ML20247F537
| ML20247F537 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/22/1989 |
| From: | Brock M MASSACHUSETTS, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#289-8668 OL, NUDOCS 8905300099 | |
| Download: ML20247F537 (19) | |
Text
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00CMETED U3NRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'89 !MY 25 P4 :01 ATOMIC SAFETY AND LICENSING BOARD Before the Administrative Judges:
Ivan W.
Smith, Chairman Dr. Richard F. Cole Kenneth A. McCollom I
)
In the Matter of
)
Docket Nos. 50-443-OL
)
50-444-OL PUBLIC SERVICE COMPANY
)
(Off-Site EP)
OF NEW HAMPSHIRE, _E T _A _L.
)
)
(Seabrook Station, Units 1 and 2)
)
May 22, 1989
)
RESPONSE OF THE MASS AG TO APPLICANTS' OBJECTION IN THE NATURE OF A MOTION IN LIMINE TO PORTIONS OF THE PREFILED TESTIMONf OF GEARY W.
SIKICH AND JOHN PAOLILLO REGARDING TOH/NECNP EX-1 A& B Citing limited sections from contention TOH/NECNP Ex 1(a) and (b)
(" contention"), Applicants move to exclude certain testimony
(" testimony") proferred by Mass AG concerning the failure of the June 28 & 29, 1988 Exercise to meaningfully test protective action ("PA") procedures for New Hampshire school children.1!
In their motion, Applicants concede that the testimony on the failure of the Exercice to test PA procedures for schools is relevant to the admitted contention, to the extent the testimony concerns the inadequate demonstration by 1
1/
This disputed testimony includes portions proferred by witnesses Sikich and Paolillo, as well as depositions and i
statements provided by school superintendents and the Phillips Exeter Academy Dean concerning the extent of participation by certain schools and school personnel in the Exercise.
See l
Applicants' Motion, pp. 4-5.
I 8905300099 890522 s})563 l
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' school teachers of PA procedures for school children.
Motion
- p. 2.
To the extent the testimony concerns the failure of the Exercise to test PA procedures that also involve school administrators, Applicants seek exclusion of the testimony alleging 1) the testimony is irrelevant to the contention and
- 2) certain statements of school superintendents and the Phillips Exeter Academy Dean concerning participation by school personnel in the Exercise, although substantially confirmed by Applicants' own admissions g.iven in discovery, are not reliable.
Applicants' motion is groundless and should be DENIED.
I.
The Testimony is relevant.
Applicants complain that the disputed testimo,ny, on the failure of the Exercise to fairly test protective action procedures involving school personnel in addition to teachers, is not expressly raised in the contention bases and therefore is outside the scope of the admitted contention.2/
The Appeal Board recently reaffirmed that a contention basis providing " reasonable specificity" is adequate to raise an issue for litigation:
[a]n adequate basis assures that the contention raises a matter appropriate for litigation in the proceeding, establishes a sufficient foundation for the contention to warrant further inquiry into the subject matter addressed by the allegations, and puts the other parties sufficiently on notice so that they will know at least generally what they will have to defend against or oppose.
Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1), ALAB-903, 28 NRC 499, 506 (1988) quoting 2/
A copy of TOH/NECNP Ex 1(a) and (b) is Attachment 2 to the testimony. _ - _ _ _ _ _ _ _ _ _ _
h.
o L
Licensing Board prehearing conference order.
(Emphasis supplied.)
It is undisputed that an adequate demonstration of PA procedures for schools must be provided by a pre-license l
exercise, ALAB-900, 28 NRC at p. 297, and that Applicants agree i
that the contention at issue fairly raised the issue of PA procedures for schools, at least involving school teachers.
Supra.
By their motion, Applicants thereby suggest that the contention bases lacked the requisite specifity to place Applicants on notice as to the issue of PA procedures involving school personnel in addition to teachers.
That assertion is not credible.
As is apparent from the generic school plan for each New Hampshire school, see NHRERP individual town plans at Appendix F, ! and as described by Applicants themselves in rebuttal testimony, "(w)ithin each SAU (public school administrative unit) and private school, there is an internal emergency operations procedure."$/
Applicants continue:
. The administrative structure, therefore, provides that a decision regarding school protective actions is made by the superintendent or facility administrator who, in turn, directs
-its implementation.
. teachers are expected to take direction from their administrative supervisors and to provide direction and control of their students.
Id. at p.53.
3/
A representative copy of public, private, and day-care schoci plans is contained in Attachment 5 to the testimony.
4/
See APPLICANTS' REBUTTAL TESTIMONY NO. 23 REGARDING SCOPE OF GRADED EXERCISE, dated April 18, 1989 at p.52. - _ _ _ - _ _ _ _ - _ _ _ _ - - _ _ _ _ - - _ -
I The NHRERP therefore clearly contemplates an integrated PA procedure within each' school to fairly test,whereby teachers take i
direction from school administrators.in the implementation of PA
-procedures for students.
It'is therefore nonsensical to_suggest that it is appropriate, or even:possible, to litigate whether school teachers,.but not-
~
school administrators, demonstrated the " organizational ability;or resources necessary to effect an early dismissal, sheltering, or.
evacuation of the-school children" in the Exercise, TOH/NECNP Ex
'1(b),-when,1under.the'NHRERP, the'" organizational ability" for teachers'necessarily includes: communication and coordination ~with their school administrative personnel.
In. addition, Applicants' complaint of inadequate notice in the contention.concerning school administrators is refuted by.the express' language of Contention Basis B.-
Although omitted in Applicants motion,' Basis B concludes:
Failure.to observe or test necessary personnel or procedures to protect students represents a fundamental flaw in the NHRERP.
On its face, this allegation is sufficient to support admission of the testimony concerning the exercise of PA procedures involving both school teachers and administrators.
-Of equal significance, by way of example Basis B expressly references pages F. 1-3, F.
1-4, of Appendix F, NHRERP Vol~.-
18A. /
The cited pages set forth PA procedures involving Hampton school personnel, primarily concerning the superintendent and principal, to be followed under certain emergency conditions.
i 5/
These cited pages are attached as Exhibit 1.
_4_
a
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'y 76 By.expressLreference, plan citation, and the basic-estructureLof the NHRERP that contemplates communication and y
coordination among all school personnel to implement 1 pas for school children, the entire testimony, therefore, is directly relevant t'o issues' fairly raised in the admitted contention.b!
II.
The Testimony is Reliable, v'
Applicants lalso seekLexlusion of statements provided by 3:
)
i of 5'public school. superintendents and the Dean of the Phil'11ps.
Exeter Academy on grounds these statements are unreliable n
' hearsay.: Motion pp. 4-5.
In substance, these statements: concern the extent of participation by the. superintendents and the Dean, their y
staffs,.and those schools under their jurisdictions, in the-e 6/
Applicants also allege that "TOH/NECNPLdefined the bases, In the face of Applicants' and Staff's objections.to their admission," so as to limit the bases to testimony involving school teachers, but not school administrators, involving PA
. procedures for school children.
As referenced above, such a division cannot be rationally. supported in view of'the NHRERP integrated PA procedures for coordination among all school personnel.
Applicants also fail to point out that, while admission of'the contention bases were indeed challenged by Applicants and Staff, neither ever argued, or sought to limit the bases, to preclude litigation involving PA procedures of school administrators, as distinct from school teachers.
TOH/NECNP, therefore, met the arguments and only those arguments,.then presented by Applicants and Staff.
For
? Applicants 1 to suggest this as a limitation for testimony on
' issues otherwise fairly raised in the bases is inaccurate, and apparently confuses arguments over contention admissibility with a discovery response seeking to explore the limits of an admitted contention.
In this case, however, Applicants sought no discovery on TOH/NECNP Ex 1(a) and (b), although Interveners specifically did seek discovery, without objection, on the
-involvement of school personnel other than teachers in the Exercise.
See Attachment 6, Global pp. 74-86 of Testimony attachments.
Applicants therefore had clear notice of Mass AG's intent to litigate issues concerning school personnel other than teachers....
,_m__.
'n 6 N
- (
Exercise.
A review of these' statements indicates that Superintendents Katner, Clancy, and Joyce and Dean Tucker did g
not personally participate in the Exercise.
In summary, these school officals, having conferred with their staffs,_ state that during'the Exercise each 'AU office received at least one phone S
call from New Hampshire emergency officials, and that to the declarants' knowledge, no action was requested or taken in response.to the: calls.
See Sikich/Paolillo Testimony pp. 15-17.
Applicants do not dispute any of the specific facts I
contained'in the statements.
Applicants rather complain they will be denied the. opportunity to fairly test the reliability of the statements.
Motion p.
5.
In their motion, Applicants neglect to point out that I
certain primary facts attested to by the school _ officials were 1
substantially confirmed by Applicants in discovery responses to Interveners.
For, example, as quoted at page 17 of the Sikich/Paolillo testimony, the only specific participation of school personnel in the Exercise, as identified by Applicants for each SAU and Phillips Exeter Academy by Applicants themselves, is that:
Administrative representatives (of the five Supervisory Administrative Units and an administrative representative of the Phillips Exeter Academy) received at least one telephone call from New Hampshire emergenc/ response personnel during the Exercise.
2estimony p.
17.
l See also Attachment 6 to Testimony.7/
{
7/
The complete response to Intetvenors' Interrogatory by l
Applicants is set forth in Attachment 6, Interrogatory 2(a).
I _ _ _ _ _ _ - _ _ _ _ - - _ - _ _ _ _ -
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- Applicants also confirm the suggestion of the superintendents that no teachers: participated in the Exercise.,
" Interrogatory 1.
~0f equal significance, the State of New Hampshire has adopted,.and confirmed, these admissions by Applicants'.
Attachments 7, Global pp. 87-94.
Finally, those statements, challenged as unreliable, are E
substantially consistent with accounts provided by Superintendents Monahan and Durgin, concerning the limited participation of'SAUs in the Exercise.S!
Indeed,.the independent' statements of all five school superintendents are consistent: concerning the limited telephone " participation". of SAUs in the Exercise, and further support the reliability of the statements.
The basic reliability of the statements of the superintendents have therefore been repeatedly established.
To the extent the statements provide greater detail, such as to whom at each SAU may have received the Exercise call, that fact might impact on the weight this Board wishes to give those i
limited sections of testimony.
However, given the independent confirmation in the record of the superintendents' basic testimony' involving limited telephone " participation" by SAUs, and,the fact.that the " double hearsay" objection by Applicants 4
primarily concerns SAU staff comments provided to their Superintendents in response to direct inquiry, there is
.8/
Applicants have not challenged the reliability of the statements provided by Monahan and Durgin.
Motion p.
- 5.. _ _ _ - _ - _ _ _ _ - _ - _ - _ _ - -
\\
-reasonable' support'for the reliability as to these double
-hearsay details on SAU part'icipation.
In any event, the basic thrust of the testimony by.the Superintendents on limited SAU m,.
participation has not been challenged by any witness or party in this proceeding.
Finally, the. statements of the superintendents, reflecting their-knowledge.of actions and exercise events, have i
independent relevance on whether PA procedures for schools were a'dequately demonstrated in the Exercise.
Under the NHRERP, l
theseisuperintendents are personally charged with oversight of the PA process <for public schools within their respective jurisdictions.
See Applicants' Rebuttal Testimony No. 23.
The extent to which each of these individuals did or did not I
participate in the Exercise is directly relevant in evaluating-l the adequacy of the PA performance.
Applicants' Motion should be DENIED.
COMMONWEALTH OF MASSACHUSETTS JAMES M. SHANNON ATTORNEY GENERAL l
=Q Matthew T. Brock I
Assistant Attorney General Nuclear Safety Unit Department of the Attorney General One Ashburton Place Boston, MA 02108-1698 (617) 727-2200 DATED:
May.22, 1989 3
. - - _ - ___O
- e.
EXHIBIT 1 m
.s:
l III. EMERGENCY RESPONSE PROCEDURES 1
Note Time A.
Receive notification from the Superintendent of Schools via telephone of an energency declaration and any pertinent infortnation. This call will also be made by the Hanpton Public Works Director.
Provide the student attendance for the. day.
8.
If the tons-activated radio is the first notifi-cation of an energency condition, contact the Hanpton Public Works Director at for further information. The tone-activated radio normally serves as back-up notification and is.
automatically activated as part of the public alerting systen.
C.
Depending-on the Emergency Classification Level, take action as follows:
1.
UNUSUAL EVENT - No notification. No action required.
2.
ALERT - School will be notified. No action l2 required unless directed. Stand By.
Superintendent may' order school cancellation via normal procedures as a precautionary measure.
Vol.'18 F.1-3 Rev. 2 8/86 l
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_f Nota Time 3.
~ SITE AREA EMERGENCY or. GENERAL EMERGENCY' a.
School in Session. School'will be noti-7-
fled and may be directed to undertake'a protective response such as early dis-
[
missal, sheltering or evacuation.
p'
' +
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b.
School-Not in Session. The Principal willnbe notified. The Superintendent of Schools will determine if school should M
.be cancelled as a precautionary measure and notify the Principal.
.(
E.-
Turn on AM/FM redio to WOKQ f,97.5 FM).
(If reception i
is poor, tune'to one of the additional stations listed in AppendixA.)- Additional. infortnation may then be obtained through. messages over the Eriergency Broadcast Systern -(if activated).
p F.
Sheltering.
If Hampton, the Superintendent or the Emergency Broadcast System announces that sheltering has been recornnended, than 1.
Class all windows and doors.
2.
Turn off all ventilation systerns using outside air (i.e., fans, air conditioning, etc.).
3.
Renain indoors. The gynnasitm and cafeteria p
have been designated as the sheltering area for L
Winnacunnet High School.
1 Vol. 18 F.1-4 Rev. 2 8/86 t
.e EXHIBIT 2 May 5, 1989
-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the QC.Cf fCD 4
ATOMIC SAFETY AND LICENSING BOARD
- g. 0 81989 NUCLLAR EAFEi/ UNIT
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL NEW KAMPSHIRE, et al.
)
'50-444-OL
)
(Seabrook Station, Units 1 and 2)
)
(Off-site Emergency
)
Planning Issues)
)
APPLICANTS' SUPPLEMENTMY RESPONSE TO INTERVENERS' DISCOVERY REOUESTS Pursuant to 10 C.F.R. 5 2.740(e), Applicants supplement their. responses by amending their answers to the " Town of i
I Hampton ("TOH"] First Set of Interrogatories and Request for I
the Production of Documents to the Applicants on the June 28-29, 1988 Exercise (" Exercise")" and the Massachusetts Attorney General's (" Mass AG"] request for Documents and Information on the Exercise, l
1.
Applicants' Supplementary Response to TOH's Informal Discovery Requests of December 23, 1988 on the June 28-29, 1988 Exercise.
Interrogatory No. 2 Identify all administrators and school personnel other than teachers who performed or participated in protective actions for school children during the Exercise.
For each, state f
l
_g (a)
The nature and extent of the participation or function performed; (b)
.The school (s) for which'edch administrator and school personnel performed or participated; Applicants' Responsq Applicants'-response to Interrogatory No. 2 of January.9, 1989 incorrectly' identified George Tucker, Dean of Faculty, Phillips Exeter Academy as a school' official who was contacted during the June 28-29, 1988 Exercise.
Further review of player'and controller information indicates that Mr. Tucker was not contacted.. A telephone call was made to Phillips Exeter' Academy by Town of Exeter officials.
No administrative representative of Phillips Exeter Academy could be contacted.
2.
Applicants' supplementary Response to M'ss AG's Request a
of March 10, 1989 for Documents and Information on the Exercise.
Reauest No. 11 Please. describe what set of ETEs were used in the METPAC model during the Exercise and why that set was used.
Anolicants' Resnonse Applicants' response to Request No. 11 of March 24, 1989 incorrectly stated that the'ETE values listed on Table 5.2.2 of YAEC Report 1618.were derived from a 1983 ETE study which was litigated as part.of the onsite proceedings.
The ETE values on Table 5.2.2 were derived from an evacuation time study, dated January, 1984, prepared by Costello, Lamasney and de Napoli, Inc. in association with C. E. Maguire, Inc. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
~
MAY-e5-1999 13:10 FROM NH YARXEE E-PLAN TO P.82
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As to answers:
Ted C. FeigenDeum vice President - Erwiineering Quality Programs and Licens;,ng New Hampshire Yankee Division of Public service Company of New Hampshire May'5, 1989 State.of New Hampshire Rockingham County, as Then personally appeared before as the above-subscribed Ted C. Feigenbaum and made oath that he is the Vice President
- Engineering Quality Programs and Licensing, New Hampshira Yankee Division,. authorized to execute the foregoing supplemental responses to interrogatories on behalf of the Applicants, and that he made inquiry and believes that the foregoing responses accurately set forth information as is available to the Applicants.
Eefore me,
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.A ciwamA M h g My commission' Expires As to objections and responses to requests for p odudticiit. hf.I.I
.ocu.ent.,
- ".:ve: m Kathryn A. Selleck Jeffrey F. Trout Jay Bradford saith Geoffrey C. Cook Ropes & Gray one International Place Boston, MA 02110 (017) 951-7000 cotfNSEL FOR AFFLICANTS ocruom.ps
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CERTIFICATE OF SERVICE I,~Geoffrey C. Cookh one of the attorneys for the Applicants-l
. herein, hereby certify.that on May 5, 1989, I made service of the within document by depositing copies thereof with Federal
.i Express, prepaid, for delivery to (or, where indicated, by 1
depositing in the United States mail, first class postage paid, addressed to):
Administrative Judge Ivan W.' Smith Adjudicatory File Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Board
. Board Panel: Docket (2 copies)
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, 90) 20814 Administrative Judge Richard F. Cole Robert R. Pierce, Esquire
. Atomic' Safety and-Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board East West, Towers Building U.S. Nuclear Regulatory 4350. East West Highway Commission j
- Bethesda, MD 20814 East West Towers Building 4350 East West Highway Betheeda, MD 20814 Administrative Judge Kenneth A.
Sherwin E. Turk, Esquire McCollom Office of General Counsel 1107 West Knapp Street-U.S. Nuclear Regulatory Stillwater, OK 74075 Commission one White Flint North, 15th Fl.
11555-Rockville Pike Rockville, MD 20852 i
John P. Arnold, Esquire Diane Curran, Esquire
-Attorney General Andrea C. Forster, Esquire George: Dana Bisbee, Esquire Harmon, Curran & Tousley Assistant Attorney General Suite 430 Office of the Attorney General 2001 S Street, N.W.
125 Capitol Street Washington, DC 20009 Concord, NM 03301-6397
- Atomic Safety and Licensing Robert A. Backus,-Esquire l
Appeal Board.
116 Lowell Street U.S. Nuclear Regulatory P. O.
Box 516
-Commission Manchester, NH 03105 Washington, DC 20555 f
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Il 's.
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Philip Ahrens, Esquire Mr. J. P. Nadeau Assistant Attorney General Selectman'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 25'Maplewood Avenue Department of the Attorney P.O.
Box 360 General Portsmouth, NH 03801 One Ashburton Place, 19th F1.
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 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
- 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. Thomas F. Powers, III Mr. William S.
Lord
~
Town Manager Board of Salactman 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 Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03842 concord, NH 03301 - _ _ _ ~_ - ____- -__-
.l.-
Mr. : Richard R. Donovan Judith H. Mizner, Esquire Federal Emergency Management 79 State Street, 2nd Floor Agency-'
Newburyport, MA 01950 Federal Regional Center 130 228th Street, S.W.
Bothell, Washington 98021-9796 Ashod N. Amirian, Esquire' 145 South Main Street P.O. Box 38 Bradford, MA 01835 M
C Geoffr g C/ Cook
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' UNITED. STATES.OF AMERICA
,j, NUCLEAR-REGULATORY COMMISSIONS
.g. NY 25 ~ P 4101 iATOMIC' SAFETY AND'-LICENSING BOARD
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'e Before-.the Administrative Judges:
DOLnt M i6 ' in E R A!C Ivan W. Smith, Chairman-
< 6 ri Dr.: Richard'F. Cole E
Kenneth A. McCollom'
- r.,,
.).'
p#
-In the1 Matter of.
)
Docket Nos'. 50-443-OLL
- g..
-)
50-444-OL'
' ^
PUBLIC' SERVICE' COMPANY
)
(Off-Site EP)
OF,NEW HAMPSHIRE, ET AL.
)
)'
L(Seabrook~ Station, Units 1.and 2)
.)
May 22,'1989 n
)
CERTIFICATE OF SERVICE
- I, Matthew T; Brock, herdy certify.that on May 22, 1989, I 2"
made' service"ofethe'within RESPONSE OF'THE MASS'AG TO APPLICANTS' iOBJECTION~IN THE NATURE OF A MOTION'IN LIMINE TO PORTIONS OF THE PREFILED. TESTIMONY OF GEARY W. SIKICH AND JOHN PAOLILLO REGARDING 1
-TOH/NECNP-EX-1.A& B by'first class mail.to:
i o
'Ivan W. 5mith, Chairman.
Kenneth A.'McCollom
-AtomiciSafety.& Licensing Board
-1107 W. Knapp St.
U.S.-Nuclear Regulatory Stillwater, OK 74075 Commissions TEast~ West, Towers; Building Docketing and Service
'4350L. East West Highway U.S. Nuclear Regulatory Bethesda, MD 20814 Commission Washington, DC 20555 Dr. Richard F. Cole Atomic' safety &: Licensing Board lU.S.--Nuclear Regulatory Commission LEast West Towers-Building 4350 EasttWest Highway-Bethesda, MD 20814 J
L_ :__- -
_2_
_L._----_---_-_-___-.__-.
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e Robert R. Pierce, Esq.
Thomas G. Dignan, Jr.,
E39 Atomic Safety & Licensing Board Katherine Selleck, Esq.
L U.S. Nuclear Regulatory Commission Ropes & Gray East West Towers Building One International Place 4350 East West Highway Betnesda, MD 20814 '
Boston, MA 02110 H. Joseph Flynn, Esq.
Sherwin E. Turk, Esq.
Assistant General Counsel U.S. Nuclear Regulatory Office of General Counsel Commission Federal-Emergency Management Office of the General Counsel i
Agency 15th Floor j
500 C Street, S.W.
11555 Rockville Pike Washington, DC 20472-Rockville, MD 20852 i
Atomic Safety & Licensing Robert A..Backus, Esq.
Appeal Board Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street i
Commission j
P.O. Box 516 Washington, DC 20555 1
Manchester, NH 03106 Atomic Safety & Licensing Boaro Jane Doughty U'.S.. Nuclear Regulatory Commission Seacoast Anti-Pollution League Washington, DC 20555 5 Market Street Portsmouth, NH 03801 Charles P. Graham, Esq.
Barbara St. Andre, Esq.
Murphy & Graham Kopelman & Paige, P.C.
33 Low Street 77 Franklin Street Newburyport, MA 01950 Boston, MA 02110 Judith H. Mizner, Esq.
R. Scott Hill-Whilton, Esq.
79 State Street Lagoulis, Hill-Whilton 2nd Floor
& Rotondi Newburyport, MA 01950 79 State Street Newburyport, MA 01950 Dianne Curran, Esq.
Ashod N. Amirian, Esq.
Harmon, Curran, & Towsley 145 South Main Street Suite 430 P.O. Box 38 2001 S Street, N.W.
Bradford, MA 01835 Washington, DC 20008 Senator Gordon J. Humphrey Senator Gordor. J.
Humphrey U.S.
Senate One Eagle Square, Suite 507 Washington, DC 20510 Concord, NH 03301 (Attn: Tom Burack)
(Attn: Herb Boynton) 1 I
yy,
- p. 3. -
l-
' John'P.1 Arnold,-Attorney General Phillip Ahrens, Esq.
Office of the Attorney. General Assistant Attorney General 25 Capitol Street Department of the Attorney Concord, NH 03301 General l
Augusta, ME 04333 William S. Lord Board of Selectmen Richard Donovan Town Hall - Friend Street FEMA Region 10 Amesbury, 104.01913 130 228th. Street, S.W.
Federal Regional Center i
Bothell, WA 98021-9796 COMMONWEALTH OF MASSACHUSETTS JAMES M. SHANNON ATTORNEY GENERAL Matthew T.
BYbck Assistant Attorney General Nuclear Safety Unit Department of the Attorney General One Ashburton Place Boston, MA 02108-1698 (617) 727-2200
.l
. DATED:
May.22, 1989 s
. x:_____-__-__.
_ _ _ - _