ML19332D544
| ML19332D544 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/14/1989 |
| From: | Gram G PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | |
| Shared Package | |
| ML19332D520 | List: |
| References | |
| OL, NUDOCS 8912040122 | |
| Download: ML19332D544 (20) | |
Text
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November 14, 1989 l UNITED STATES OF AMERICA ,
NUCLEAR REGULATORY COMMISSION j be. fore the ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of )
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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL-1 NEW HAMPSHIRE, et al. ) 50-444-OL-1 >
) (Offsite Emergency (Seabrook Station, Units 1 and 2 ) Planning and Safety >
') Issues)
)
AFFIDAVIT OF GEORGE R. GRAM I,-George R. Gram, being on oath, depose and say:
- 1. I am Executive Director, Emergency Preparedness and Community Relations, New Hampshire Yankee. As such, I am responsible for
- all emergency preparedness planning and implementation associated with Seabrook Station. A statement of my professienal qualifications is a matter of record in this proceeding.
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'2. New Hampshire Yankee recently received correspondence from Douglas J. Rowe, Co-Chairman, Massachusetts Emergency Broadcast system, and John F. Bassett, Manhger, WCGY-FM, Lawrence, L Massachusetts, dated October 13, 1989, and October 20, 1989, i
respectively'(attached as "A"). The correspondence references a l: 9912040122 891115 PDR ADOCK 05000443 1 g PDR -
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i previous letter of agreement, dated September 14, 1987, between New -
Hampshire Yankee and the Massachusetts Emergeracy Broadcast System l in which New Hampshire Yankee agreed to provide certain services !
and equipment for the planning and implementation of an alertia.,
system in support of the New Hampshire Yankee Offsite Response !
Organization (ORO). .
- 3. In the aforementioned correspondence, Masrs. Rowe and Bassett state that they are terminating their letters of agreement with I nan Hampshire Yankee because New Hampshire Yankee has not provided the equipment indicated in the September 14, 1987, letter of agreement with the Massachusetts Emergency Broadcast System.
- 4. In July, 1987, I was appointed project Director of Massachusetts emergency planning for New Hampshire Yankee. The project entailed development and implementation of a utility ,
sponsored emergency response organization and program for that portion of the Seabrook Station emergency planning zone situated in Massachusetts.
- 5. At that time, negotiations were underway with WLYT/WHAV, Haverhill, Massachusettc, to have them provide emergency information to the Massachusetts portion of the Seabrook Station EPZ. New Hampshire Yankee agreed to equip WLYT/WHAV for. this ;
purpose, and a commitment letter was signed by the management of WLYT/ WHA \ an August 12, 1987, l
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- 6. In developing the Seabrook Plan for Massachusetts Communities, .
New Hampshire Yankee pursued a " defense in depth" strategy to ;
assure that backup mechanisms were available to implement the plan.
Pursuant to this strategy, discussions were held in the summer of 1987 with Mr. Rowe, who represented the Massachusetts Emergency Broadcast System. Mr. Rowe expressed to New Hampshire Yankee his interest in upgrading the existing capability of the Massachusetts Emergency Broadcast System. WCGY, Lawrence, Massachusetts, was then, as it is now, the Common Program control Station (CPCS-1) or ,
gateway station in the Merrimack Valley Operational Area of the ,
Massachusetts Emergency Broadcast System. Mr. Rowe informed New Hampshire Yankee that WCGY r(quired adoitional equipment in order to allow activation directly by the ORO in a manner similar to that used with WLYT/WHAV.
- 7. At that time, New Hampshire Yankee agreed to further discuss upgrading all of the existing Massachusetts Emergency Broadcast System r.tations in the Merrimack Valley Operational Area. However, in order to establish a backup means for issuing emergency information to the Massachusetc. comrunities within the Seabrook
_ Station EPZ, New Hampshire Yankee agreed to evaluate and to upgrade the capability of only WCGY to serve as the backup station in
(- support of the Seabrook Plan for Massachusetts Communities- New Hampshire Yankee made this agreement with Mr. Rowe in his role as Co-Chairman of the Massachusetts Emergency Broadcast System. In the letter of agreement with Mr. Rowe dated September 14,1987, New Hampshira Yankee agreed to provide certain items of equipment to '
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I upgrade the capability of tiCGY, enabling WCGY to serve as a backup EBS station to WLYT/WHAV, and in fact some of the equipment w&s installed and has been maintained by NNY (See 1.ffidavit of Gary J.
- r catapano.at paragraph 6).
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- 8. Prior. to axecuting the letter of agreement with Mr. Rowe, New Hampshire Yankee advised him of the backup role contemplated for WCGY.
- 9. New Hampshire Yankee maintains its commitment to upgrade WCGY's equipment (consistent with its role in the Massachusetts EBS operational Plan) to the level outlined in the September 14, 1987
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letter of agroement with Mr. Rowe. On October 26, 1989, New Hampshire Yankee advised Mr. Bassett of its intention to honor this commitment (attached as "B").
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November 14, 1989 The above-subscrioed George R. Gram appeared before me and made oath that he had read the foregoing affidsvit and thet the statements set forth therein are true to the best of his knowledge. 1 Befort me, I JL St<.la.4) toa Notary Public My commission Expires:
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-e. Great Radio .
P.O. Box 566 48 Fachburg St . Marlboro, Massachusetts 01752 - . :(508)485 1470
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October 13, 1989 Et
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Mr. R. Boyd, Jr.
s 888 Performance Services Maneger '
F eql P. O. Box 300-
, Seabrook, NH 038*'1
>e n t Mr. Boyd:
I i Your Ictter of September 20, 1 9119 , in not accurate! It attempts to describe a mcoting br twr :n on. If you will recall, at the end of that meeting there was no spirit of cooperation. -[
6 I said to you that as Co-Chairman of the EDS Systems in .
Massachusetts, 14, _1987.
I was going to withdraw my letter of September In fact, a copy of the letter 1 intended to send you vas FAX'D to'you on Septrmbr'r 20th qivinq you the further ,
opportunity to review the commitment made by Mr. Tnomas.
After telephone calls and a request by N . ll . Y . to delay the withdrawal, I agreed. It was understood that the reason
-for the delay was N.H.Y. .:as to submit a retised commitment.
Year plan as submitted to NRC includes the EBS System.
You now say, and I quote, "IF the Morrimac Valloy E.B.S. -
Network is,utiliced."
. I still remember the days of N.ll.Y. ast:ing Mr. Bassett of WCGY and myself to sign, " quick instant" drewn agreements with the intent of complying with FEMA requirements. My recollection
-vas tnat the FEMA regulations recuire nuclear plants to cooperate with and be integrated with the E.B.S. System. As I
-tried to tell you at our mcoting, there was an intent to put ,
Massachusetts residents on equal rootinq with New llampshire residents. Mr. Ca ta pa no assured me- that he wou t ri i n.s ta l l a system in the-Merrimae Valley con n i n t.a n t. with the .iyu tem described la'cr in the a ttached letter. ,
., my dishprointment, the CPCS-1 statica WCGY "the gateway" to b Massachusetts, has not received the committed equipment or services, not to mer.tlon the other stations of the Merrimac ,
Valley. Your selection of WLYT as a source to activate specific receivers is-voll intentioned and commrindable, but does not activate the E.B.S. System.
Serving the Amvent Swuroon Morbet Beween Boston one Wor: ester 24 Hours e Ocv
Your letter! indicates a total lack of understanding of the E.B.S. '
System. WIYT does NOT trigger a notification to the general public. It triggers only YOUR system. She many radio stations serving the general public would redeive NO notice. Your idea '
that the media would decend on your media center is perhaps accurate,-but FEMA and the E.B.S. System do not work by press release. FEMA regulations involve agreements with CPCS-1 stations and coordination with state emergency E.B.S. chairmen. I suggest you review the regulations. ,
My most disappointing. thought about your letter is that you say that N.H.Y.'s commitment concerning Public Notifica?lon was negotiated. Can you please tell me when, where and who negotiated away the rights of the general public ?
As you can read from the' attached copy, which was previously FAX'D to you, I said that I had reviewed your plans and determined that N.!!.Y. was a " recognized responsible" organization. In view of the apparent change in attitude of the operators of N.H Y., I now formally submit withdrawal authorization, dated September 20, 1989, and I am sending a copy of this communication to the CPCS-1 station WCGY.
very truly yours, ser_. .A Douglas J/ Rowe Co-Chairman Massachusetts Emergency Broadcast System ATTACHMENTS A. Letter of withdrawal 9/20/89 B. Co-Chairmans EBS letter 9/14/87 C. WCGY letter 9/14/87 D. All CommSystem Plan & Letter dated 11/14/88 E. N.H.Y. letter'9/29/89 cc: WCGY
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... Great Radio P.O. Box $66 48 Fitchburg SL e Marlboro, Manachuseu 01752 + (508)485-1470
% 20 September 1989 h Mr. Michael Lewis Emergency Preparedness / Resource Supervisor g/ j-New Hampshire Yankee 58, Post Office Box 300 .
8l4 Seabrook, New Hampshire 03874 #
Dear Mr. Lewis Pursuant to our meeting today I, as Co-Chairman of the Massachusetts Emergency Broadcast System h e'r e b y revoke my letter of 14 September 1987, i..iw Hampshire Yankee has, regretfully, refused to honc. the terms and conditions of that letter of agreement.
It has been two years since the letter was te;r.ared and the E.B.S. stations of Merrimac Valley have not received the promised cooperation. The limited equipment installed has not fulfilled commitments ,
made, oral or written, j Sincerely, l
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Douglas J. Rowe Co-Chairman Massardosetts Emeregency .;
Broadcast S; st em Enc 1: Agreement 14 September 1987 l
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! Sevn; the Af'.aent Sucu re: . Mer.et se%een Boston en: Worcester 24 ~ours : Dev c !
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The Messachusetts Emsfgency Broadcast $gstem is !
Committed to responding to eng e,mergency that meg effect residents , .
, of Messachusetts. The Emergency Broadcast $gstem is a voluntary .
ergenizetten authertred by and created by the Federal Communications Commission, its primary function is to alert the public in the event of s Presidential Declaration of Emergeneg; most specifielg nucieer attack. But the authority to use the EBS has been ;
delegated down to the individuel licensee which must use its :
" independent distration and responsibility ".
The Messachusetts Emergency Broadcast System would ,
recognize eseg responsible iscal business or ergenizetten that meg be responsible for creating er reporting a local emergency.
After review of New Hampshire Yonkee's Offsite Response Organization and determining that en incident et New Hampshire Yankee could effect Messoche.:stts residents and that activation of the EBS could mitigste the effects caused by en incident the New Hampshire Yankee Offsite Response Orgentretion is recogonized as a responsible local ergenizetten within the meaning of the Rules and Regulations governing the EBS. ;
IUlth regard to the planning and implementation of the -
eierting system it is understood that MilV/0RO will provide certain services and equipment et its supense and that this process of planning and implementation will be en ongoing one.
' - The following equipment er d services will be initialg supplied:
- 1. Dedicated telephone line and answering device with l competable teping equipment.
- 2. Fan or similar device for receiving hard copy of eng message.
- 3. RPU or simi!ar transmit / receive equipment to enable messages to be sont / received without reliance on telephone. Also,
! to enable EBS station to transmit from incident eres or from erees
! that the incident meg cause en effect. i
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George S./ Thomas DouglasJ. Rove //
l Vice President of Producticn Co. Chairman V l New Hampshire Yankee Massachusetts Emergency Division of Public Service Broadcast System Company of Naw Hampshire
' Agent for the Seabrook Joint Owners Date
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A LETTER OF AGREEMENT BETWEEN RADIO STATION WCGY AND NEW HAMPSHIRE YANKEE'S OFFSITE RESPONSE ORGANIZATION '
Purpose:
To activate Emergency' Broadcast System as Provided Title 47 U.S.C. 151, 154 (i) and (o), and 303 (r) Chapter 1. Part 73, Subpart G, Fede,ral Communications Commission Rules and Regulations, Radic
- Broadcast System (EBS) as pertains to day-to-day emergency operation and to provide for cooperation and coordination between New Hampshire Yankee's Offsite Response Organization (NHY/ORO) and the management of radio station WCGY 93.7 FM, Lawrence, Massachusetts, in the event of an accident Saabrook, New / incident at the Seabrook Nuclear Power Station (SNPS) in Hampshire.
Scoce of Activity of WCGYr The management of WCGY, Lawrence, Massachusetts. (when requested) agrees to activate the Emergency Broadcast System for the Emergency Planning 2one located within the Commonwealth of Massachusetts which consists of the following six (6) communities:
Amesbury, Merrimac, Newbury, Newburyport, Salisbury, and West Newbury.
The management of WCGY further agrees to activate (when-roquested) the tone-activated radios supplied as part of the public notification system and broadcast emergency public information when notified to oc so by the Offsite Response Director of the NHY/ORO, using a pre-arranged authentication system.
WCGY further agrees that they have and will maintain a rocording capability to record the actual voice of the NHY/ORO offsite Response Director, and they will broadcast the message, acceptance '
cf/or participation in this plan shall not be deemed as a relinquishment of program control and shall not be deemed to prohibit the licensee from axercising its independent discretion and l cosponsibility in any given situation.
WCGY further agrees that the'NHY/ORO Offsite Response Director is authorized (through a pre-arranged authentication procedure) tc activate the Emergency Broadcast System servicing the l'
Saabrook Emergency Planning Zone area in the event that there is an accident off-site and/or incident at-the Seabrook Nuclear Power Station with 1onsequences.
The NHY/ORO Offsite Response Director will notify the l mtnagement of WCGY when to activate the tone-alert radios and when to bcgin broadcasting Emergeacy Public Information messages. The context i
of these messages and the interval at which the messager will be ropeated will be supplied by NHY/ORO.
l This agreement becomes valid when signed by the signatures indicated below. Once valid, it can be terminated by eithe- NHY/ORO ,
or.the management of WCCY by written notification ninety (90) days 1
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.G.,orge V. Thomas Mm- w ~
p nager Vice President of Production VCGY 93.7 FM
-N;w Hampshire Yankee '
Division of Public Service Company of New Hampshire '
Agent for the Seabrook Joint owners
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165 Menell Coun, Kmw, NH 03431 603/337 0009 1 I
November 14, 1988 1
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! Er. Doug Rowe, Esq.
l'- Morse, Morte and Rowe P.O. Box 617 d'.
jj Marlboro. Massachusetts 01752
Dear Dcug,
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l Fer cur discussions, attachtd is a description of the EBS equipment package AllComm, Inc..has developed for broadcast stations.
This package was developed based upon research relative to the EBS i network's current configuration and its operational status. This l research specifically examined these issues for the New England area, I however, our research included discussions with Emergency Management i Agencies in Florida, California, and Tennessee, broadcasters from around the country and officials from FEMA and the FCC. ,
<l The basic intent of these efforts was-to determine the operational ;
I l' status of the EBS network. We needed to know what was broken and what could be done to fix it, if anything. These efforts were all ,
encompassing and not limited to hardware issues. They included other important areas such as training of-station personnel, development of EBS procedures for each station, and the naed for ongoing preventative maintenance and surveillance programs for station EBS hardware packages.
l 1 -At the same time we were conducting our review, there were several other efforts underway at a federal level which may have appeared at
~first to be headed towards the same goal. These efforts, however, were directed towards the further development of EBS as a communications link from the President to the public during a time of an emergency. This of course was the original purpose for which EBS was conceived.
l In contrast to these efforts, the pr'blems o facing emergency management personnel and broadcasters on a daily basis are quite different. These problems often require the activation of EBS for rapidly developing technological incidents that effect several municipalities or a county-wide area. It is for these types of >
incidents and regional-weather advisories for which EBS is most often
[ utilised. Therefore, it is logical to conclude that EBS must be fine- '
! tuned on a station-by-station basis in order to be responsive to s these types of incidents. Our research and recommendations for j'
creating a responsive funct:onal EBS network are focused along these lines.
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In order to achieve this goal, we have developed a basic generic icquipment package to be installed at each station in the operational crea. This equipment pacxage is designed to "fix" all of the hardware items that we identified during our research as being inadequate. The package is also designed to facilitate the initial notifiestion to station personnel and to assist personnel with EBS rasponsibilities once activiated. This " generic" package is then teilored to fit a particular station's needs and management concerns.
Procedures for station personnel are reviewed, revised or developed, i cnd a specially developed training program is initiated. Once installed, the EBS equipment itself is also placed under a preventative maintenance and surveillance program. A training review is conducted on an annual basis and training is provided for new station personnel as required.
Collectively, these efforts combined with the willing participation of the broadcasters, state, and local authorities create a viable and responsive EBS network.
This program and hardware equipment packages have been in place and operational in the State of New Hampshire for the Seacoast
-Operational Area since March of 1987. Several broadcast stations outside of New Hampshire also have installed these equipment packages. If you would like to visit one of these stations, or would prefer a demonstration of the hardware package at your location, l please let me know.
Thank you again for your interest in our products and services.
Sincerely, Gary J. Catapano, President GJC/cer Attachments 4
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__ _ _ _ i 165 Martell Court, Keene, NH 03431 603/357 0009 l l
i OPERATION OF THE CA7&TLUNKT EBS NOTIFICATION SYSTEM ;
The system utilizes the CFCS-1 station as a " gateway" station I allowing access and control of the operational area. The other I stations in the operational area monitor the gateway station. These ,
stations are termed satellite stations. 1 The equipment at the satellite stations monitors the CPCS-1 station continuously. The equipment package installed at each station consists of the following: the EBS Custom Control Unit, a TFT EES
. Receiver, Encoder, Decoder Unit and a specially modified Nakamichi MR-2 Cassette Deck. High power strobe lights are utilized as visual and silent means of notification to personnel in the air studio (s).
When the gateway station transmits an EBS tone, the TFT Decoder
- decodes the signal and activates the EBS Control Unit which causes the following events to occur simultaneously:
- 1. The strobe light (s) in the air studio (s) begin to flash. s
- 2. The receiver on the TFT "unmutes" and the emergency message
~ being transmitted by the CPCS-1 becomes audible over the speaker. A " mute" switch is provided to override this
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feature if the equipment is installed in the air studio.
- 3. The cassette deck starts automatically and begins recording the emergency message being broadcast.
. 4. The broadcast audio from the CPCS-1 station comes up on the console on the channel utilized for EBS and the DJ ean select it on " cue" channel in order to monitor it.
The strobe light remains " flashing" until reset by a reme te reset button installed on the audio console. However, the remote reset button does not stop the tape recorder which continues to run for 10 minutes or until manually reset via a switch on the EBS Control Unit.
When alerted by the flashing strobe light (s), station personnel are trained to select the appropriate channel on the audio board and bring up the EBS audio on " cue" to determine if it is a test or an
- actual emergency EBS activiation.
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e i t c If it is an actual emergency, the station can rebroadcast the message rccorded from the CPCS-1.
The encoder portion of the TFT Unit is wired to the EBS activation button installed on the audio board to allow activation from the air studio. Should an AM and FM station be co-located, the equipment can b3 remoted to both air studios. Special audio bridging can be added :'
for simulcasting emergency information. Additional equipment wiring is performed at each staticn to allow operation of the features described above. '
1An outdoor antenna is normally provided with each package.
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Where nocessary, a notch filter or " trap" is also provided to ensure proper cperation in the presence of strong R.F. fields.
When complete and installed, the system is placed under a monthly preventative. maintenance and surveillance program. ;
In order to allow integration of the Operational Area with the state-wide EBS Network, the EBS equipment package at the CPCS-1 station is tuned to monitor the State Operational Primary Relay Station.
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zYankee .
September 29, 1989 Douglas'Rowe '
Nass. Energency Broadcast System l P.O.-Box 566 Marlboro, WA 01752 i
Dear Mr..Rowe,
1 Pursuant to our meeting of September 20, 1989, New Hampshire l Yankee would like to outline its commitments with regard to j Public Notification and future Energency Planning participation '
by the State of Nassachusetts.
NHY's connitment concerning Public Notification. as '\
j negotiated with federa) officials, is to issue all residents, '
schools, businesses, public buildings, nursing homes, etc. public information material. This material outlines the responses the
'public should follow in the event energency sirens are sounded within the six towns of the Seabrook Emergency Planning Zone. In addition,-tone alert radios are being distributed to public &
private: schools, day care facilities, nursing homes, special needs facilities, hotels, actals, inns, hospitals and businesses.
These radios will activate once an EBS tone is received from WLYT, and then monitor the station for'energency information.
The second issue is the future participation of Mass. in Energency Planning for Seabrook Station. Once the State begins to plan with NHY, we vill re-evaluate our broadcasting capabilities and requirements, will formulate cost effective
-alternatives and implement the selected alternative. If the Norrimack Valley EBS Network is utilized, due to prudency considerations, federal and State assistance must be requested, documented-and denied prior to a re-evaluation by NHY.
We hope our position in this matter is clear and appreciate the support you continue to provide on our behalf. NHY vishes to continue our relationship with you and the Wass. EBS. If you l
' have any questions or concerns please call me at (603) 474-9521 Ext. 2417. Thank you for your time and we look forward to your continued cooperation.
Sine
'ist.1oly, s .
R. Boyd, r.
Performance Services Manager {
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jjg9451 l New Hampaire Yonkee Division of Pubte Sennee Company of New Hompshine D O by 3T
- Smb-r.'r W 03F74 *Te! W a(6031 C bof7'
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. Of i October 20, 1989 ;
f Mr. B. Boyd, Jr. .
Performance Services Manager P.O. Box 300 i
O Seabrook, New Hampshire 03874
Dear Mr. Boyd:
I have received Yankee a copy from Douglas Rowe.of the letter of Octolor13,1989, to New Hampshire- '
. I am in agreement with the facts as stated by Mr. Rowe.
WCGY has not received the promised equipment or services as outlined in the letter of agreement response between radio station WCGY and New llampshire Yankee's offsite organization.
There is NO pre-arranged authentification system, there is N0 dedicated telephone receive line and equipment answering to the device, there is NO RPU or similar transmit /
incident area.
The letter of September 14, 1987 equipment and services were rendered.was to become valid when signed and the and services are not forthcoming I consider the CPCS-1/WCGY letter ofSince y September 14, 1987 void effective today. The management of WCGY does not intend to perpetuate an agreement that the public may rely when, fact, ,
on in' p
to notify the general public,there is no agreement, or more importantly NO E.B.S. sy .
i l ,Very truly yours, t.
John F. Bassett -
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Attachment:
- WCGY-NHY/ORO Letter 9/14/87 cc: Douglas J. Rowe, Esq. !
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Leslie,Greer, Esq. .
W'XM & WCGY BostenAcwence Mo:13 FRAMN STRc_ET. ! AW9EtCE MA 0 Sochusetts wiAT & WEATJu west & r ee- rw vm. . , ~~ ..
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Yankee October 26, 1989 i
John Bassett
-33 Franklin Street
' Lawrence, MA 01840 D;ar Mr. Bassett:
New Hampshire Yankee is in receipt of your letter datec trt M r 20,
- 1989. It appears from your letter that you are not complateil informed of ,
7 -Nsw Hampshire Yankee's position regarding its commitment to WCGY/WCCM.
Our commitment, with regard to the Mass. Broadcasters Agreement, was to evaluate WCGY/WCCM's equipment, provide new or upgrade existing equipment to ensure the following exists:
- 1) Dedicated '.elephone line and answering device with compatible taping equipment.
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2). Fax or similar device for receiving hard copy of any message.
3)_ RPC or similar transmit / receiver equipment to enable messager to be sent/ received.without reliance on telephone. Also, enable EBS stations '
. to ' transmit from'ine d6mt area or f rom areas that the incidant may cause effect.
! At a meeting on September 20th, Mr. Rowe of the Mass. Broadcasters j; Association took the position that NHY was to provide equipment to all of j the EBS statiens in the Herrimac Valley area. We reiterated our commitment l to WCGY/WCCM and were under the impression Mr. Rowe understood this._ It I was .and still is, the position of NHY that we vill evaluate your stations' l- squipment and supply the necessary component:; as outlined in the Mass.
Broadcasters-Agreement. (See attached.)
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We would like the opportunity to provide you with further details of this. unfortunate misunderstanding and conduct a review of your stations'
! equipment so that NHY can fullfil its commitment as outlined in the attached. Please call me at 1-603-474-9521 X 2417 at your convenience to i.
set up a meeting to review and discuss these issues.
L Sincerely, L
RobertBoyd,Jrh 'W~
Manager Performance Services
- RB /lmk l Attachment P4K9557
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11ew Hampshire Yonkee Division of Public Servic? Company of New Hampshire
' s. Box 300
- Seabrmk, NH 03274
- Telephone (603) 474 9521 1
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CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr., one of the attorneys for the Applicants herein, hereby certify that on November 11,, 1989, I
.made service of the within document by depositing copies thereof l with Federal Express, prepaid, for delivery to (or, where indicated, by depositing in the United States mail, first class postage pr.id, 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, MD 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 Regu)atory 4350 East West Highway Commission Bethesda, MD 20814 East Wcst Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Kenneth A. Mitzi A. Young, Esquire Mccellom Edwin J. Reis, Esquire
-1107 West Knapp Street Office of the General Counsel Stillwater, OK 74075 U.S. Nuclear Regulatory Commission-One White Flint North, 15th Fl.
11555 Rockville Pike Rockville, MD 20852 John P. Arnold, Esquire Diane Curran, Esquire Attorney General Andrea C. !'erster, Esquire Georgu Dana Disbee, Esquire Harmon, Curran & Tousley
' Assistant Attorney General Suite 430 Office of the Attorney General 2001 S Street, N.W.
25 Capitol Street Washington, DC 20009 Concord, NM 03301-6397
- Atomic Safety and Licenbing Robert A. Backus, Esquire Appeal Board 116 Lowell Street U.S. Nuclear Regulatory P. O. Box 516 ccmmission Manchester, NH 03105 Washington, DC 20555
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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 v Paul McEachern, Esquire John Traficonte, Esquire "
Shaines & McEachern Assistant Attorney General _
25 Maplewood Avenue' Department of.the Attorney .
-P.O.iBox 360 General Portsmouth, NH- 03801 One Ashbutton Place, ' . 9th F1.
Boston, MA~ 02108 Chairman Mr. Calvin A. Canney Board of Selectmen City Manager
'95 Amesbury Road City Hall
- Kensington, NH 03833. 126 Daniel Street Portsmouth, NH 03801'
- Senator Gordon J. Humphrey R. Scott Hill-Whilten, Esquire U.S. Senate Lagoulis, Hill-Whilton &
Washington, DC. 20510 Rotondi (Attn: ~ Tom Burack) 79 State Street Newburyport, MA 01950
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- Senator'Gordon J..Humphrey Barbara J. Saint Andre, Esquire {
> OnetEagle Square, Suite 507 1(opelman and Paige, P.C. i
- Concord, NH 03301 77 Franklin Street ,
(Attn: Herb Boynton) Doston, MA 02110 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 Judith H. Mizner, Esquire
. Office of General Counsel 79 State Street, 2nd Floor Federal Emergency Management Newburyport, MA 01950 Agency 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
- immpton,' NH 03842 Concord, NH 03301 em 2 en i
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% .Mr.-Richard R. Donovan Jt i .; Federal' Emergency; Management
. Agency Federal Regional Center 130 228th Street, S.W.
- c ' '~- Bothell, Wsshington' 98021-9796
.Ashod N. Amirian,' Esquire 145 South Main' Street P.O. Box 38
.Bradford,.MA 01835 xnd Thomhs T. DigmtTF, . Jr.
(*= Ordinary U 3. First. Class Mail) i
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