lands support the tubing and the lobes i
l provide a path for water to flow adjacent to the tube.
The quatrefoil design directs the flow along the tubes in a way that minimizes steam formation and chemical concentration at tube-to-tube support plate intersections.
The quatrefoil support plate results in higher average velocities adjacent to the tubes than the original lower assembly support plates, which feature circulation flow holes between tube holes. The quatrefoil support plate minimizes sludge deposition.
The combination of high velocities in the support plate region and corrosion resistant material should minimize the potential for tube corrosion in the vicinity of the support plates.
9-3.
As stated in NUREG-0896 Supplement No.
5, Safety Evaluation Report related to the operation of Seabrook Station Units 1
and 2,-
Section 10.3.4, the Seabrook Technical Specifications will contain
[Section 6.7.4c]
a requirement to implement a.
secondary water chemistry monitoring and control program that conforms with -
N U REG-0800, Standard Review Plan, Section 5.4.2.1.
The implementation of a water chemistry program conforming to these guidelines will minimize the possibility of an enviroment in the steam generator that will. promote corrosion processes.
e) Staff Response to Interrogatory 6(d).
1 f)
Not applicable.
See Staff P,esponse to interrogatory 6(d).
]
l g) See Staff Responses to Interrogatories 6(a) and 6(b).
h)
The Staff's evaluation began with the North Anna 1 steam generator tube rupture event on July 15, 1987.
The Staff has not yet l
completed its evaluation and reached a conclusion on steam generator l
l l
leakage procedures and equipment.
-It is expected that a NRC Bulletin will be issued to communicate any conclusions reached by the Staff to licensees and applicants.
]
l i) See Staff Response to interrogatory 6(b).
(Conrad)
Interrogatory 7 Please identify and provide copies of all correspondence and records of contacts between the Staff and Applicants regarding testing of steam generhtor tubes at the Seabrook plant.
Answer The Staff objects to answering this interrogatory since the information requested, assuming it exists, is reasonably obtainable from another source, namely the Applicants and the Staff's Public Document Room.
1 i
I
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Interrogatory 8 V/ hat is the Sta ff's position with respect to the adequacy of Applicants' program for prevention of biofouling of cooling systems in the Seabrook nuclear power plant?
Answer Interrogatory 9 Please identify and produce all documents on which you rely or intend to rely during this proceeding to support your position on NECNP j
contention IV (biofouling of coolant systems).
This includes but is not limited to all documents used in answers to these interrogatories, summary disposition motions, testimony, and cross-examination of witnesses during hearings.
Answer l
Interrogatory 10 1
Please identify all persons on whose factual knowledge opinions, or techniccal expertise you rely or intend to rely for your position on j
i contention IV.
4 i
Answer Interrogatory 11 Please identify all persons you may call as witnesses on contention IV.
Please describe the substance of their testimony; and identify and describe any documents and the portions thereof that they may rely on for their testimony.
Answer interrogatory 12 Please identify and provide access to all studies, evaluations, reports, or other documents which describe and/or evaluate actual or potential biofouling conditions at Seabrook.
Answer l
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Interrogatory 13 Please identify and provide access to documentation of all inspections of safety and non-safety related cooling systems that are affected by or are potentially affected by biofouling.
Answer The Staff objects to answering this interrogatory since the identity of cooling systems which are or may be affected by biofouling is reasonably obtainable from another source, namely the Applicants.
Additionally, reports of all inspections of the Seabrook facility conducted f
by the Staff are available in the Public Document Room. Moreover, to the extent that the interrogatory seeks documentation of inspections of cooling
)
systems at facilities other than Seabrook,
the interrogatory is objectionable because it calls for information not necessary to a proper l
l decision in the proceeding.
1 ectfully submitt
'l
% & Jn; Greg y Alpn Berry 1
Coun l fot NRC Staff I
Dated at Bethesda, Maryland this 7th day of December 1987 i
l 1
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U.S. NUCLEAR REGULATORY COMMISSION HERBERT F. CONRAD PROFESSIONAL QUALIFICATIONS My present position is Senior Materials
- Engineer, Material Engineering Branch Office of Nuclear Reactor Regulation.
In this.
capacity I am responsible for technical safety review and evaluation of materials used in the construction of nuclear power plant components.
Specially, the responsibilities include evaluation of materials application, l
heat treatment, fabrication, inspection and corrosion control.
I am a l
former member of the American Society of Mechanical Engineers Nuclear Code Committee Subgroup on Fabrication and Examination (Section 111).
I hold a M.S.
In Metallurgy (1959) and a B.S.
In. Mechanical Engineering (1957) from the Massachusetts Institute of Technology.
I am registered by the State of California as a Professional Engineer in--
Mechanica. Engineering and in metallurgical Engineering with more than 28 years of professional experience.
I am a member of the American Society for Metals (ASM).
I have several publications in metallurgy, the most l
recent is a contribution to the ASM Metals Handbook, Volume 10, Failure 1
Analysis ( ASM,1975).
j i have been with the Nuclear Regulatory Commission since February i
1973, two years of which were as a loan employee on detail from the University of California.
Prior to my assignment to Washington, I was employed by the Lawrence Livermore Laboratory of the University of California as a Metallurgist.
J
o
)
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF
)
50-444 OL-01 NEW HAMPSHIRE, et al.
)
On-site Emergency Planning
)
and Safety issues (Seabrook Station, Units 1 and 2)
)
AFFIDAVIT OF HERBERT F. CONRAD 1, Herbert F. Conrad, being first duly sworn do hereby depose as follows:
1.
That I participated in the preparation of the NRC Staff's responses to Interrogator!es 2, 3, 6 of NECNP's First Set of interrogatories And Request For The Production of Documents To The NRC Staff on NECNP contentions I.V.
and IV.
i 2.
That such responses are correct to the best of my knowledge and belief.
$<]+Y Aa Herbert F. Conra~d Sworn to and subscribed before me
)
this 4th day of December 1987:
4x%Le&df/Aab -
My Commision Expires: July 1,1990
4 NUCLEAR REGULATORY COMMISSION EMMETT MURPHY
)
PROFESSIONAL QUALIFICATIONS My name is Emmett Murphy.
I am employed as a Materials Engineer, Material Engineering
- Branch, Division of Engineering and Systems Technology, Nuclear Reactor Regulation of the NRC.
I graduated from the University of Maryland in 1970 with B.S. In Aerospace Engineering and received an M.S. degree in Civil Engineering from the University of l
Maryland in 1973.
I worked for Westinghouse at the Bettis Atomic Power i
Laboratory (Pittsburgh, PA) between 1973 and 1979.
While at Bettis, I l
was engaged in the structural design and analysis of naval reactor core l
components.
In 1979, I joined the NRC where I have been involved l
chiefly with plant-specific and generic issues pertaining to steam generator tube integrity.
l l
l L _ _ ____________________ _ ___ _____
- E M D @ q {g;g g 7kOtKEIG ussac UNITED STATES OF AMERICA N Nc 9 P1 :05 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAbH MEig>C in the Matter of
)
)
Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF
)
50-444 OL-01 NEW HAV.PSHIRE, et al.
)
On-site Emergency Planning
)
)
and Safety issues (Seabrook Station, Units 1 and 2
)
CERTIFICATE OF SERVICE I
hereby certify that copies of "NRC STAFF
RESPONSE
TO NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NRC STAFF ON NECNP CONTENTIONS
- 1. V.
AND IV" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mail system, this 7th day of December 1987.
)
Sheldon J. Wolfe, Esq., Chairman
- Dr. Emmeth A. Luebke Administrative Judge Administrative Judge Atomic Safety and Licensing Board 5500 Friendship Boulevard U.S. Nuclear Regulatory Commission Apartment 1923N Washington, DC 20555 Chevy Chase, Maryland 20815 Dr. Jerry Harbour Ms. Carol Sneider, Esq.
Administrative Judge Assistant Attorney General j
Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Commission One Ashburton Place,19th Floor Washington, DC 20555 Boston, MA 02108 Beverly Hollingworth Richard A. Hampe, Esq.
209 Winnacunnet Road New Hampshire Civil Defense Agency Hampton, NH 03842 107 Pleasant Street Concord, NH 03301 Sandra Gavutis, Chairman Calvin A. Canney, City Manager Board of Selectmen City Hall RFD 1 Box 1154 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801
Stephen E. Merril:
Faul McEachern, Esq.
3 Attorney General Matthew T. Brock, Esq.
George Dana Bisbee Shaines & McEachern Assistant Attorney General 25 Maplewood Avenue Office of the Attorney General P.O. Box 360 25 Capitol Street Portsmouth, NH 03801 Concord, NH 03301 Roberta C. Pevear 3
Angie Machiros, Chairman State Representative Board of Selectmen Town of Hampton Falls 25 High Road Drinkwater Road Newbury, MA 09150 Hampton Falls, NH 03844 Allen Lampert Mr. Robert J. Harrison Civil Defense Director President and Chief Executive Officer Town of Brentwood Public Service Co. of New Hampshire 20 Franklin Street P.O. Box 330 Exeter, NH 03833 Manchester, NH 03105 Charles P. Graham, Esq.
Robert A. Backus, Esq.
McKay, Murphy and Graham Backus, Meyer & Solomon j
100 Main Street 116 Lowell Street j
Amesbury, MA 01913 Manchester, NH 03106 j
Diane Curran, Esq.
Philip Ahren, Esq.
Harmon & Weiss Assistant Attorney General 2001 S Street, NW Office of the Attorney General Suite 430 State House Station #6 i
Washington, DC 20009 Augusta, ME.04333 1
Edward A. Thomas Thomas G. Dignan Jr., Esq.
Federal Emergency Management Agency Ropes & Gray 442 J.W. McCormack (POCH) 225 Franklin Street Boston, MA 02109 Boston, MA 02110 H.J. Flynn, Esq.
William Armstrong Assistant General Counsel Civil Defense Director i
Federal Emergency Management Agency Town of Exeter 500 C Street, SW 10 Front Street Washington, DC 20472 Exeter, NH 03833
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Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel
- Board
- U.S. Nuclear Regulatory Ccmmission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 i
t u_
Jane Doughty Docketing and Service Section*
Seacoast Anti-Po!!ution League Office of the Secretary 5 Market Street U.S. Nuclear Regulatory Commission Portsmouth, NH 03801 Washington, DC 20555 Maynard L. Young, Chairman William S. Lord j
Board of Selectmen Board of Selectmen 10 Central Road Town Hall - Friend Street South Hampton, NH 03287' Amesbury, MA 01913 Michael Santosuosso, Chairman Peter J. Matthews, Mayor 1
Board of Selectmen City Hall l
South Hampton, NH 03287 Newburyport, MN 09150 l
l Mr. Robert Carrigg, Chairman Judith H. Mizner, Esq.
I Board of Selectmen Silverglate, Gertner, Baker-i Town Office Fine and Good Atlantic Avenue 88 Broad Street North Hampton, NH 03862 Boston, MA 02110 R. K. Gad Ill, Esq.
Mrs. Anne E. Goodman, Chairman Ropes & Gray Board of Selectmen 225 Franklin Street 13-15 Newmarket Road Boston, MN 02110 Durham, NH 03824 Gary W. Holmes, Esq.
1 Holmes & Ellis 47 Winnacunnet Road Hampton, NH 03842 Gregory / Alan 3drry Counselyor RC Staff
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