ML20245J294

Testimony of F Kantor Re Basis A.5 of Commonwealth of Ma Atty General Amended Alert Notification Sys Contention.* Kantor Prof Qualifications Encl.W/Certificate of Svc.Related Correspondence

ML20245J294
Person / Time
Site:	Seabrook
Issue date:	04/26/1989
From:	Kantor F Office of Nuclear Reactor Regulation, NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
References
CON-#289-8523 OL-1, NUDOCS 8905040086
Download: ML20245J294 (17)

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i103 d C I, D pnD CORRESPONDENCE 8 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '89 ITR 26 P3 :28 cr 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 (SeabrookStation,UnitsIand2) )

TESTIMONY OF FALK KANTOR REGARDING BASIS A.5 0F MASSACHUSETTS ATTORNEY GENERAL'S AMENDED ALERT NOTIFICATION SYSTEM CONTENTION Q1: Please state your full name, employer, and occupation.

A1: My name is Falk Kantor. I am employed as a Section Chief in the Emergency Preparedness Branch of the Of fice of Nuclear Reactor Regulation of the U.S. Nuclear Regulatory Commission. -In this capacity I am. responsible for supervising the review and evaluation of radiological emergency plans submitted by nuclear power plant applicants and licensees to ensure the proposed plans meet the regulatory requirements and guidance of the Commission.

Q2. Mr. Kantor, have you prepared a statement of your professional qualifications?

A2. Yes, a statement of my professional qualifications is attached to this testimony.

Q3. Mr. Kantor, what is the purpose of your testimony?

A3. My testimony addresses those issues relating to Basis A.5 of the Massachusetts Attorney General's amended alert notification siren contention which the Licensing Board found to be in dispute in its March pr%88R 838@p ysd

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3, 1989 order (LBP-89-09) which granted in part and denied in part Applicants' motion for summary disposition of the Attorney General's i contention.

I Q4. Mr. Kantor, are you familiar with Basis A.5 of the Attorney General's amended alert notification system contention?

A4 Yes, I am. Basis A.5 of the Attorney General's contention states:

The time needed for driver alert, dispatch, route transit, setup and activation in accordance with NRC regulations will aceed 15 minutes for many of the VANS vehicles in optimum weather condition. The reasons for this include the time required to get vehicles on the road (which itself includes the time required to notify the driver, have the driver proceed to the vehicle, check out the vehicle equipment, start the vehicle and leave the staging area, along with other vehicles at the staging area), the distance to be traveled, the traffic that will be encountered, the setup time and the need for both alert signal and message capability within the 15 minute period. In poor weather, heavy traffic, and nighttime conditions the times needed to accomplish these tasks will increase.

Q5. Please identify the issues relating to Basis A.5 of the Attorney General's contention which your testimony addresses.

A5. The four issues relating to Basis A.5 which the Board found to be in dispute are listed at pages 37-38 of the Board's March 3,1989 order. The issues are:

1. What is an appropriate conservative estimate of the length of time it l would take for drivers to take the necessary actions before their vehicles leave their stations during conditions likely to prevail at the time of need?

2. Given that there is snowfall of 0.5 inches or more during 5.5% of the days of the year, would a conservative estimate of travr.1 times to VANS acoustic locations include the somewhat prolonged travel times anticipated during snow conditions? If so, what time estimates should be included?

3. What is an appropriate conservative estimate of the length of time it would take for people within five miles of Seabrook to receive the information message to be broadcast over the EBS?

4. What is an appropriate conservative estimate of the total length of time for alerting and informing people within five miles of Seabrook?

Is that estimate within acceptable guide lines? (if it is longer than 15 minutes, what are the factors we are to consider in deciding whether the time period is adequate?)

Q6. Mr. Kantor, are you familiar with Applicants' Vehicular Alert and Notification System (VANS)?

A6. Yes, I am.

Q7. What is the VANS?

A7. The Vehicular Alert and Notification System (VANS) is a mobile fixed siren concept designed to provide public alerting for the Massachusetts portion of the plume exposure pathway Emergency Planning Zone (EPZ). The VANS is comprised of heavy-duty trucks equipped with a telescoping crane to which is attached a Dual Whelen Model WS-4000 siren. The VANS vehicles are deployed to sixteen acoustic locations from six continuously staffed primary staging areas.

08. Mr. Kantor, where are the regulatory requirements regarding alert and notification systems found?

A8. The Commission's requirements regarding alert and notification systems are set forth in 10 CFR 50.47(b)(5), which states:

...means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established."

and Appendix E to 10 CFR 50, Section IV.D.3, which states:

"The design objective of the prompt public notification system shall be to have the capability to essentially complete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes."

09. Mr. Kantor, is a vehicular alert and notification system required by NRC regulations?

A9. No. The regulations require Applicants to demonstrate that administrative and physical means have been established for alerting and providing prompt

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l instructions to the public within the plume exposure pathway EPZ. The l regulations do not expressly require or prohibit the use of specific systems or methods to achieve this objective.

Q10. What guidance criteria exist regarding alert and notification systems?

A10. Guidance criteria regarding alert and notification systems are found in NUREG-0654/ FEMA-REP-1, Revision 1 and Supplement 1, FEMA-REP-10, and FEMA Guidance Memorandum AN-1. These documents provide guidelines for developing and evaluating the alert and notification systems required by the regulations for nuclear power plants. Regarding the "about 15 minutes" requirement of the regulations for notification of the public, NUREG-0654, Appendix 3 at 3-3 states:

The minimum acceptable design objectives for coverage by the system are:

a) Capability for providing both an alert signal and an informational or instructional message to the population on an area wide basis throughout the 10 mile EPZ, within 15 minutes.

b) The initial notification system will assure direct coverage of essentially 100% of the population within 5 mises of the site.

c) Special arrangements will be made to assure 100% coverage within 45 minutes of the population who may not have received the initial notification within the entire plume exposure EPZ.

Additional guidance criteria for assessing the adequacy of alert and notification systems are found in FEMA-REP-10 and FEMA GM AN-1.

The guidance documents also contain guidelines on siren sound levels to be used in the design of alert and notification systems. The acceptability of the VANS design sound levels is beyond the scope of my

staff visit to the VANS staging areas and acoustic locations, including the location with the longest route transit time.

The total elapsed time required to deploy and activate the VANS system is arrived at by summing the time estimated to complete the following tarks: (1) alert the operators,-(2) dispatch the vehicles from the staging areas, (3) travel from the staging areas to the acoustic locations, (4) setup the sirens at the acoustic locations, and (5) sound the sirens.

The Board already has determined that there is no genuine dispute involving Applicants' time estimates for alerting the operators, traveling from the staging location to the acoustic locations in non-snow conditions, and setting up and sounding the sirens. Thus, the only questions surrounding Applicants' time estimates to alert the public relate to the time required to dispatch the VANS vehicles and the travel time estimates for the VANS vehicles in snow conditions. The Board also had questions related to the time required for people within five miles of Seabrook to receive the information message broadcast over the EBS and the estimate of the total length of time for alerting and informing people within five miles of Seabrook.

Q13. Mr. Kantor, with respect to the time estimated to dispatch the VANS vehicle operator ' rom the staging locations to the acoustic locations

(" dispatch time"), the Board has inquired as to the appropriate conservative estimate of the length of time it would take for drivers to take the necessary actions before their vehicles leave their stations during conditions likely to prevail at the time of need. Does the Staff have a position regarding the appropriate conservative time estimate for dispatch of the VANS vehicles?

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A13. Yes. The Staff's position is that Applicants' design planning basis time of 50 seconds to dispatch the VANS vehicles from the staging areas appears I to be an appropriately conservative time estimate.

Q14. Please discuss the bases for this conclusion. -

A14 This conclusion is based on a review of Applicants' program for ensuring prompt response by the VANS operators to a notification to dispatch the VANS vehicles, and on the documented results of alert and dispatch tests. The Applicants' program includes the periodic training and annual re-qualification of each VANS operator, the requirement for the VANS operators to perform non-emergency (ongoing) procedural steps when on duty; periodic dispatch drills; continuous staffing of the VANS staging areas with one supervisor and twenty VANS operators for the sixteen primary VANS vehicles; the provision of supplemental and backup VANS operators and vehicles which ensures that the sixteen primary VANS operators (and vehicles) are not required to leave their duty station to perform any maintenance, testing or administrative functions; and a prioritized dispatch system for dispatching the first VANS vehicles to the furthest acoustic locations which provides a five minute margin in the event a driver is momentarily indisposed. The Vehicular Alert and Communication System (VANS) also assures prompt vehicle dispatching. Upon activation by the OR0 EOC Contact, the VANS automatically sounds audible alarms and activates visual alarms at the staging areas, and automatically opens the overhead doors at those staging areas where vehicles are stored indoors.

An additional conservatism in Applicants' program is that the VANS operators are notified by the OR0 EOC Contact and placed on standby

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, status at a Notification of Unusual Event, the lowest emergency classification. The VANS vehicles are dispatched to the acoustic l locations at an Alert or higher level emergency. Thus, except for very low probability events, the VANS operators will be alerted and standing by in anticipation of the dispatch signal. Even for these rare, low probability events, the design basis dispatch time of 50 seconds appears reasonable and achievable.

Q15. Mr. Kantor, with respect to travel time, the Board has stated that

"[g]iven that there is snowfall of 0.5 inches or more during 5.5% of the days of the year, would a conservative estimate of travel times to VANS acoustic locations include the somewhat prolonged travel times anticipated during snow conditions? If so, the Board has asked "what time estimates should be included?" Please address these questions.

A15 Applicants have evaluated the impact of snow conditions on VANS transit times. The results are presented in their prefiled testimony and in their September 17, 1988 filing to the Board. Appl 6. ants have utilized an adverse winter weather average speed reduction factor of 25% in their evacuation time estimate study for Seabrook. Applying this speed reduction factor to the average VANS transit times shows that winter adverse weather, which occurs about 5% of the time, could cause the design planning basis transit times (10 minutes to VL-01 to 15; 15 minutes to VL-16) to be exceeded by less than 1.5 minutes for seven of the sixteen acoustic locations. This delay is 10% or less of the overall 15 minute design objective and is considered to be a conservative estimate for the following reasons. The 25% speed reduction factor is applicable to evacuating traffic which consists primarily of passenger vehicles. It is expected that the VANS trucks with their wider wheel base, heavier weight, and dual mud and snow tires will be less affected by snou and ice a_ --- - - - , _ -

conditions than passenger vehicles. In addition, Actual route transit tests conducted by Applicants under icy road conditions indicate a speed reduction factor less than 25%, i.e., faster travel times.

In the Staff's view, Applicants have appropriately considered the potential impact of adverse weather conditions on the VANS transit times.

The Staff believes a 25% speed reduction factor, and the resulting pro-longed travel times, is a reasonably conservative estimate for planning purposes. Given the relatively minor impact of adverse weather on the VANS travel times, the relatively infrequent number of days on which adverse weather occurs, the dispatch of the VANS at the Alert level, and the unlikely need for immediate protective actions, the staff concludes that the VANS system meets the requirements of the regulations and the guidance criteria of NUREG-0654/ FEMA-REP-1 even under adverse weather conditions.

Q16. Mr. Kantor, the Board also inquired as to the estimated length of time it would take for people within five miles of Seabrook to receive the information message to be broadcast over the EBS. What is your response to this question?

A16. Applicants have described the process for broadcasting an EBS message in the event of an emergency at Seabrook. In accordance with the guidance in NUREG-0654, Appendix ?, a prompt notification scheme must include the capability for offsite officials to provide infonnation promptly over the air at the time of activation of the alert signal. The SPMC and associated implementing procedure provides that the informational message will be transmitted over the EBS concurrently with the alerting signal.

For events requiring immediate protective action reconsnendations, the New Hampshire Yankee Offsite Response Organization (NHY ORO) maintains

prerecorded messages at each EBS station. The Applicants have timed each message to determine the length of time necessary to deliver the message.

Each message has an approximate duration of two minutes. The initial message is played three times and subsequently repeated at 15 minute intervals. Specifically scripted informational messages may contain additional information that could extend the time necessary to deliver the message. However, as noted by Applicants, these messages would not be used for events requiring immediate protective action recommendations. In addition, public education program is in place to provide information to the public on an annual basis to tune to the EBS stations when the sirens are heard and on what actions to take in the event protective actions are necessary.

In my view, Applicants estimate of about two minutes to broadcast prerecorded EBS messages, concurrent with the alerting signal, for events requiring immediate protective actions is an appropriately reasonable time estimate for people within five miles of Seabrook to receive the information broadcast over the EBS. This approach meets the requirements of the regulations and is consistent with the practice at other nuclear power plant sites. The replay and subsequent repetition of the message assures that people who did not initially receive the message will be informed in a reasonably acceptable timeframe.

Q17. Mr. Kantor, the final issue which the Board determined to be in dispute is the estimated total time for alerting and informing people within five miles of Seabrook and whether that estimate is within acceptable guide-lines. What is the Staff's position on this issue?

A17. It is the Staff's position that Applicants have demonstrated that the administrative and physical means have been established for alerting and

. providing. prompt instructions to the public within the Massachusetts portion of the Seabrook EPZ. The time estimate for alerting and informing-people within five miles of Seabrook is within the "about 15 minutes" requirement of the regulations under both normal weather conditions (maximum value of 13 minutes 37 seconds) and adverse weather conditions (maximum value of 16 minutes and 28 seconds).

Q18. Please explain the bases for your answer.

A18. The bases for my response is my review of the information provided by Applicants in their testimony and other submittals as well as my review of the conclusions of FEMA in their evaluation of Applicants' FEMA-REP-10 Design Report, the SPMC and the June 7-9, 1988 exercise. Applicants have presented reasonably conservative estimates of the times required to alert the VANS operators, dispatch the VANS, travel to the acoustic locations, set up the sirens, sound the sirens, and, concurrently with siren activation, broadcast an EBS message. The summation of these times results in time estimates for alerting and notifying the public in the.

Massachusetts portion of the EPZ within 5 miles of Seabrook which are within acceptable NRC/ FEMA guidelines.

019. Mr. Kantor, does this complete your testimony?

A19. Yes, it does.

E FALK KANTOR EMERGENCY PREPARE 0 NESS BRANCH DIVISION OF RADIATION PROTECTION AND EMERGENCY PREPAREDNESS OFFICE OF NUCLEAR REACTOR REGULATION PROFESSIONAL QUALIFICATIONS I am employed as a Section Chief in the Emergency Preparedness Branch, Division of Radiation Protection and Emergency Preparedness, Office of Nuclear. Reactor Regulation, U.S. Nuclear Regulatory Commission. I have responsibility for supervising the review and evaluation of radiological emergency plans submitted by reactor applicants and licensees to ensure proposed plans meet the regulatory requirements and guidance of the Commission. I also function as a team member on emergency preparedness inspection teams engaged in the observation and evaluation of nuclear power plant emergency drills and exercises. 'I have been involved in the assessment of emergency planning and preparedness for nuclear power plants since March 1981.

I have been a member of the NRC (AEC) Staff since January 1973. From that time until June 1980 I held the position of Site Analyst in the Accident Analysis Branch. My duties included the review and evaluation of the radiological consequences of postulated design basis accidents, the effectiveness of pro-posed engineered safety features, the population density and growth character-

istics in the site environs, and the possible adverse effects on plant safety of nearby industrial, transportation and military facilities. From September 1980 until March 1981 I was a member of the NRC's onsite technical support section at the Three Mile Island facility. I have participated in the detailed review of over_ thirty nuclear power plant sites with the primary objective being to ensure public health and safety through the application of Commission regulatory requirements and guidance on reactor siting. I have presented testimony on siting and emergency preparedness issues at public hearings on the licensing of nuclear facilities, including Shoreham and Seabrook, and I have appeared before the Advisory Committee on Reactor Safeguards.

I entered graduate school in 1967 at the University of Pittsburgh on a U.S. Public Health Service Fellowship and received a MS degree in 1968 in Radiation Health (Health Physics). Following graduation I was employed by the NUS Corporation in Rockville, Maryland, and engineering and environmental  !

consulting organization. At NUS I was involved in the environmental aspects of siting both nuclear and fossil power plants.

In 1963, I began employment with the Westinghouse Electric Corporation at the Bettis Atomic Power Laboratory in Pittsburgh, Pennsylvania. My duties included the design of radiation shielding for nuclear power reactors for both landbased and shipboard applicants. I participated in field tests at Federal reactor facilities to evaluate the effectiveness of shield design features on operating reactors.

I received a BS degree in Industrial Engineering in 1958 from the Pennsylvania State University. Upon graduation I entered the U.S. Air Force where I  !

attended the Basic Meteorology Program at St. Louis University in St. Louis, l Missou ri . Following the completion of this program in 1959, I served as a l weather officer in the U.S. Air Force.

2 In addition to my formal education, I have attended training courses sponsored by the NRC on reactor systems and operation and emergency preparedness. In May of 1979 I attended the course titled " Planning for Nuclear Emergencies" at Harvard University and in September 1980 I participated in the Radiological Emergency Response Operations Training course at the Nevada Test Site.

I am a member of the Health Physics Society. I was a member for 25 years ' '

the National Guard and currently am a member of the U. S. Coast Guard Auxf lary.

I have contributed to the following NRC documents:

" Emergency Planning Input for Shoreham Nuclear Power Station", NUREG-0420, Supplement No. 10, May 1989.

" Director's Findings on Shoreham Emergency Planning Contentions",

April 7,1989.

" Final Director's Decision Under 10 CFR 2.206", Pilgrim Nuclear Power Station, December 29, 1988.

" Issuance of Extension to the Exemption to CFR Part 50, Appendix E,Section IV.F.3 for the Pilgraim Nuclear Power Station", May 11, 1988.

" Issuance of Exemption to 10 CFR Part 50, Appendix E, Section IV.F.3 for the Pilgrim Nuclear Power Station", December 9,1987.

" Director's Decision Pursuant to 10 CFR 2.206 for the Perry Nuclear Power Plant", dated September 14, 1987.

" Issuance of Exemption to 10 CFR Part 50, Appendix E, Section IV.F.2 for the North Anna Power Station", March 28, 1988. Exemption to conduct an exercise in 1987 granted based on licensee's response to SGTR event on July 15, 1987.

" Emergency Planning Input for the Humboldt Bay Power Plant, Unit No. 3 Decommissioning Safety Evaluation Report", letter to J.D. Shiffer, VP Nuclear Power Generation, PGE, April 29, 1987.

" Director's Decision Under 10 CFR 2.206 for San Onofre Nuclear Generating Station (Expansion of EPZ)", January 29, 1987.

" Emergency Planning Input for Grand Gulf Safety Evaluation Report".

December 12, 1986.

" Issuance of Exemption to 10 CRF Part 50, Appendix E,Section IV.F.2, Wolf Creek Generating Station", November 14, 1986.

" Issuance of Exemption to 10 CFR 50, Appendix E, Section IV.F.1 for the Perry Nuclear Power Plant", dated October 31, 1986.

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" Emergency Plan Input for the Nine Mile Point Nuclear Station, Unit No. 2, Safety Evaluation Report", NUREG-1047, dated February 1985. Supplement No. 3 dated July 1986.

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" Emergency Planning Input for the Seabrook Station Safety Evaluation Report",

NUREG-0896, Supplement No. 4, May 1986.

" Emergency Plan Input for the Hope Creek Generating Station Safety Evalution Report", dated October 10, 1984. Supplements dated June 19, 1985 and January 16, 1986.

Issuance of Exemption to 10 CFR 50, Appendix E, Section IV.F.1 for the Perry Nuclear Power Plant", dated December 11, 1985.

" Emergency Planning Input for the Millstone Nuclear Power Station, Unit No. 3, Safety Evaluation Report", NUREG-1031, Supplement No. 4., dated November 1985.

" Emergency Planning Input for the Perry Nuclear Power Plant Safety Evalu-ation Report," with P. D. Robinson, dated January 1984. Supplements dated January 1985 and September 1985.

" Director's Decision Under 10 CFR 2.206, Fermi-2", August 12, 1985.

"NRC Staff Response to Applicant's Motion for an Exemption from 10 CFR 50, Appendix E Section IV.F.1, for Limerick Generating Station. Affidavit dated July 11, 1985.

" Emergency Planning Input for the Fcrmi-2 Safety Evaluation Report".

NUREG-0798, Supplement No. 3 (January 1983), Supplement No. 5 (March 1985),

and Supplement 6 (July 1985).

" Final Director's Decision Under 10 CFR 2.206, Maine Yankee Atomic Power Plant", May 13, 1985.

" Emergency Planning Input to the Palo Verde Safety Evaluation Report".

NUREG-0857, Supplement No. 4, March 1983. Supplement No. 5 (November 1983),

Supplement No. 7 (December 1984), Supplement No. 8 (May 1985).

" Emergency Planning Input to the Wolf Creek Generating Station Safety Evaluation Report," NUREG-0881, Supplement No. 2. June 1983. Supplement No.4, December 1983, Supplement No. 5, March 1985.

" Emergency Exercise Exemption Review for Cooper Nuclear Station",

February 26, 1985.

" Emergency Preparedness Input For Waterford 3 Safety Evaluation Report (Exercise Exemption)", January 30, 1985.

" Emergency Planning Input for Safety Evaluation Report for Limerick Generating Station", NUREG-0991, October 1984.

" Emergency Planning Input for the Shoreham Nuclear Power Station Safety Evaluation Report", NUREG-0420, Supplement No. 7, September 1984.

" Director's Decision Under 10 CFR 2.206 for Three Mile Island Nuclear Station, Unit No.1," July 27,1984.

4 i " Inspection Report 50-/341/84-15 Emergency Preparedness Exercise, Enrico Fermi Atomic Power Plant, Unit No. 2", July 27,1984.

" Director's Decision Under 10 CFR 2.206 for the Enrico Fermi Atomic Plant, Unit No. 2", April 20, 1984.

" Inspection Report 50-341/83-24, Emergency Preparedness Appraisal, Enrico Fermi Atomic Power Plant, Unit No.2", November 28, 1983.

" Interim Director's Decision Under 10 CFR 2.206, Maine Yankee Atomic Power Station", September 30, 1983.

" Input for GPU vs B&W Lawsuit Review Safety Evaluation Report (TMI-2),"

September 1983.

" Inspection Report 50-213/81-14, Emergency Preparedness Appraisal, Haddam Neck Plant", Appraisal Team Leader, April 1982.

" Final Supplement to the Final Environmental Statement, Pilgrim Nuclear Station, Unit No. 2", May 1979. Contributor on Demography and Nearby Industrial, Transportation and Military Facilities.

"Seabrook Alternative Site Study, NRC Staff Testimony, Seabrook Station,"

before the Atomic Safety and Licensing Appeal Board, December 12, 1978.

Contributor on Design Basis Accident Analysis.

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.n UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 89 APR 26 P3 :28 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

.;i In the Matter of ) 00C"l' Docket Nos. 50-443 OL-01"'

PUBLIC SERVICE COMPANY OF 50-444 OL-01 NEWHAMPSHIRE,etal. On-site Emergency Planning

) and Safety Issues (Seabrook Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of the "NRC STAFF BRIEF REGARDING RELEVANCE OF DISCOMFORT," " TESTIMONY OF KENNETH M. ELDRED REGARDING BASIS A.1 0F MASSACHUSETTS ATTORNEY GENERAL'S AMENDED ALERT NOTIFICATION SYSTEM CONTENTION," and " TESTIMONY OF FALK KANTOR REGARDING BASIS A.5 0F l MASSACHUSETTS ATTORNEY GENERAL'S AMENDED ALERT NOTIFICATION SYSTEM CONTENTION" 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 Comission's internal mail system, or as indicated by double asterisks, by express mail, this 25th day of April 1989:

Peter B. Bloch, Chairman

• H. J. Flynn, Esq.

Administrative Judge Assistant General Counsel Atomic Safety and Licensing Board Federal Emergency Management Agency U.S. Nuclear Regulatory Comission 500 C Street, S.W.

Washington, DC 20555 Washington, DC 20472 Dr. Jerry Harbour

• Philip Ahrens, Esq.

Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Comission Stat.e House Station Washington, DC 20555 Augusta, ME 04333 Dr. Emeth A. Luebke** John Traficonte, Esq.**

Administrative Judge Stephen A. Jonas, Esq. '

4515 Willard Avenue Assistant Attorney General Chevy Chase, MD 20815 Office of the Attorney General One Ashburton Place,19th Floor Thomas G. Dignan, Jr. , Esq.** Boston, MA 02108 Robert K. Gad. III, Esq.

One International Place Geoffrey Huntington, Esq.

Boston, MA 02110-2624 Assistant Attorney General Office of the Attorney General 25 Capitol Street Concord, NH 03301 l

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~ Diane Curran, Esq.**

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Mrs. Anne E. Goodman; Chaiman

' Hannon, Curran & Tousley Board of Selectmen 2001 S. Street,'NW. 13-15 Newmarket' Road Suite 430 Durham, NH- 03824 In Washington, DC 20009 Hon. Gordon J. Humphrey Calvin A. Canney' United States Senate City Hall . .

531 Hart Senate Office Building 126 Daniel Street Washington, DC 20510 Portsmouth, NH 03801' Peter J. Matthews,' Mayor Allen Lampert- City Hall Civil Defense Director Newburyport,.NN 01950 Town of Brentwood

. 20 Franklin Michael'Santosuosso, Chairman Exeter, NH 03833 Board of Selectmen South Hampton, NH. 03827 William Armstrong Civil Defense Director' Ashod N. Amirian, Esq.

Town of Exeter Town Counsel for Merrimac 10 Front Street 145 South Main' Street' Exeter,'NH 03833 P.O. Box 38L Bradford, MA 01835 Gary W.-Holmes,.Esq.

Holmes & Ellis Robert A. Backus, Esq.**

47 Winnacunnet Road Backus,-.Meyer_& Solomon.

Hampton, NH 03842 116 Lowell Street Manchester, NH 03106 J. P. Nadeau

' Board of Selectmen Paul McEachern. Esq.

10 Central Street Shaines & McEachern Rye, NH 03870 25 Maplewood Avenue-P.O. Box 360 Judith H. Mizner, Esq, Portsmouth, NH 03801 79 State Street Newburyport, MA 01950 Charles P. Graham, Esq.

McKay, Murphy & Graham Robert Carrigg, Chairman 100 Main Street Board of Selectmen Amesbury, MA 01913 Town Office Atlantic Avenue William S. Lord-North Hampton, NH 03862 Board of Selectmen Town Hall - Friend Street

' Sandra Gavutis, Chairman Amesbury, MA 01913 Board of Selectman

- RFD #1, Box 1154 Kensington, NH 03827 R.. Scott Hill-Whilton, Esq.

Lagoulis, Clark, Hill-Whilton

& McGuire 79 State Street Newburyport, MA 01950

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Barbara J. Saint Andre, Esq. Ms. Suzanne Breiseth Kepelman & Paige, P.C. Board of Selectmen 77 Franklin Street Town of Hampton Falls j Boston, MA 02110 Drinkwatter Road )

Hampton Falls, NH 03844 '

Atomic _ Safety and Licensing Appeal Panel (5)* Docketing and Service Section* I U.S. Nuclear Regulatory Commission Office of_ the Secretary I Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 4 Atomic Safety and Licensing Board

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Panel (1)* j U.S. Nuclear Regulatory Commission i Washington, DC 20555 l

/ L Gregory Al2 1'3 erd t' Counsel for NRC S laff ('

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