Response Opposing New England Coalition on Nuclear Pollution,Commonwealth of Ma & Towns of Rye,Hampton,South Hampton,Kensington & Hampton Falls Contentions Re Radiological Emergency Response Plan.W/Certificate of SvcML20154L495 |
Person / Time |
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Site: |
Seabrook |
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Issue date: |
03/06/1986 |
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From: |
Bisbee G NEW HAMPSHIRE, STATE OF |
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To: |
NRC COMMISSION (OCM) |
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References |
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CON-#186-347 OL, NUDOCS 8603110496 |
Download: ML20154L495 (12) |
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Category:INTERVENTION PETITIONS
MONTHYEARML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20237C6981998-08-18018 August 1998 Sapl/Necnp Reply to Naesco Response to Proposed Contentions.* Board Should Admit Sapl/Necnp Contentions 1-4 & North Atlantic Energy Svcs Corp Arguments to Contrary. W/Certificate of Svc ML20237C6791998-08-18018 August 1998 Sapl/New England Coalition on Nuclear Pollution Reply to Staff Answer to Contentions.* Petitioners Believe Board Can & Should Give Cases Consideration W/O Filing of Addl,But Not Substantively Different Contention.W/Certificate of Svc ML20237A0501998-08-10010 August 1998 North Atlantic Energy Svc Corp Response to Proposed Contentions.* Petitioners Failed to Propose Admissible Contention.Request for Hearing & Petition to Intervene,As Applied to Both Petitioners Should Be Denied ML20236X9281998-08-10010 August 1998 NRC Staff Answer to Contentions.* for Reasons Stated,All of Contentions Proposed Should Be Rejected & Proceeding Should Be Terminated.W/Certificate of Svc ML20066H2581991-02-14014 February 1991 Response of Ma Atty General & Necnp to ASLB Order of 910124.* Intervenors Believe ASLB Should Reopen Record, Permit Discovery & Hold Hearing on Beach Sheltering Issues. W/Certificate of Svc ML19332D7241989-11-21021 November 1989 Intervenors Motion for Clarification Or,In Alternative,For Reconsideration.* Clarification or Reconsideration of Scheduling Requirements Set by Commission 891121 Order Requested.Certificate of Svc Encl ML19332D5191989-11-15015 November 1989 Applicant Answer to Intervenors Motion to Admit late-filed Contention & Reopen Record Based Upon Withdrawal of Commonwealth of Ma Emergency Broadcast Sys Network & Wcgy.* Motion Should Be Denied Since Results Unlikely to Change ML19325E0171989-10-20020 October 1989 Applicant Answer to Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Motion to Assert Addl Bases for Original Onsite Exercise Contention JI-Onsite Ex-1 Should Be Denied.W/Certificate of Svc ML19325E0011989-10-20020 October 1989 Applicant Response to Intervenors Motion to Amend Intervenors Motions of 890929 & 1013 to Admit Contentions on 890927 Onsite Emergency Plan Exercise.* Issue Re Admittance Committed to Board Discretion.Certificate of Svc Encl ML20248J3511989-10-13013 October 1989 Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Advises That Applicant Contentions Filed on 890929 to Admit Addl Bases Re Scope of Onsite Exercsise Should Be Admitted.W/Certificate of Svc ML20248J0601989-09-28028 September 1989 Intervenors Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Requests Hearing & to Engage in Discovery for Hearing on Contention.Supporting Documentation & Certificate of Svc Encl ML20247Q6761989-09-22022 September 1989 Intervenors Second Informational Suppl to Low Power Contentions Filed on 890721 & 0828.* Incorporates Encl Plant Startup Test Procedure 1-ST-22,Rev 2 Into Low Power Testing Contentions.W/Supporting Info & Certificate of Svc ML20246N1001989-09-0101 September 1989 Intervenors Reply to Responses of Applicant & Staff Re Intervenors Motion to Admit Contention,Or,In Alternative,To Reopen Record & Request for Hearing.* Contention Raises New Issues & Should Be Admitted.W/Certificate of Svc ML20247E0321989-07-21021 July 1989 Intervenors Motion to Admit Contention,Or in Alternative,To Reopen Record & Request for Hearing.* Requests Contentions Re Deficiencies in Training,Mgt Control,Supervision, Communication & Procedure Compliance Be Admitted ML20246P2041989-07-0505 July 1989 Joint Intervenor (Ji) Contentions on Spmc & June 1988 Graded Exercise.* ML20248F4691989-04-0303 April 1989 Seacoast Anti-Pollution League (Sapl) Trial Brief on Contention Ji 56 & Sapl Contentions EX-2,4,6,7,8,12,13 & 14.* Svc List Encl ML20206M9761988-11-23023 November 1988 NRC Staff Response to 881114 Board Order Requesting Comments on Significance of ALAB-903 for Seabrook Proposed General Exercise Contentions.* Contentions & Bases Should Be Denied. Certificate of Svc Encl ML20206M9431988-11-22022 November 1988 New England Coalition on Nuclear Pollution Comments on Significance of ALAB-903 to Seabrook Offsite Exercise Contentions.* Svc List Encl ML20206M9031988-11-22022 November 1988 Seacoast Anti-Pollution League Comments on Significance of ALAB-903 to Exercise Contentions.* Svc List Encl ML20205R7201988-11-0202 November 1988 Town of Hampton Contention on Applicant Plan to Fund Decommissioning Costs of Seabrook Station.* Supporting Documentation & Certificate of Svc Encl ML20205R5661988-11-0202 November 1988 Seacoast Anti-Pollution League Contentions on Applicant Plan in Response to NRC Order CLI-88-07.* Supporting Documentation Encl ML20205R5441988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Financial Qualifications to Operate Seabrook Nuclear Power Station.* Supporting Documentation & Certificate of Svc Encl ML20205R4971988-11-0202 November 1988 New England Coalition on Nuclear Pollution Contentions on Applicant Decommissioning Plan,Motion for Stay of Low Power Operation & Motion to Reopen Record.* Supporting Info & Svc List Encl ML20205R4821988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Decommissioning Plan for Seabrook Nuclear Power Station.* ML20205E0011988-10-24024 October 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to Commonwealth of Ma Atty General Exercise Contentions.* Certificate of Svc Encl ML20205E0271988-10-21021 October 1988 New England Coalition on Nuclear Pollution (Necnp) & Town of Hampton (Toh) Reply to Applicant & NRC Staff Responses to Contentions Toh/Necnp EX-2 & Toh/Necnp EX-3.* Svc List Encl ML20205D8051988-10-21021 October 1988 Town of Hampton & New England Coalition on Nuclear Pollution Reply to Responses of Staff & Applicant to Intervenor Contentions on Graded Exercise.* Certificate of Svc Encl ML20206C1951988-10-18018 October 1988 Seacoast Anti-Pollution League (Sapl) Reply to Applicant & Staff Responses to Sapl Contentions on June 1988 Graded Exercise.* Svc List Encl ML20204G9731988-10-13013 October 1988 NRC Staff Response to Intervenors Contentions on Graded Exercise.* Proposed General Exercise Contentions Should Be Admitted for Litigation & Proferred Contentions Should Be Denied Admission.Certificate of Svc Encl ML20154S4571988-09-28028 September 1988 Applicant Response to Intervenor Contentions on June 1988 Seabrook Exercise.* Intervenor Contentions Should Be Disposed Of.Certificate of Svc Encl ML20154P3461988-09-21021 September 1988 New England Coalition on Nuclear Pollution & Town of Hampton Contentions Re 1988 Exercise of Offsite Plans & Preparedness for Plant Emergency Planning Zone.* Svc List Encl ML20154K8741988-09-21021 September 1988 Commonwealth of Ma Atty General Exercise Contentions Submitted in Response to June 1988 Plant Initial full- Participation Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154K9331988-09-21021 September 1988 Town of Hampton & New England Coalition on Nuclear Pollution Emergency Planning Contentions on 880628-29 Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154N9061988-09-20020 September 1988 Seacoast Anti-Pollution League Contentions on Graded Exercise.* Svc List Encl ML20154D7431988-09-12012 September 1988 New England Coalition on Nuclear Pollution Petition for Review of ALAB-899.* Petition Should Be Granted on Basis That Integrity of RCS Significantly Paramount to Safe Operation of Plant.W/Certificate of Svc ML20151A6461988-07-0707 July 1988 NRC Staff Response to Town of Salisbury Amended Contentions Re Applicant Plan for Commonwealth of Ma Communities.* Applicant Untimely Amends to Contentions Should Be Rejected. Certificate of Svc Encl ML20151A6301988-07-0606 July 1988 NRC Staff Response to City of Haverhill Detailed Contentions.* City of Haverhill late-filed Contentions Should Be Rejected.Certificate of Svc Encl ML20196G7031988-06-27027 June 1988 Applicant Response to City of Haverhill Detailed Contentions.* Contentions Should Be Rejected & City Should Be Denied Admission as Party,Per 10CFR2.714.Supporting Documentation & Certificate of Svc Encl ML20196A3761988-06-22022 June 1988 New England Coalition on Nuclear Pollution (Necnp) Reply to Applicant & NRC Staff Response to Necnp Contentions on Spmc.* Certificate of Svc Encl ML20196A3991988-06-22022 June 1988 Reply of Massachussetts Atty General to Responses of NRC Staff and Applicant to Contentions 7 Through 83 Filed by Massachussetts Atty General.* Certificate of Svc Encl ML20196A5261988-06-22022 June 1988 Town of Amesbury Reply to NRC Staff & Applicant Responses to Town of Amesbury Contentions on Seabrook Plan for Massachussetts Communities.* Certificate of Svc Encl ML20196A8701988-06-20020 June 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to First Six Contentions Filed by Commonwealth of Ma Atty General.* ML20151N6271988-06-17017 June 1988 Town of Salisbury Reply to Applicant Response to Intervenor Contentions on Seabrook Plan for State of Ma Communities ML20151A8361988-06-17017 June 1988 Reply of Town of West Newbury to Responses of Applicant & NRC Staff to Intervenors Contentions Re Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl ML20151N6461988-06-17017 June 1988 Town of Salisbury Amended Contentions Re Applicant Plan for State of Ma Communities.Certificate of Svc Encl 1999-07-20
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20237C6981998-08-18018 August 1998 Sapl/Necnp Reply to Naesco Response to Proposed Contentions.* Board Should Admit Sapl/Necnp Contentions 1-4 & North Atlantic Energy Svcs Corp Arguments to Contrary. W/Certificate of Svc ML20237C6791998-08-18018 August 1998 Sapl/New England Coalition on Nuclear Pollution Reply to Staff Answer to Contentions.* Petitioners Believe Board Can & Should Give Cases Consideration W/O Filing of Addl,But Not Substantively Different Contention.W/Certificate of Svc ML20237A0501998-08-10010 August 1998 North Atlantic Energy Svc Corp Response to Proposed Contentions.* Petitioners Failed to Propose Admissible Contention.Request for Hearing & Petition to Intervene,As Applied to Both Petitioners Should Be Denied ML20236X9281998-08-10010 August 1998 NRC Staff Answer to Contentions.* for Reasons Stated,All of Contentions Proposed Should Be Rejected & Proceeding Should Be Terminated.W/Certificate of Svc ML20066H2581991-02-14014 February 1991 Response of Ma Atty General & Necnp to ASLB Order of 910124.* Intervenors Believe ASLB Should Reopen Record, Permit Discovery & Hold Hearing on Beach Sheltering Issues. W/Certificate of Svc ML19332D7241989-11-21021 November 1989 Intervenors Motion for Clarification Or,In Alternative,For Reconsideration.* Clarification or Reconsideration of Scheduling Requirements Set by Commission 891121 Order Requested.Certificate of Svc Encl ML19332D5191989-11-15015 November 1989 Applicant Answer to Intervenors Motion to Admit late-filed Contention & Reopen Record Based Upon Withdrawal of Commonwealth of Ma Emergency Broadcast Sys Network & Wcgy.* Motion Should Be Denied Since Results Unlikely to Change ML19325E0171989-10-20020 October 1989 Applicant Answer to Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Motion to Assert Addl Bases for Original Onsite Exercise Contention JI-Onsite Ex-1 Should Be Denied.W/Certificate of Svc ML19325E0011989-10-20020 October 1989 Applicant Response to Intervenors Motion to Amend Intervenors Motions of 890929 & 1013 to Admit Contentions on 890927 Onsite Emergency Plan Exercise.* Issue Re Admittance Committed to Board Discretion.Certificate of Svc Encl ML20248J3511989-10-13013 October 1989 Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Advises That Applicant Contentions Filed on 890929 to Admit Addl Bases Re Scope of Onsite Exercsise Should Be Admitted.W/Certificate of Svc ML20248J0601989-09-28028 September 1989 Intervenors Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Requests Hearing & to Engage in Discovery for Hearing on Contention.Supporting Documentation & Certificate of Svc Encl ML20247Q6761989-09-22022 September 1989 Intervenors Second Informational Suppl to Low Power Contentions Filed on 890721 & 0828.* Incorporates Encl Plant Startup Test Procedure 1-ST-22,Rev 2 Into Low Power Testing Contentions.W/Supporting Info & Certificate of Svc ML20246N1001989-09-0101 September 1989 Intervenors Reply to Responses of Applicant & Staff Re Intervenors Motion to Admit Contention,Or,In Alternative,To Reopen Record & Request for Hearing.* Contention Raises New Issues & Should Be Admitted.W/Certificate of Svc ML20247E0321989-07-21021 July 1989 Intervenors Motion to Admit Contention,Or in Alternative,To Reopen Record & Request for Hearing.* Requests Contentions Re Deficiencies in Training,Mgt Control,Supervision, Communication & Procedure Compliance Be Admitted ML20246P2041989-07-0505 July 1989 Joint Intervenor (Ji) Contentions on Spmc & June 1988 Graded Exercise.* ML20248F4691989-04-0303 April 1989 Seacoast Anti-Pollution League (Sapl) Trial Brief on Contention Ji 56 & Sapl Contentions EX-2,4,6,7,8,12,13 & 14.* Svc List Encl ML20206M9761988-11-23023 November 1988 NRC Staff Response to 881114 Board Order Requesting Comments on Significance of ALAB-903 for Seabrook Proposed General Exercise Contentions.* Contentions & Bases Should Be Denied. Certificate of Svc Encl ML20206M9431988-11-22022 November 1988 New England Coalition on Nuclear Pollution Comments on Significance of ALAB-903 to Seabrook Offsite Exercise Contentions.* Svc List Encl ML20206M9031988-11-22022 November 1988 Seacoast Anti-Pollution League Comments on Significance of ALAB-903 to Exercise Contentions.* Svc List Encl ML20205R7201988-11-0202 November 1988 Town of Hampton Contention on Applicant Plan to Fund Decommissioning Costs of Seabrook Station.* Supporting Documentation & Certificate of Svc Encl ML20205R5661988-11-0202 November 1988 Seacoast Anti-Pollution League Contentions on Applicant Plan in Response to NRC Order CLI-88-07.* Supporting Documentation Encl ML20205R5441988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Financial Qualifications to Operate Seabrook Nuclear Power Station.* Supporting Documentation & Certificate of Svc Encl ML20205R4971988-11-0202 November 1988 New England Coalition on Nuclear Pollution Contentions on Applicant Decommissioning Plan,Motion for Stay of Low Power Operation & Motion to Reopen Record.* Supporting Info & Svc List Encl ML20205R4821988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Decommissioning Plan for Seabrook Nuclear Power Station.* ML20205E0011988-10-24024 October 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to Commonwealth of Ma Atty General Exercise Contentions.* Certificate of Svc Encl ML20205E0271988-10-21021 October 1988 New England Coalition on Nuclear Pollution (Necnp) & Town of Hampton (Toh) Reply to Applicant & NRC Staff Responses to Contentions Toh/Necnp EX-2 & Toh/Necnp EX-3.* Svc List Encl ML20205D8051988-10-21021 October 1988 Town of Hampton & New England Coalition on Nuclear Pollution Reply to Responses of Staff & Applicant to Intervenor Contentions on Graded Exercise.* Certificate of Svc Encl ML20206C1951988-10-18018 October 1988 Seacoast Anti-Pollution League (Sapl) Reply to Applicant & Staff Responses to Sapl Contentions on June 1988 Graded Exercise.* Svc List Encl ML20204G9731988-10-13013 October 1988 NRC Staff Response to Intervenors Contentions on Graded Exercise.* Proposed General Exercise Contentions Should Be Admitted for Litigation & Proferred Contentions Should Be Denied Admission.Certificate of Svc Encl ML20154S4571988-09-28028 September 1988 Applicant Response to Intervenor Contentions on June 1988 Seabrook Exercise.* Intervenor Contentions Should Be Disposed Of.Certificate of Svc Encl ML20154P3461988-09-21021 September 1988 New England Coalition on Nuclear Pollution & Town of Hampton Contentions Re 1988 Exercise of Offsite Plans & Preparedness for Plant Emergency Planning Zone.* Svc List Encl ML20154K8741988-09-21021 September 1988 Commonwealth of Ma Atty General Exercise Contentions Submitted in Response to June 1988 Plant Initial full- Participation Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154K9331988-09-21021 September 1988 Town of Hampton & New England Coalition on Nuclear Pollution Emergency Planning Contentions on 880628-29 Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154N9061988-09-20020 September 1988 Seacoast Anti-Pollution League Contentions on Graded Exercise.* Svc List Encl ML20154D7431988-09-12012 September 1988 New England Coalition on Nuclear Pollution Petition for Review of ALAB-899.* Petition Should Be Granted on Basis That Integrity of RCS Significantly Paramount to Safe Operation of Plant.W/Certificate of Svc ML20151A6461988-07-0707 July 1988 NRC Staff Response to Town of Salisbury Amended Contentions Re Applicant Plan for Commonwealth of Ma Communities.* Applicant Untimely Amends to Contentions Should Be Rejected. Certificate of Svc Encl ML20151A6301988-07-0606 July 1988 NRC Staff Response to City of Haverhill Detailed Contentions.* City of Haverhill late-filed Contentions Should Be Rejected.Certificate of Svc Encl ML20196G7031988-06-27027 June 1988 Applicant Response to City of Haverhill Detailed Contentions.* Contentions Should Be Rejected & City Should Be Denied Admission as Party,Per 10CFR2.714.Supporting Documentation & Certificate of Svc Encl ML20196A3761988-06-22022 June 1988 New England Coalition on Nuclear Pollution (Necnp) Reply to Applicant & NRC Staff Response to Necnp Contentions on Spmc.* Certificate of Svc Encl ML20196A3991988-06-22022 June 1988 Reply of Massachussetts Atty General to Responses of NRC Staff and Applicant to Contentions 7 Through 83 Filed by Massachussetts Atty General.* Certificate of Svc Encl ML20196A5261988-06-22022 June 1988 Town of Amesbury Reply to NRC Staff & Applicant Responses to Town of Amesbury Contentions on Seabrook Plan for Massachussetts Communities.* Certificate of Svc Encl ML20196A8701988-06-20020 June 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to First Six Contentions Filed by Commonwealth of Ma Atty General.* ML20151N6271988-06-17017 June 1988 Town of Salisbury Reply to Applicant Response to Intervenor Contentions on Seabrook Plan for State of Ma Communities ML20151A8361988-06-17017 June 1988 Reply of Town of West Newbury to Responses of Applicant & NRC Staff to Intervenors Contentions Re Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl ML20151N6461988-06-17017 June 1988 Town of Salisbury Amended Contentions Re Applicant Plan for State of Ma Communities.Certificate of Svc Encl 1999-07-20
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210Q7531999-08-11011 August 1999 Order Approving Application Re Corporate Merger (Canal Electric Co). Canal Shall Provide Director of NRR Copy of Any Application,At Time Filed to Transfer Grants of Security Interests or Liens from Canal to Proposed Parent ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210J8501999-08-0303 August 1999 Order Approving Transfer of License & Conforming Amend.North Atlantic Energy Service Corp Authorized to Act as Agent for Joint Owners of Seabrook Unit 1 ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20206A1611999-04-26026 April 1999 Memorandum & Order.* Informs That Montaup,Little Bay Power Corp & Nepco Settled Differences Re Transfer of Ownership of Seabrook Unit 1.Intervention Petition Withdrawn & Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205M7621999-04-15015 April 1999 Notice of Withdrawal of Intervention of New England Power Co.* New England Power Co Requests That Intervention in Proceeding Be Withdrawn & Hearing & Related Procedures Be Terminated.With Certificate of Svc CLI-99-06, Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 9904071999-04-0707 April 1999 Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 990407 ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20204E6401999-03-24024 March 1999 Protective Order.* Issues Protective Order to Govern Use of All Proprietary Data Contained in License Transfer Application or in Participants Written Submission & Oral Testimony.With Certificate of Svc.Served on 990324 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML20203F9471999-02-0909 February 1999 License Transfer Application Requesting NRC Consent to Indirect Transfer of Control of Interest in Operating License NPF-86 ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20195K4061998-11-24024 November 1998 Memorandum & Order.* North Atlantic Energy Services Corp Granted Motion to Withdraw Proposed Amends & Dismiss Related Adjudicatory Proceedings as Moot.Board Decision LBP-98-23 Vacated.With Certificate of Svc.Served on 981124 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20154C8171998-10-0606 October 1998 Notice of Appointment of Adjudicatory Employee.* Notice Given That W Reckley Appointed as Commission Adjudicatory Employee to Advise Commission on Issues Related to Review of LBP-98-23.With Certificate of Svc.Served on 981006 CLI-98-18, Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 9810061998-10-0505 October 1998 Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 981006 ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20154F9891998-09-29029 September 1998 License Transfer Application Requesting Consent for Transfer of Montaup Electric Co Interest in Operating License NPF-86 for Seabrook Station,Unit 1,to Little Bay Power Corp ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20151Z5611998-09-18018 September 1998 Order.* Pursuant to Commission Order CLI-98-18 Re Seabrook Unit 1 Proceeding,Schedule Described in Board 980904 Memorandum & Order Hereby Revoked Pending Further Action. with Certificate of Svc.Served on 980918 ML20151Y0331998-09-17017 September 1998 Order.* All Parties,Including Util,May File Brief No Later than 981007.Brief Shall Not Exceed 30 Pages.Commission May Schedule Oral Argument to Discuss Issues,After Receiving Responses.With Certificate of Svc.Served on 980917 ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed 1999-09-02
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'. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '86 MAR -7 PI2 :41 Before the Nuclear Regulatory Commission GFFitt . .. ..
00CdET!% % i .p.,
BRANCH
)
In the Matter of ) Docket Nos. 50-443-OL
) 50-444-OL PUBLIC SERVICE COMPANY )
OF NEW HAMPSHIRE )
(Seabrook Station, Units I and II )
)
THE STATE OF NEW HAMPSHIRE'S RESPONSE'TO CONTENTIONS FILED BY NECNP, THE COMMONWEALTH OF MASSACHUSETTS, THE TOWNS OF RYE, HAMPTON, SOUTH HAMPTON, KENSINGTON, AND HAMPTON FALLS ON THE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN Introduction The State of New Hampshire responds below to certain of the contentions on the New Hampshire Radiological Emergency Response Plan (hereinafter referred to as the NHRERP or State Plan)1 . The State's response herein pertains primarily to the issues raised by the parties relating to the planning process itself, as opposed to the adequacy of the plan. As to the numerous other issues raised in the contentions filed by the eight parties on February 24, 1986, the State of New Hampshire disputes in many instances erroneous factual allegations and assertions contained in these contentions. At appropriate stages in the litigation of these contentions, the State
' will detail its further responses.
1The New Hampshire Radiological Emergency Response Plan consists of some thirty-eight volumes, nineteen of which include specifically the emergency plans for the localities in the Seabrook EPZ. These volumes are intended as one comprehensive State Plan and 4
must be viewed as such in reviewing the adequacy of State and local radiological emergency planning.
8603110496 860306 PDR ADOCK 05000443 PDR c "
G JC. D'
Several of the contentions filed on February 24, 1986 relate to portions of the NHRERP, which nad not yet been made available to the parties. See, for instance, NECNP Contention RERP-9, SAPL Contention 14, SAPL Contention 15, SAPL Contention 13. This will advise the Board and parties that the following material has been submitted to FEMA by.the State, and has been or will soon be served on the Board and parties:
- New Hampshire Compensatory Plan;
- Additional Letters of Agency to be included in Volume 5 of the NHRERP;
- Voluine 6 of the RERP (pertaining to Evacuation Time Estimates);
- Draft public information material.
Town of Hampton Contentions I and II &
In these two contentions, the Town of Hampton contends in essence that the planning process failed to comply with state and federal law. . In response to these contentions, the State first flatly rejects the suggestion that 'he State has ignored concerns raised by the Town of Hampton and has failed to cooperate wit; the Town in developing the NHRERP, including the Town of Hampton local plan.
Moreover, issues relating to the adequacy of the planning process are irrelevant to the issue before this Board as to whether the plan itself satisfies federal requirements. The Town's assertion in Contention I that the planning process was violative in some fashion of FEMA regulations and the Town's allegation in Contention II that the planning process was inconsistent with state law are not litigable issues in this proceeding.
a 4
r
[' '
NECNP Contentions HERP-1 and NHLP-1 NECNP asserts in these two related contentions that the NHRERP
! is inadequate because some municipalities have not approved or adopted the plans, and have refused to participate in testing of the ,
j plans. As'noted above with regard to the Town of Hampton Contentions
'I and II, such allegations do not raise issues regarding the adequacy of the plans themselves, but relate only to the way in which the
.j plans were developed. Consequently, these two contentions, in and of themselves, do not raise litigable issues in tnis proceeding.
- In response to NECNP's suggestion that local governments must approve the-NHRSRP, including their own local plans, the State
! invites the Board's' attention to the case of Vernet, et al. v. Town .
of Exeter, Rockingham County Superior Court, No. 86-E-06 (February '
i 14, 1986). A copy of the Court's decision in that case is attached I hereto as Appendix A. As the Board will note in reviewing that I
decision, the Court squarely held in that case that there is no state requirement for Town approval of the radiological emergency response
- plans.
! HECNP Contention RERP-8 NECNP in this contention alleges generally that sneltering is not an " adequate protective measure" for Seabrook, and that tne NdRERP does not provide " adequate criteria" for the choice of protective measures.
'As NECNP correctly points out, however, sheltering is only one of the protective actions available in the event of a radiological emergency at seabrook station. It is the adequacy of all protective
measures taken together which is the relevant inquiry of this Board in reviewing the NHRERP. Consequently, NECNP's assertion that sheltering is insufficient does not set.forth a litigable issue.
NECNP Contention NHLP-2(e)
In subpart (e) to its contention NHLP-2, NECNP asserts that "each emergency response for organization shoulo be surveyed to determine whether they intend to stay in the EPZ to implement the plan during an emergency". This contention does not state a deficiency in the NHRERP or any of its local plans. Moreover, there is no requirement for each emergency response organization to conduct j such a survey. As stated, therefore, this contention does not raise-a litigable issue.
i j
NECNP Contention NHLP-3(a)
NECNP concludes in this contention that a dedicated telephone line from Public Service Company to each Town's emergency response organization is required. Insofar as there is no regulatory 4
requirement for such a dedicated telephoto line, this contention i
i raises no litigable issue.
NECNP Contention NHLP-3(b) l In this contention NECNP asserts that"ln]otification of any plant malfunction should be mechanically communicated to an offsite entity." Insofar as there is no regulatory requirement for such a i
j mechanical notification system, there is no regulatory basis for this I
contention.
l i
l l
I
F
-S-Contention of Attorney General Francis X. Bellotti Relative to Emergency Planning for the New Hampshire Beach Communities Attorney General Bellotti has refiled his contentions relative to the Emergency Planning for the New Hampshire Beach Communities, which he initially filed on September 9, 1983. Tne contention raises generally the issue of the adequacy of sheltering and evacuation as protective actions for the beach area transient population in the Towns of Seabrook, Hampton, North Hampton and Rye. To the extent that Attorney General Bellotti asserts in his contention that the protective actions of evacuation and sheltering must ensure complete protection to the transient beach population under all circumstances, then it sets forth no regulatory basis.
Hampton Falls Contention 1 With regard to Hampton Falls' assertion in its Contention 1 that Town approval :Us necessary for implementation of the NHRERP, including the Hampton Falls local plan, please refo: to the State's response to NECNP Contentions RERP-1 and 14HLP-1 above.
Town of Rye Contention 3 To the extent that the Town of Rye asks the Licensing Board in this contention to declare that the local plan for tne Town of Rye is void and of no effect, the Town raises no issue which is litigable in this proceeding. As to the Town's assertions relating to the process by which the NHRERP was developed, please refer to the State's response to NECNP Contentions RERP-1 an NHLP-1 and Town of Hampton's Contentions I and II.
7_.
e i-Town of Kensington Contention 11' In this contention, the Town of Kensington asserts that its local plan should provide'for communications with federal emergency
- response organizations. Neither of the citations prompted by the Town, however, (10 CFR: 550.47, Appendix E, (E)(9)(u) and NOREG 0654 SII, F.1.c. requires such a communications link between tne Town and federal emergency response organizations. Consequently, there is no regulatory basis for thi's contention.
Town of South Hampton Contentions 1 and 3 The Town of South Hampton in these two contentions asserts that i
I the NHRERP is inadequate because it lacks generally letters of agreement with local emergency response agencies and volunteer emergency workers. Insofar as the Town claims that letters of agreement are necessary for individual emergency workers, the contention fails to set forth a regulatory basis.
l Respectfully submitted, THE STATE OF NEW HAMPSHIRE STEPHEN E. MERRILL ATTORNEY GENERAL Dated: March 6, 1986 By _A '
George Daha Bisbee \>
Assistant Attorney General Environmental Protection Bureau Of fice of ttua Attorney General 3
25 Capitol Street Concord, NH 03301-6397 Telephone (603) 271-3678
[- . .
APPENDIX A TIJe # tate of Seto ll?ampsfjire ROCEINGHAM. SS.
SUPERIOR COURT
- PENNY VERNET, ET AL *
- v.
- DECISION There are two issues presented by this petition.
First, whether the citizens of a town,- by vote of the town meeting, may prohibit town officials or agencies from implement- '
ing a nuclear emergency response plan prepared by or for the -*
community under the direction of the State Civil Defense Agency.
They may not.
Second, whether the citizens may require the selectmen to present any such plan to the town meeting for approval by majority vote. They may.
Under New Hampshire law the Governor is authorized and empowered to prepare a comprehensive plan and program for the civil defense of the state. He is also authorized and empowered to coordinate the preparation of plans and programs for civil defense by the political subdivisions of the state. This authority includes responsibility for studying, planning and implementing a nuclear
2-emergency response plan which provides adequate protective measures i
, in'the event of an emergency at Seabrook.
RSA 107, RSA 107-B.
In accordance with the law, the Governor has delegated civil defense authority to the State Civil Defense Agency and its director.
RSA 107:3. In the _ exercise of his responsibilities, the director is required to seek and has sought the cooperation and participation of local units of government. There is no state or federal , requirement, however, that the selectmen or the citizens of towns approve nuclear emergency response plans.
Local refusal to cooperate or to approve plans cannot prevent the civil defense director from carrying out his duty to initiate and implement a nuclear emergency response plan. A reasonable interpretation of the relevant statutes and decisions does not' support the conclusion that the legislature intended to permit a local unit of government either by vote of the selectmen or vote of
~
the town meeting to defeat the clear purpose of the legislation.
Parker-Young Co. v. S ta te , 83 N.H. 551, 557 (1929). The' powers conferred by RSA 41:8, RSA 107, RSA 107-B clearly establish a statutory scheme for nuclear emergency response planning which cannot be over-ridden by a town.
While it is true that in New Hampshire town meetings the voters are sovereigns and their will when duly expressed is supreme, the power of the town meeting is not limitless. Attorney General v.
Fulsom, 69 N.H. 556, 557 (1899). The town meeting, then, is 7
w e
- 4 without authority to control the selectmen in the exercise of those i
powers which are specifically conferred on them by the legislature.
. ~
Moulton v. Beals, 98 N.H. 461, 463 (1954). ~ Town meeting is also ;
without authority to enact any provision which conflicts with state statute. Piper v. Meredith,,110 N.H. 291~(1970).
Authority for civil defense in the towns is conferred by statute upon the selectmen, rendering them " state officers" and not agents or servants of the town in matters of civil defense. As officers of the state they must carry out the state civil defense director's plans. (See Moulton v. Beals , supra.) As agents of the ~ town they must also represent the town in the planning process to the extent that participation does not interfere with their duties as state officers.
Approving radiological emergency plans does not constitute
! " ordinary business of the town." Rich v. Errol, 51 N.H. 350, 354 l (1871). Approval of such plans, therefore, is not within the scope l
! of selectmen authority to " manage the prudential af fairs of the town."
! RSA 41:8; Moulton v. Beals, suora. Nor does state or federal law give authority to selectmen to approve these plans.
Even. without a requirement for town approval of the plan, the Nuclear Regulatory Commission and the State Civil Defense , Agency.
i do solicit and consider local comment and response to the plans.
t (Defendant's Exhibit C,~ letter, New Hampshire Civil Defense Agency i
to Exeter Town Manager.)
While citizens of a town cannot interfere with the state '
director's_ activities, and cannot prohibit selectmen from implement-ing the director's orders, that restraint does not foreclose them from considering plans at a town meeting._ It is not inconsistent
/
with selectmen duties as state officers that they be required to present. such plans at town meeting when directed to do so by the voters. Or that they do so on their own initiative.
New Hampshire has an historic tradition.of town meeting. From the resolution of local problems to the discussion of national issues, town meeting has served for hundreds of years as an open forum for citizen debate. There may not be in this century an issue for the ,
citizens of Exeter with more impact upon their peace, welfare and
' interest than the emergency nuclear response plan.
To the extent the state and federal governments place importance on an expression of approval or disapproval of the plan by the town, the citizens of the town may validly seek to provide that expression by vote at the town meeting.
"The Exeter plan is, in fact, going to be the Exeter plan. We are not going to impose anything on Exeter."
(State Civil Defense Director to the citizens of Exeter, February 15, 1984.)
So ordered.
\Me k
'J seph ). Nadeau, Presiding Justice Dated: 2-14-86
i .
e
- CERTIFICATE OF SERVICE C0(.ME T ED I, George Dana Bisbee, one of the attorneys for the Applican't98kC herein, hereby certify that on the 5th day of March, 1986, I made servi e of the.within document by mailing copies thereof, poggagg ,.
LFFICE de ;n.: . ...
Administrative Judge Helen Hoyt Administrative Judge ShcM 6WiUir;fdacf Wolfe, Chairman BRANCH Chairperson Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel ~
U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Dr. Emmeth A. Luebke Dr. Jerry Harbour Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Philip Ahrens, Esquire Thomas J. Dignan, Jr.,' Esquire Assistant Attorney General R. K. Gad, III, Esquire Department of the Attorney General Ropes & Gray State House Station 6 225 Franklin Street Augusta, ME 04333 Boston, MA 02110 Jo Ann Shotwell, Esquire Sherwin E. Turk, Esquire Assistant Attorney General Deputy Assistant Chief Department of the Attorney General Hearing Counsel One Ashburton Place, 19th Floor Office of the Executive Counsel Boston, MA 02108 Director U.S. Nuclear Regulatory Commission Ms. Diana P. Randall Washington, DC 20555 70 Collins Street Seabrook, NH 03874 Robert A. Backus, Esquire Backus, Meyer & Solomon Diane curran, Esquire 116 Lowell Street Harmon & Weiss P. O. Box 516 20001 S Street, N.W. Manchester, NH 03105 Suite 430 Washington, DC 20009 Anne Verge, Chairperson Board of Selectmen Town IIall South Hampton, Nil 03827
r O
Paul McEachern, Esquire Matthew T. Brock, Esquire Mr. Patrick McKeon Shaines & McEachern Selectmen's Office 25 Maplewood Avenue 10 Central Road P. O. Box 360 Rye, NH 03870 Portsmouth, NH 03801 Mr. Calvin A. Canney Ms. Roberta C. Pevear City Manager The Town of Hampton Falls City Hall Drinkwater Road 125 Daniel Street Hampton Falls, NH 03844 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Angie Machiros Tne Town of Kensington Chairman of the RFD 1 Board of Selectmen East Kingston, NH 03827 Town of Newbury Newbury, MA 01950 Senator Gordon J. Humphrey Mr. Richard E. Sullivan U.S. Senat'e Mayor Washington, DC 20510 City Hall (Attn: Tom Burack) Newburyport, MA 01950 Senator Gordon J. Humphrey Town Manager's Office 1 Pillsbury Street Town Hall Concord, NH 03301 Friend Street (Attn: Herb Boynton) Amesbury, MA 01913 Mr. Thomas Powers Brentwood Board of Selectmen Town Manager RFD Dalton Road Town of Exeter Brentwood, NH 03833 10 Front Street Exeter, NH 03833 Gary W. Holmes, Esquire Holmes & Ells H. Joseph Flynn 47 Winnacunnet Road Assistant General Counsel Hampton, NH 03841 office of General Counsel Federal Emergency Management Richard A. Hampe, Esquire Agency Hampe & McNicholas 500 C Street, S.W. 35 Pleasant Street Washington, DC 20472 Concord, NH 03301 f%
J George' Dana Bisbde'