ML20154P511

Town of Amesbury Answers to NRC Staff First Set of Interrogatories & First Request for Production of Documents to Towns of Amesbury,Newbury,Salisbury,West Newbury & Merrimac & City of Newburyport.* W/Certificate of Svc

ML20154P511
Person / Time
Site:	Seabrook
Issue date:	09/23/1988
From:	Lord W AMESBURY, MA
To:	NRC OFFICE OF THE GENERAL COUNSEL (OGC)
Shared Package
ML20154P479	List: ML20154P474 ML20154P511
References
OL-1, NUDOCS 8810030086
Download: ML20154P511 (16)

Text

.

O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BITORE THE ATOMIC SAFETY AND LICENSING BOARD

] In the Matter of )

)

PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL-1 NEW HAMPSHIRE, et al. ) 50-444-OL-1

) Offsite Emergency (Seabrook Station ) Planning Issues

• Units 1 and 2) )

TOWN OF AMESBURY ANSWERS TO NRC STAFF'S FIRST SET OF INTERROGATORIES AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO THE TOWNS OF AMESBURY, NEWBURY, SALISBURY, WEST NEWBURY, AND MERRIMAC, AND THE CITY OF NEWBURYPORT NOW COMES the Town of Amesbury (TOA) and hereby answers NRC ,

STAFF'S FIRST SET OF INTERROGATORIES AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO THE TOWNS OF AMESBURY, NEWBURY, SALISBURY, WEST r

NEWBURY, AND MERRIMAC, AND THE CITY OF NEWBURYPORT dated September 6, i

ll 1 1988 as follows:  ;

OILTECTION TO PRODUCTION OF DOCUMENTS I I 4  ;

i TOA objects to the Staff's request that any documents to be l produced by TOA must be proviced at Staff offices located in  ;

t i Rockville, Maryland. The request is unduly burdensome and costly to i

l TOA, is disruptive of record keeping maintained by the Town, and could I i unreasonably compel TOA to transfer documents outsioe the EPZ. In ,

I I addition, in view of the great disparity in resources between the l t Staff and TOA, it is only appropriate that the Staff assume the burden i i of coming to TOA to inspect any relevant documents of TOA, provided, i

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however, that said inspection is conducted during the discovery period, during normal business hours, at a mutually agreeable time, following reasonable notice to TOA.

Il{TERROGATORIES QUESTION:

1. Identify and supply each document containing procedures, plans, orders, instructions, directions, and training materials of the Intervenors for any action in the event of?

a) a radiological emergency or disaster stemming from a nuclear plant acident whether the plant is located inside or outside of Massachusetts; b) other radiological emergencies or disasters; and c) all other "emergencies" or disasters as defined in paragraph 4 of the above definitions.

ANSWER:

1 (a - b). Tnis Interrogatory in objected to as overly broad and unduly burdensome. To the extent the Staff seeks identification or production of documents concerning Intervenors other than TOA, or information on issues beyond TOA's jurisdiction, the Staff should address those inquiries elsewhere. This Interrogatory is also objected to on grounds that, on information and belief, the Staff is already in possession of all planning documents concerning Seabrook Station, which were generated in conjunctior, with Applicants and the Commonwealth, prior to the vote by the Commonwealth and TOA not to .

participate further in emergency planning for Seabrook Station. TOA is not in possession of any documents involving radiological emergency planning generated since that date.

1 (c). TOA has not approved any emergency or disaster plan for the Town.

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QUESTION:

2. With regard to each document set out in response to Interrogatory 1, describe the functions in emergencies of any of the following categories of personnel:

a) State and local police, to include persons employed full or part time, and both private and public security personnel, such as special officers and deputies; b) Civil Defense personnel;

, c) Professional or volunteer fire-fighting personnel; d) First aid and rescue personnel; e) Local support services personnel including civil Defense / Emergency Service personnel; f) Medical support personnel; g) Emergency Service personnel; h) Health and Environmental Department personnel; i) Natic.nal Guard, Militja or Reserve personnel; j) Boards of Eoucation, School Boards or Departments, and teachers; k) Employees of all other State, local or municipal 1

departments or agencies;

1) Individuals obligated to provide assistance pursuant to agreements to aid between municipalities or other government units, or pursuant to other agreementst and a m) Individuals available to provide assistance pursuant to agreements to aid betweer, municipalities or oth- government i units, or pursuant to other agreements.

ANSWER:

1

2. See Answer to Interrogatory 1. By way of further objection, the documents speak for themselves and the Staff has substantially greater resources to analyze these documents as 3t choosen.

QUESTION:

3. Set out the training each of the catugory of personnel l

set out in Interrogatory 2 has to perform its function in an "emergency".

ANSWER:

3. See Answer to Interrogatory 2.

QUESTION:

4. Identify the Massachusetts Civil Defense agency areas in which the Seabrook plume emergency planning zono (EPZ) is located. Provide the Civil Defense Plans for those areas and for l

the Commonwealth.

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, ANSWER:

4. See Answer to Interrogatory 1.

QUESTION:

5. Identify the number of individuals in each of the personnel categories listed in Interrogatory 2(a)-(m), and the number of such personnels (a) within the 10-mile EPZ plume e;tposure pathway; (b) from 10 to 25 miles of Seabrook Station; (c) from 25 to 50 miles of Seabrook Station; (d) from 50 to 100 miles of Seabrook Stationt and (e) within the commonwealth of 7

l Massachusetts outside the aforementioned areas.

I ANSWER:

5. See Answer to Interrogatory 1. By way of further answer, the

< number of individuals in each of the personnel categories in TOA are as follows:

i a) Police: 1 Chief, 5 Sergeants, 23 full time, 6 reserve 15 auxillary

. b) civil Defense personnel: 1 full time, 15 volunteers i

20 reserve c) Professional or volunteer fire-fighting personnel:

2 1 Chief, 1 Deputy, 28 Professional and 14 volunteer d) First aid and rescue personnel S6e Answer to 5(c).

l e) Local support services personnel including civil Defense /

! Emergency Service personnel: See Answer to 5(c).

f) Medical support personnel: 250 employees - Town of Amesbury j

Hospital g) Emergency Service personnel See Answer to 5(c).

h) Health and Environmental Department personnel: 1 i

0 i) National Guard, Militia or Reserve personnel:

j) Boards of Education, School Boards or Departments, and teachers: School committee 7 members

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School Administrationt 1 Superintendenti 4 Ad31nictrativo Stoff As of 1987-1988 - Teachers:

Horace Mann: 1 Principal 13 Teachers (including half-time)

Ames Elementarvi 1 Principal 32 Teachers (including 1 nurse)

Cashman Elementarvt 1 Principal 45 Teachers (including 1 nurse)

Amesbury Middle: 1 Principal 1 Assistant Principal 49 Teachers (including i nurse)

Amesbury Hiuht 1 Principal 1 Assistant Principal 58 Teachers (including i nurse) k) Employees of all other State, local or municipal departments or agencies: Public Works Departmentt 40 (12 vater, 6 Sewer, 24 Public Works) 3 Administrators; 1 Secretary 1 Town Manager

1) Individuals obligated to provide assistance pursuant to agreements to aid between municipalities or other government I units, or pursuant to other agreements and

1) See Answer to Interrogatcry 1. By way of further answer, TOA vill assist other Towns if requested, and, if TOA resources are l

1 available and not otherwise engaged.

) m) Individuals available to provide assistance purr.uant to t

l agreements to aid between municipalities or other government units, or pursuant to other agreements: See Answer to 5(1).

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QUESTION:

6. Identify the type: and number of the following resources available for use in the event of emergencies pursuat.t to the documents identified in Interrogatory it (a) polico vehicles; (b) fire trucks; (c) buses; (d) vans; (e) other vehicles; (f) helicopters and other aircraft; (g) boats; (h) sirens and public notification systems; (i) radios; and (j) all other equipment.

ANSWERt

6. See Answer to Interrogatories 1 and 2.

QUESTION:

7. Identify the resources enumerated pursuant to Interrogatory 6 (a)-(j ) , according to their locationt (a) within the 10-mile EPZ plume exposure pathway; (b) from 10 to 25 miles of Seabrook Station; (c) from 25 to 50 miles of Seabrook Station; (d) from 50 to 100 miles of Seabrook Station; and (e) within the commonwealth of Massachusetts outside the aforementioned areas.

ANSWERt

7. See Answer to Interrogatory 1. By way of further answer, TOA owns the following resources (a) police vehicles: 1 staff car, 4 cruisers, 1 unmarked cruiser, 1 canine vehicle; (b) 11 fire Department vehicles; (c) 0 buses; (d) i vant (e) other vehicles, Public Work Department has 7 pickup trucks, 10 dump trucks, 2 back hoes, 1 trojan loader, 6 enclosed service trucks; School Department has 3 pickup trucks; (f) O helicopters and other aircraf t; (g) 2 boats; (h) 1 fire horn; 1 public square sirent (i) radies; Police and Fire Departmen*.s have radios in vehicles and portable and (j) all other equipment. (j) is objectionable as vague and overly broad.

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QUESTION:

8. Identify the number and location c! Massachusetts National Guard Units in each of the Intervenor jurisdictions, the number of members of each unit, their distance from the Seabrook plume exposure EPZ, and the number and location of the following resources available for use by the National Guard in emergencies:

(a) cars; (b) trucket (c) vanat (d) helicopters; (e) other reans communication facilities, including of transportation; and (f) radios and other means of public notification. Supply the same information for any Militia or Reserve unit in such jurisdiction.

(Footnote: If any of the data sought under Interrogatory 8 are withheld on the ground they are classified, please indicate the type of data so withhold.)

ANSWER:

8. See Answer to Interrogatory 14 QUESTION:

9. Identify any plans made for radiological monitoring in the event of a radiological emergency from any cause, including (a) the number and location of personnel trained and available to accomplish such monitoring, and (b) a description and enumeration of radiological monitoring equipment available for use in such an emergency, along with identification of tne equipment's location.

ANSWER:

9. See Answer to Intorrogatory 1.

QUESTION:

10. Identify any provisions made for handling of individuals contaminated in a radiological emergency stemming from any cause, including (a) the number and location of personnel trained and available to assist in decontamination of contaminated individuals, and (b) a description and enumeration of equipment available for use in decontamination, along with identification of the equipment's location.

ANSWER:

10. See Answer to Interrogatory 1.

QUESTION:

loa. Iduntify all documents in your possession identifying facilities in Massachusetts which have or claim to have radiologically equipment, personnel or expertise to trea*

contaminated individuals. Supply such documents.

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ANSWER:

10a. Honoital Manaaement of Radiation Accidents, Dennis Carlson, M.D. (1980). The Staff may inspect this document in accordance with the conditions set forth in OBJECTION To PRODUCTION OF DOCUMENTS, alMEIA .

QUESTION:

11. Identify any provisions made by the Nassachusetts Department of Agriculture, or other state or local governmental agency, concerning protective measures to be used for the 50-mile ingestion pathway from any nuclear plant, including the methods for protecting the public from consumption of contaminated foodstuffs; and identify any procedures for detecting contamination, for imposing protective measures such as interdiction of food supply, impoundment, or quarantine, and for public notification concerning food contamination and the

• protective measures to be followed. '

ANSWER:

11. See Answer to Interrogatory 1. l QUESTION:

12. Identify the number of Massachusetts Civil Defense personnel according to location within the commonwealth, and -

identify the amount and location of equipment available for their }

use to protect the public in the event of an emergency. Set out [

the training of Civil Defense personnel. l t

ANSWER

12. See Answer to Interrogatory 1.

QUESTION: (

13. Identify the location of stations authorized to '

broadcast under Federal Emergency Broadcast System (EBS) regulations and the Massachusetts EBS operational Plan

("operational Plan"). Provide a copy of the Operational Plan, i

ANSWER:

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13. See Answer to Interrogatory 1.

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QUESTIONS

14. Identify all documents, agreements and communicstions

dated within the last five years concerning the operation of the .

EBS. Produce a copy of all such documents, agreements and communications.

ANSWER:

14. See Answer to Interrogatory 1.

QUESTION:

15. Identify the provisions of federal or state law which preclude activation of the EBS at the discretion of management of AM, FM, and television stations, in connection with day-to-day emergency situations posing a threat to the safety of life and property, such as hurricanes, floods, icing conditions, heavy snows, fires, toxic gases, power failures, industrial explosions, 1

and civil disorders.

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, ANSWER:

15. See Answer to Interrogatories 1 and 18.

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i QUESTION- L i

1C. List all Federal funds received by any Intervenor

] jurisdiction during the past 5 years for purposes of developing and other documents concerning l

! plans, procedures, manuals, responses to emergencies, and identify, with respect to each such I

)! document, under what statutes these funds were provided and the i Federal agencies or departments from which the funds were , i

' received. l ANSWERt j None QUESTION:

i j 17. With respect to each document identified in f l Interrogatory 1, identify any Federal or state law or regulation ,

pursuant to which each such document was prepared. l ANSWER:

l 17. See Answer to Interrogatory 18.

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QUESTION:

18. Identify all Massachusetts statutes and regulations, and all local regulations, ordinances or other provisions, (a) concerning actions to be taken by state or local authorities, or those acting in their behalf, in the event of emergencies, including the preparation of plans for actions to be taken in emergencies; (b) concerning any prohibitions on any such actions or plans; and (c) concerning any prohibitions on any person or organization other than state or local authorities with respect to any such actions or plans.

ANSWER:

18. See Answer to Interrogatory 1. By way of further answer, this Interrogatory is objected to as calling for a legal opinion. The Staff may inspect TOA's ordinances in accordance with the conditions set forth in OBJECTION TO PRODUCTION OF DOCUMENTS, supra.

QUESTION:

19. Set out the conditions, including citations to all applicable provisions of state and local laws and regulations, (a) under which state and local authorities may permit private individuals or organizations to take action on their behalf in an emergency; and (b) under which state and local authorities are precluded from authorizing private individuals or organizations from taking action on their behalf in an emergency. ,

t ANSWER:

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19. See Answer to Interrogatory 18. l QUESTION: l

20. Set out examples illustrating the conditions described ,

in Interrogatory 19(a) and (b).

ANSWER: i

20. See Answer to Interrogatory 18. l QUESTION: l

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21. Define what you consider to be "the beach" in the  ;

Massachusetts portion of the Seabrook Station EP . Set out the  !

geographic boundaries of that "beach" area. [

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ANSWERS

21. This Interrogatory is objected to as irrelevant and not likely to lead to the discovery of admissible evidence.

QUESTION:

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22. Using the definition of "the beach" you supplied in answer to Interrogatory 21, provide the following data along with a copy of any study or other document relevant to the following informations (a) the maximum number of cars at the beach on the 10 busiest days within the last five years, along with indication of the time and date of such maximar (b) the number of cars remaining at the beach following each 1/2-hour interval for the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the aforementioned maximal (c) the number of cars entering and leaving the beach during each 1/2-hour interval within the 8-hour period. If you do not have data for 1/2-hour intervals, supply such data for the periods you have. Indicate 1 whether the foregoing computations were made manually or J automatically.

ANSWER:

22. See Answer to Interrogatories 1 and 21. By way of further j answer, ".; adopts the statements, testimony, and evidence presented

! by Intervenors, to the extent applicable, in the NHRERP litigation.

QUESTION:

23. Identify all studies conducted during the last five 3

i years concert.ing improving the movement of traffic in and out of

) "the beach" area. Provide a copy of all such studies.

ANSWER:

23. TOA has conducted no such studies. See Answer to Interrogatory 1.

)

l QUESTION:

)

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24. Identify all studies conducted during the last five 4 years concerning improving the movement of traffic in the event

! of emergencies within the Seabrook Station EPZ which include I

estimates of the volumeProvide of traffic or the time within which a copy of all such studies.

i traffic can be evacuated.

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, ANSWER:

24. None. See Answer to Interroga;ories 22 and 23. 1 QUESTION:

i 25. Identify all State and it cal laws and regulations

' concerning the following actions to be taken in the event of radiological or other emergencies (131 definition 4) (1) 3 guiding traffic; (2) blocking roadways, erecting barriers in roadways, and channeling traffic; (3) posting traffic signs on roadways; (4) removing obstructions from public roadways, l including towing private vehicles; (5) activating sirens and 4 directing the broadcast of EBS' messages; (6) making decisions and recommendations to the public concerning protection actions for the ingestion exposure pathways; (8) making decisions and recommendations to the public concerning recovery and reentry; i (0) dispensing fuel from tank trucks to automobiles along roadsides; and (10) performing access control at the Emergency i Operations center, the relocation centers, and the EPZ l perimeters.

ANSWER:

! 25. See Answer to Interrogatory 18.

! QUESTION:

26. Identify all studies performed during the last five 1

years concerning the availability and possible use of sirens and j other means of emergency communication to the public in the event j of emergencies. Provide a copy of all such studies.

l ANSWER:

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26. TOA has conducted no such studies. TOA adopts, and

incorporates by reicxence all relevant statementa, documents, reports, evidence or other inforLatinn proferred by the commonwealth concerning sirens and siten content),ons for the Seabrook EPO, with supporting documentation as detailed therein and as previously filed in this i proceeding. See Answer to Interrogatory 1.

l QUESTION:

j 27. Identify all sirens or other means of emergency 1 communication in the Seabrook EPZ vhich can be heard by the l general public.

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ANSWER:

27. See Answer to Interrogatories 1, 7(h) and 26.

QUESTION:

28. Identify all studies performed by Intervenors during the last five years concerning planning for emergencies. Produce a copy of all such studies.

ANSWERt

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28. See Answer to Interrogatory 1. ,

DATED. September 23, 1988 By: v[ 4//

William Lord, Chairman TOWN OF AMESBURY Board of Selectmen STATE OF NEW HAMPSHIRE ROCKINGHAM, SS. September 23, 1988 Personally appeared the above-named William Lord and swore to the truthfulness of the foregoing statements based upon personal knowledge, information and belief.

Before met e y M _ A r-NotaryvPublic/dustice a t -the-Boaoe-t My Commission Expirest 5~ A / 9 / i 13 wa msa.u.rAmt s - ,w w.... x..,.w F M4.ti A LEO 4 il W S

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l CERTIFICATE OF SERVICE I, Matthew T. Brock, one of the attornek r the own of Amesbury herein, heraby certify that on September 23, 1988, I made ,

l service of the foregoing document, TOWN OF AME!(@RYs ANSWERS. TO NRC j j STAFF'S FIRST SET OF INTERROGATORIES AND FIRST REQUEST?.FOR ' PRODUCTION r OF DOCUMENTS TO THE TOWNS OF AMESBURY, NEWBURY, $ALISBURY, WEST l NEWBURY, AND MERRIMAC, AND THE CITY OF PEWBURYPORT, by depositing }

copies thereof in the United States Mail, first class postage prepaid  ;

for delivery (or, where indicated, by Express Mail, prepaid) addressed i to:  ;

• Ivan Smith, Esq., Chairman *Dr. Jerry Harbour j Atomic Safety & Licensing Board Atomic Safety & Licensing Board  ;

(Off-Site) (Off-site) i U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comm.  !

East West Towers Building East West Towers Building .

4350 East West Highway 4350 East West Highway  !

Bethesda, MD 20814 Bethesda, MD 20814  :

• Judge Gustave A. Linenberger, Jr.

• Atomic Safety & Licensing [

Atomic Safety & Licensing Board Appeal Board Panel l (Off-Site) U.S. Nuclear Regulatory Comm.

Washington, DC i

U.S. Nuclear Regulatory Commission 20555 j East West Towers Building  ;

4350 East West Highway

• Thomas Dignan, Esq.

Bethesda, MD 20814 George H. Lewald, Esq. f Kathryn A. Selleck, Esq.

• Adjudicatory File Ropes & Gray Atomic Safety & Licensing Board 225 Frankin Street Panel Docket (2 copies) Boston, MA 02110 U.S. Nuclear Regulatory Commission ,

East West Towers Building

• Carol S. Sneider, Esq. t 4350 East West Highway Stephen H. Oleskey, Esq.  !

Bethesda, MD 20814 Allan R. Fierce, Esq.  !

f Department of the Atty. General

• Stephen E. Merrill, Esq. One Ashburton Place George Dana Bisbee, Esq. Boston, MA 02108 i Office of the Attorney General l State House Annex

• Diane Curran, Esq.

Concord, NH 03301 Andrea C. Forster, Esq. l Harmon & Weiss 2001 S Street, N.W., Suite 430

• Shervin E. Turk, Esq. Washington, DC 20009-1125 j Office of General Counsel U.S. Nuclear Regulatory Commission

• Richard R. Donovan 15th Floor - one White Flint North Federal Emergency Mgmt. Agency 11555 Rockville Pike Federal Regional Center Rockville, MD 20852 130 228th Street, S.W. i Bothell, Washington 98021-9796 l

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Philip Ahrens, Esq. Robert A. Backus, Esq.

Assistant Attorney General Backus, Meyer & Solomon Office of the Attorney General 111 Lowell Street State House, Station 6 Manchester, NH 03105 Augusta, ME 04333 Mrs. Anne E. Goodman Jane Doughty Board of Selectmen Seacoast Anti-Pollution League 13-15 Newmarket Road 5 Market Street Durham, NH 03824 Portsmouth, NH 03801 William S. Lord, Chairman Rep. Roberta C. Pevear Board of Stlectman Drinkwater Road Towr. of Amesbury Hampton Falls, NH 03844 Town Hall, Friend Street Amesbury, MA 01913 R. Scott Hill-Whilton H. Joseph Flynn, Esq.

Lagoulis, Clark, Hill-Whilton Office of General Counsel

& McGuire Federal Emergency Mgmt. Agency 79 State Street 500 C Street, S.W.

Newburyport, MA 01950 Washington, DC 20472 Stanley W. Knowles Ashod N. Amirian, Esquire Board of Selectmen 376 Main Street i P.O. Box 710 Haverhill, MA 01830 North Hampton, NH 03862 J.P. Nadeau, Selectman Alfred V. Sargent, Chairman ,

Selectman's Office Board of Selectmen Town of Salisbury 10 Central Road Rye, NH 03870 Salisbury, MA 01950 Senator Gordon J. Humphrey Senator Gordon J. Humphrey U.S. Senate One Eagle Square, Suite 507 [

Washington, DC 20510 Concord, NH 03301 (Attnt Tom Burack) (Attn Herb Boynton)

William Armstrong Allen Lampert Civil Defense Director Civil Defense Director ,

10 Front Street Town of Brentwood Exeter, NH 03833 Exeter, NH 03833 Richard A. Hampe, Esq. Gary W. Holmes, Esq.

Hampe and McNicholas Holmes and Ells 35 Pleasant Street 47 Winnacunnet Road Concord, NH 03301 Hampton, NH 03C42 2

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i Charles P. Graham, Esq. Calvin A. Canney, City Manager Murphy & Graham City Hall 33 Low Street 126 Daniel Street  ;

Newburyport, MA 01950 Portsmouth, NH 03801  !

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Sandra Gavutis Brentwood Board of Selectman l Town of Kensington RFD Dalton Road RFD 1, Box 1154 Brentwood, NH 03833 i East Kensington, NH 03827  :

L Robert Carrigg, Chairuan Mr. Thomas H. Powers, III Board of Selectmen Town Manager Town Offine Town of Exeter  ;

Atlantic Avenue 10 Front Street No. Hampton, NH 03862 Exeter, NH 03833 ,

Judith H. Mirner, Esq. Beverly Hollingworth t 79 State Street 209 Winnacunnet Road i 2nd Floor Hampton, NH 03842 I Newburyport, MA 01950 Leonard Kopelman, Esquire Barbara J. Saint Andre, Esquire Michael Santosuosso, Chairman Kopelman & Paige, P.C.

Soard of Selectmen 77 Franklin Street itewell Street, RFD 2 Boston, MA 02110 So. Hampton, NH 03827

• Robert R. Pierce, Esq.

Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission l East West Towers Building i 4350 East West Highway Bethesda, MD 20814 o ^s i &s

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I r l Matthew T. Brock

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