ML20154E710

Fourth Suppl to Commonwealth of Ma Atty General Jm Shannon Petition Under 10CFR2.758 for Waiver of or Exception from Public Util Exemption from Requirement of Demonstration of Financial Qualification.* Certificate of Svc Encl

ML20154E710
Person / Time
Site:	Seabrook
Issue date:	09/15/1988
From:	Dean G MASSACHUSETTS, COMMONWEALTH OF
To:	NRC COMMISSION (OCM)
Shared Package
ML20154E698	List: ML20154E694 ML20154E710
References
OL-1, NUDOCS 8809190105
Download: ML20154E710 (21)

Text

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w. . . . . . w . . . , . -+ . ces evs e **a e2504171 P.06 September 15, 1988 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the COMMISSION In the Matter of )

)

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

)

(Seabrook Station, Unit 1 ) (Onsite Emergency Planning and 2) ) and Safety Issues)

)

FOURTl! SUPPLIDODfT TO MASSACHUSITITS ATTORNEY GENERAL JAMES M. SNANNON'S PETITION UNDER 10 C.F.R. 5 2.758 FOR A NAIVER OF OR AN EXCEPTION FROM THE PUBLIC UTILITY EXEMPTION FROM THE REQUIREMENT OF A DEMONSTRATION OF FINANCIAL QUALIFICATION Presently before the Nuclear Regulatory Conmission

("Commission") pursuant to the certification of the Appeal Board in ALAB-695 is MASSACHUSETTS ATTORNEY GENERAL JAMES M. SHAFNON'S PETITION UNDER 10 C.F.R. 5 2.758 FOR A WAIVER OF OR AN EXCEPTION FROM THE PUBLIC UTILITY EXEMPTION FROM THE REQUIREMENT OF A DEMONSTRATION OF FINANCIAL QUALIFICATION. The Massachusetts Attorney General submits this Fourth Supplenent to that Petition to bring to the commission's attention new information that i

8009190105 800915 3 PDR ADOCK 050 0

U:visivee ass ai .aom ECPS-505TCr4 **co 0.2'04171 P,07 demonstrates the necessity of granting a wavier of or exception from the public utility exemption from the requirenent of a demonstration of financial qualification, i.e., new information thrit further demonstrates the inappropriateness of applying a generic presumption that the rate process will assure that a

adequate funding will be available to cover the costs of safe low

' " *.n power operation and the permanent shut down of the Seabrook Nuclear Power Station.

l BACKGROUND on September 9, 1988 the Attorney General flied with the Commission a MCTION OF MASSACMUSETTS ATTORNEY GENERAL JAMES M.

SIIANNON FOR LEAVE TO FILE A DOCUMENT NOT AUTHORIZED BY THE COMMISSION'S RULES 0F PRACTICE accompanied by the THIRD SUPPLEMENT TO MASSACHUSETTS ATTCRNEY GENERAL JAMES M. SHANNON'S PETITION UNDER 10 C.F.R. 9 2.158 FOR A WAIVER OF OR AN EXCEPTION FROM THE PUBLIC UTILITY EXEMPTION FROM THE REQUIREMENT OF A DEMONSTRATION OF FINANCIAL QUALIFICATION ("MASS AG THIRD SUPPLEMENT"). The MASS AG THIRD SUPPLEMENT was filed to bring i

to the Commission's attention information contained in the August 31, 1988, Response of Public Service Company of New Hampshire

("Public Service") to the NRC Request for Financial Information.

On September 9 and 13, 1988, subsequent to the filing of the MASS AG THIRD SUPPLEMENT, Public Service supplemented its August 31, 1988 response. The September 9, 1988 supplemental response 2

w ay1ra 1:144 **=* ECFS-EOSTCr4 **** 0201171 P.03 included a copy of the Bankruptcy Court decision which was appended to the MASS AG THIRD SUPPLEMENT as Third Supplemental Appendix III and referenced an intention on Public Service's part to seek a rehearing in the Bankruptcy court at some unspecified time in "the near future." The September 13, 1988 supplemental response filed by Public Service was provided under cover of

• n 1etter which described the supplemerital response as providing "a description of the further progress which has been made in developing arrangements to cover through 1989 HMWEc's share of the costs" of low power operation and permanent shut down following a period of low power operation, t

THE IMPLICATION OF PUBLIC SERVICE'S SUPPLEMENTS l

l The Massachusetts Attorney General submits that the September 13, 1988 supplemental response itself is substantial evidence i

that the public utility exemption from the requirement of a demonstracion of financial qualification should be waived in the 1

circumstances of the low power operation license application for I

the Seabrook Nuclear Power Station: it demonstrates beyond cavil  ;

j that ths rate process does not now provide assurance that funds L

will be available to cover the costs of safe 1:w power operation l and the permanent shut down of the Seabrook Nuclear Power Station  !

i and, thus, that application of the public utility exemption would not serve the purposes for which rule was adopted. 10 c.P.R. t l 2.758(b).

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To bring this important information to the commission's attention, the Attorney General hereby supplements his March 7, 1988 petition by stating:

1. That Attachment 1 to Public Service's September 13, 1988 supplemental responsa indicates that:

i

a. An assured source of funds to make up for those not

1. w available through November 30, 1988 due to MMWEC's decision to withhold payments to t 'te project does not exist as connecticut Light and Power company's commitment to provide funds to cover the shortfall through November 30, 1988 does not extend to all MMWEC's share of project costs but is limited to a specified amount and does not cover the "property taxes associated with HMMEC's ownership share";

b. An uncured default by one of the Joint Applicants continues because connecticut Light and Power Conpany's provision of funds is expressly not "on MMWEC's behalf" and 2

pursuant to an understanding that auch "should not be i construed as curing HMWEC's deficiency."  ;

2. That Public Service's September 13, 1988 supplemental response makes manifest the substantial uncertainty concerning the source of funds to nake up for those funds not provided by l MMWEC to cover MMWEC's share of the operating costs of the l

Seabrook Nuclear Power Station in thatt 1 i

As doncribed in Attachment 2 to Public Service's a.

supplemental response (a press release, not an agreement or I i

even a memorandun of understanding), the so-called i

4 f

"settlement" announced by MMWEC's General Manager is merely "tentative" and has not yet been reduced to writing, ratified by MMWEC's Board of Directors, nor approved by the appropriate governmental agencies.

b. The settlement, if finalized, reduced to writing, ratified, and approved, will 'Ey provide for funding of HMWEC's share of the costs of the Seabrook Nuclear Power i Station through the end of 1989 and, then, only if MMWEC's share of those costa does not exceed $30 million.

3. That no adequate provision appears to have been nade for funds to make up for those not provided by MMWEC to cover its share of the costs to be incurred in the event of the permanent shut down of the Seabrook Nuclear Power Station i folicwing low power operation in thatt

a. Although the MMWEC prean release attached to Public Service's supplemental response indicates that under the tentative, unwritten, unratified, and unapproved settlement MMWEc's "cancellation or abandonment exposure will be linited r to a maximum of $10 million - down from the present estimate of $60 million. . . (, j a neither the press release nor the text of the supplemental response identifies the entity that will assume the estimated remaining $50 million "exposure" (the

, text of the supplemental response refers to the excess being l

assumed by "another (unidentified) Joint Owner" and attempts I

to downplay its significance by referencing the estinated i

5 l

t

pipita 15:49 ** = Er55-E05TCt4 **cs OI504171 P.11 level of "decontamination and disposal costs" but failing to consider the wubstantial ongoing operating costs during the period in which the contaminated fuel nust be stored pending an unlikely sale or eventual shipment to a presently nonexistent high level radioactive waste storage facility.

(Sta MASSAC!!USETTS ATTORNEY GENERAL JAMES M. SHANNON'S

• :n PETITION UNDER 10 C.F.R. I 2.758 TOR A WAIVER OT OR AN EXCEPTION FROM THE PUBLIC UTILITY EXEMPTION TROM TNE REQUIREMENT OF A DEMONSTRATION OF FINANCIAL QUALIFICATION at

$1 22-23.).

b. Other than tha wholly unspecified and inadequate provision of the tentative, unwritten, unratified, and unapproved settienent, the only provision for the a source of funds for auch costs is Public Service's bald assertion in its supplemental response that "the remaining Joint Qnan would meet their collective responsibility . . . and would then enforce their legal rights to contribution against other (unidentified) parities."

4. That on the basis of the information referenced in paragraphs 1 through above, as well as that in prior filings of the Massachusetts Attorney General, it is nanifest that there is l

considerable doubt concerning the ultimate availability of adequate funds to cover the costs of safe low power operation and the permanent shut down of the Seabrook Nuolear Power Station and that the rate process has not and cannot assure the i

j availability of such funds.

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f~ usis see ni46 .ico i&s-sosTcr4 AAA ~ Odd 4171 A16 CONCLUSION WHEREFORE, Attorney General James H. Shannon prays that the CommiseionI (1) determine that the public utility exemption from the requirement of a demonstration of [inancial qualification should be waived or an exception granted with respect to the licensing of the Seabrook plants (2) stay the issuance of a license authorizing low power i operation and testing pending the outcome of proceedings concerning a dete:mination of whether the Applicants can demonstrate that they possess the requisite financial qualifications to assure safe low power operation and a permanent shut down of the Seabrook Nuclear Power Station in the event that t

! a full power commercial operating license is not issued; I (3) issue such other orders and grant such other relief as may be equitable and necessary to assure the public health and safety in light of the present extraordinary financial straights of the Joint Applicants, particularly that of lead owner, and the  :

i continuing inability of the Joint Applicants to identify a secure  !

source of funds to make up for those not provided by those Joint  !

Applicants who are not providing funds to cover their share of 1

j the costs of the Seabrook Nuclear Power Station.

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wa 6- . coo .s. o + ++. ev = c.m i m .. . eneatet p,g3 RESPECTFULLY SUBMITTED, JAMES M. SMANNON ATT (EY 7 C0 MA SACHUSETTS -

I "

BY: 'Ttav . onas George B. Dean Assistant Attorneys General Department of The Attorney General One Ashburton Place Boston, Massachusetts 02138 (617) 727-2200 DATED: September 15, 1988 8

w 15/1998 15:46 **** ECF3-EC5TCtl **ca 02'04171 P.14 Robert J. Harrison I Prei oem ano en+ hoewe cmee.

NYN-08124 Pubec SeMee of New Hoirpehire Septeaber 13, !988 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk 7 References a) FacilityOperatingLicYeNSF-56,DocketNo.50-443 b) USNRC Letter dated August 11, 1988,

• Financial Coverage for the Cost of Low Power Operation - Request for Additional Information*, 3. Boger to R. J. Harrison c) PSNH Letter dated August 31, 1988,

• Ret Raquest for Additional Inf ormation*, NYN-88115 in Docket No. 50-443 Re: Second Supplemental Response to Request for Additional hformation Cantienent in reference (b), the NRC requested clarification with regards to the applicants' ability to provide financial coverage for the cost of low power operation of Seabrook and the cost of any permanent shutdown of the facility and maintenance in a safe condition following low power operation. In reference (c), PSNH furnished datatied responses and indicated that a further response to NRC Question 4 would be filed on or before September 15, 1988.

Enclosed herewith is a Supplemental Response to NRC Question 4 in reference (b), together with the attachments referred to therein. Th',s provides a description of the further progrees which has been sade in developing arrangements to cover through 1989 MMWEC's share of the costs referred to in reference (b). Because these arrangements are inextricably {

interrelated to the broader complest issues af fecting MfWEC's role in the Project, they could not be put in final form by our self-imposed deadline f.,f September 13. However, the final details will be provided as soon as they are available.

If you need any further information or clarification, please contact the undersignet, or Edward A. Brown, President and CEO of New Hampshire Yadee Division.

Very truly yours.

R. J. Rarrison RJR fe Enclosures cc Service List e

wivNW ltt47 **** ECPS-E05TCH **** 02:04171 P.15 Enclemura to NYN-st12 4 NRc Ouestion No. 41 Provide a detailed statement of the joint owners' plan for covering the 11.6 percent share of Seabrook costs that is 3' no longer being paid by Massachusetta Municipal Wholesale Electric Company (MMWEC) . Identify any new or prospective ra'ner (s) or other participants) in the project and describe in detail the arrangements for their participation and for covering the share of costs formerly paid by KKWEC. Describe how MMWEC's share of costs will be covered by the time low power operation is authorized. (For this purpose assume that low power authorization is received after September 1, 1988.)

Sunnlamental Rannonna to MRc Ouantion di on June 1, 1988 when MMWIC announced its intended "withdrawal from the seabrook Station nuclear project", and that it would make no further payments to the Seabrook

Project and that it would seek an agreement "to take MMWEC out of the project in a financially responsible manner", the

Project account referred to in Response to NRC Question 2 (see reference (c)) contained a positive balance in MMWIC's favor sufficient to cover MMWEC's share of the anticipated l

billings for the month of June and part of July. On July 13, 1988, Northeast Utilities ("NU"), the registered holding I

company parent of The connecticut Light and power Company  !

3

("CL&P"), one of the Joint Ovn6rs, announced that it would advance sufficient funds in lieu of the MMwEc obligation to ,.

permit the Project to meet its obligation through August, 1988. On July 20, 1988 $2,249,000 was advanced to the i

unAvAne 13:4e **** ECPS-E05TCH **** 0304171 P 16 Project by NU, which covered MMWEC's share to September 9, 1988.

On August 30, 1988 NU delivered to the Project its commitment that CL&P would "cover the shortfall in Seabrook

, Project costs resulting from (MWWEo+et-tallure to meet its contractual obligation to the project" (see Attachment 1).

This commitment extends through November 30, 1988. This commitment expressly excludes real estate taxes, but all such taxes coming due on or before November ?0, 1944 have already been paid. on August 31, 1988, $1,067,000 was advanced to the Project by CL&P which covered MMWEC's share for the balance of September. This commitment will permit the Project to "cover" the MMWEC share through November 30, 1986.

On September 10, 1988, MMWEC announced a tentative settlement which, subject to preparation of final contracts and obtaining requisite approvals, among other things assures financing of its share of the project through 1989. This i

agreement among MMWEC and the other Joint owners of Seabrook "over MMWEC's continued participacion in the project ... caps

(MMWEC's) financial exposure to Seabrook and provides a vehicle for ... (getting) out of this project" and also provides for payment of MNWEC's share of the Project costa l until the earlier of commercial operation or cancellation of i

Seabrook Unit 1. The relevant substance of this agreement follows (see Attachment 2): An independent power producer l .

w w 4: o .s.*o + +++ e v e va n,s4 .ses engag7g p,g7

("IPP") commits to advance to the Project all funds necessary to pay MMWIc's share of the Project's on going expenses, including low power operations and real estate taxes, up to an aggregate of $30 million. MMWEC commits to sell, when l

,, Unit i begins commercial operation 7-but at a price to be negotiated now, the portion of MMWEC's CWnership Share of 4 Seabrook attributable to those participants in MMWEC that do not desire to retain their interests in MMWEC's ownership shara. Thin arrangement assures the Project a reliabic cash flow more than sufficient to cover MMWEc's share of the presently estinated seabrook operating costs during the period through the earlier of commercial operation or the end of 1989.

The IPP will not become a "participant" or "Joint owner" l

of Seabrook station by reason of this agreement. If some or all of MMWIC's interest in the Project is ultimately purchased by the IPP or another entity, then an appropriate license amendment would be filed with the NRC at that time requesting any necessary approvals for the transfer of the appropriate portion of MMWEc's interest to the purchaser.

MMWEc remains primarily liable for its share of any shutdown l costs which would be incurred if permanent shutdown were to

! occur up to an aggregate of $10 million, any excess thereof attributable to MMWEc's share being assumed by another Joint owner. While the aggregate of these latter costs as defined

-3 l

sei ewa-e.vk< cnc.:g g w w me ro.~r . e. c,gg in the Joint ownership Agreement would be substantial, the Response to NRC Question 1 (see reference (c)) indicates that the decontamination and disposal costs inherent in any permanent shutdown after only low power testing operations

,. which would be necessary to "reduce residual radioactivity to a level that permits release of the property for unrestricted use" as contemplated by NRC Regulation are relatively anali.

See 10 CPR $50.2. If such a shutdown were to be required, 1

the Joint Owners would expect that these commitments would be sufficient to cover HMWEC's share of such costar however, as licensees of the NRC, the remaining Joint Owners would meet their collective responsibility to see that the facility was properly brought to permanent shut down in a timely and safe manner so as to permit prompt license termination and would then enforce their legal rights to contribution against other parties.

09/tg/19sa 15:49 +5**ECFbEOSTCH +s== 00!O4171 P.19 r906tTHilAllt trntrnll5 Attachmnnt 1 to NYM-99124 3 , ,,,,o m.... ,,, e. . .,, (2 pages 1 fm.,_.'_,_.. h'[o[he**ccu'""'m i Iful4LIAid 0 G W S cu 4.u. w e.e. ,n ev me en.ce.

gy9y,g )g, g,gg i

" Mr. John F. O. Richorn, Jr. ' ' *  !

Chairman & Chief Executive officer Eastern Utilities Assootates F. O. sox 2333 ,

5oston, Massachusetts 01207 '

Dear .lohnt '

This letter is sent to you in your capacity as Chairman of

the Seabrook project Executhve Committee, and is intended to i confirm our understandings about the nature and duration of the  ;

i funding commitment that The Connecticut Light and Power Company (CL&F) resultinis making to cover the shortfall in Seabrook project cotta Company'g from Massachusetts Municipal Wholesale riectric

the project, s (MMWEC) failure to meet its contractual obligations to on or before August 30, 1988, and then on or before the 20th i

l days that of September and October,1988, CL&P will make the payment i is projected by the New Hampshire Yankee Division (NNY) of r Public Service Company of New Hampshire (F5NN) as then being i i

necessary to carry the funding allocable to MMWEC's share of the

{

costs of the Seabrook nuclear project (the Freject) through the end of the month following the date in which payment is made. As  !

of the date hereof, such amounts are eatinated to be  !

approximately as follows: i l

Payment Date Funding Through  !

Ascunt _

August 30, 1988 september 30, 1988 september 20, 1944 31.1 at111on -

October 31,'1988 $1.4 million i October 20, 1984 November 30, 1988 ut.7 million i ns.2 ailliona i

• Plus an additional amount estimated at $210,000 as a special assessment with respect to PSNN pension costs  !

attributable to NHY esplayees and an additional amount j estimated at $800,000 as the camp-up costs associated with the issuance of a low-power license if those ramp-up costs are incurred prior to November 30, 1988. l l

i I

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w 4: 4::= i: 4:e ... e :-e. w i .... cacaivt a,2 CL&P's payment obligations are limited to the Project costs projected by NHY and approved by the Executive cor.aittee of the Project, provided, that without CL&P's written consent CL&P will not be obligated ~to make payments that on a cumulative basis exceed by more than ten percent the projected amounts given in the above table and the associated foetnote, and provided further, that CL&P will not make any payments with respect to property Project. taxes associated with MMWEC's ownership share of the e- only to provide necessary funding,Aa_ cover the deficiency resulting fram MMMIC's failure to pay. CL&P hns not assumed MMWEc's contractual obligatione and as not asking these payments on MMWEC's behalf, so these payments should not be construed as curing MMWEC's deficiency. Beyond that, MMWEC retains all of its contractual responsibilities as a joint owner, including responsibility for covering the costs of low power operation and costs of a permanent shutdown of the facility and maintenance of the facility in a safe condition after a period of low power operation, 30, 1988 If any of these costs are incurred prior to November and exceed the amounts committed by c1&P in the preceding30, November paranraphs, 1968. or if those costs are incurred on or after As a joint owner, MMWEC retains all nuclear risk (including Price-Anderson and deccanissioning), and CL&P assumes none of MMWEC's responsibility.

Very truly yours, s

• ces cros of seabrook Joint owners l

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I Rrw(VAx)/1rw I

w a- elyw tuw * *** tiWS-E03TCt1 ****

. CHC4171 P.21 Attae.Vont 2 t_o NYN-89124 a o u s t u C C o a o o a (2 pagt s 1 o s news release "Mn I'or !anadiate Release i

September 10, 1988 MHVtc AND JOINT CitNtk3 MACM TENTATIVE SEA 8 ROCK stTTLEXENT

p. '~

Massachusetta Municipal Vholesale 81estris Company ( W EC) today announced a tentative settlement with other joint evners of Seatrook over NHVtC's continued participation in the project.

"On June 1,1988, MHVIC adopted a Strategic plan of Action designed to take itself out of the Seabrook project in a financially responsible manner. Since that time we have been engaged in tough nogettations to achieve this objective." sat.d MMVic General Manager Cary L. Hunt. "The tentative settlement caps our financial exposure to Seabrook and provides a vehicle for our participating municipal light departments to get out of this project," Hunt said.

• tn teaching this nettlement agreement, we have had to comptestse on tesues of stains be ause of the enormous peittical, regulatory and econoste uncertaintiae surrounding thte project

• he said.

Under terse of the settienent. which wet be ratified by the tcGEC leard of Directors and other parttee, and is subject to goverraental approvals:

1. An independant power producer will make all HMVic featreek payments to the prwject untti che coamercial operasten date or samenation and HMWtc vt11 be creetted with all payments made on its behat! since 19Nic stepped making payments June 1,1944 thus resolving all tasues about an 19Nic default on its seabrook obit latione:

sers

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wn/two niti **co ECFS- OSTCr4 .cos 02:04171 p.23 2.

Upon commercial operation, an independent power producer vill purchase or acquire capacity or output associated with interest attributable to any MMVtc participant that wants to get out of the project. contingent upon terms and conditions to be negotiated.

3.

p, NNVEC's cancellation or abandensent exposure vill be Itaited to a maximum of $10 million . down from the present estimate of $60 million (MHVtc has the funda necessary to caver this exposure in the bank because of its decisten to stop maktug additional investments in Seabrook last June);

4 MMVEC will receive $3.5 million in cash as reimbursement for legal and other cosesi 3.

All claise against MHVtc will be released in exchange for HMVtc releasing all clalas against the joint owners and others.

"This tentative agreement provides a clear resolution of the teabrook issue for our acabers no matter what happone to the project from this point forward,' Hunt said, "Vith this situatten stabilized, we can now turn our attention to the remaining strategic objectives of restructuring our debt and nederating our rates for ratepayers.* Hunt said.

Documents teptementing this tentative settlement agreement are being dratted and Hunt said he espected final approvat within ateut 4$

days.

30

@/19J1C 19891 **c:i E@s-5CSTCN *cca 025041it P hb i*

. ..' **i. ff UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION *26 SEP 15 P4 :06

. p o.

i boCM 't

> p n. . .

In the Matter of )

)

PUBLIC SURVICE COMPANY OF NEW ) Docket No.(s) 50-443/444-OL HAMPSHIRE, ET AL. )

• • (Seabrook Station, Units 1 and 2) A

)

)

CERTIFICATE OF MERVICE J

J I, George B. Dean, hereby certify that on September 15, 1988, I inade

) service of the within Motion of Massachusetts Attorney General James M. Shannon for Leave to File a Document Not Authorized by the Commission's Rules of Practice and Fourth Supplement to Massachusetts Attorney General James M.

Shannon's Petition Under 10 C.F.R. $ 2.756 For a Waiver of or an Exception From the Public Utility Exemption From the

] Requirement of a Demonstration of Financial Qualification, by first i

class mail, or by Federal Express SS indicated by (*), or by telefax, at l indicated by (**), tot i

• • Lando W. Zech, Jr., Chairman Thomas M. Rooerts. Commissioner

U.S. Nuclear Regulatory Commission U.S. Nuclear Hegulatory Commission 1717 H Street 1717 H Street Washington, DC 20555 Washington, DC 20555 Kenneth C. Rogers, commissioner Kenneth M. Carr, Commissioner U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 1717 H Street 1717 H Street

Washington, DC 20555 washington, DC 20555 i

j Alan S. Rosenthal, Chairman i U.S. Nuclear Regulatory Commission

! 1717 H Street

{

Weshington, DC 20555 i

, @/10/1993 10 C +cca ECF5-ECSTCH *cco 02504171 P.b4 Thomas S. Moore Howard A. Wilber U.S. Nuclear Regulatory Commission U.S. Nuclear Regolatory Commission 1717 H. Street 1717 H. Street Washington, DC 20555 Washington, DC 20555 Sheldon J. Wolfo, Chairperson Ivan W. Smith, Chairman U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 1717 H. Street 1717 H. Street Washington, DC 20555 Washington, DC 20555 Dr. Emmeth A. Luebke Dr Jerry Harbour

,, 5500 retendship loulevard >U.S. Nuclear Regulatory Commission Apartment 1923H 1717 H Street Chevy Chase, MD 20815 Washington, DC 20555 H. Joseph Flynn, Esq. Stephen E. Merrill Assistant General Counsel Attorney General Office of General Counsel George Dana Bisbee, Esq.

Federal Emergency Management Agoncy Assistant Attorney General 500 C Street, S.W. 25 Capitol Street Washington, DC 20472 Concord, NH 03301 Docketing and Service Paul A. Fritzsche, Esq.

U.S. Nuclear Regulatory Commission Office of the Public Advocate 1717 H. Street State House Station 112 washington, DC 20555 Augusta, Mt 04333 Roberta C. Peaver Diana P. Randall State Representative 70 Collins Street Town of Hampton Talls Seabrook, NH 03874 Drinkwater Road Hampton Palls, NH 03044 Atomic Safety & Licensing Robert A. Backus, Esq.

Appeal Board Panel Dachus Heyer & Soloman U.S. Nuclear Regulatory Commission 116 Lowell Street 1717 H. Street P.O. Box 516 Washington, DC 20555 Manchester, NH 03106 Sherwin E. Turk, Esq. Judith H. Mizner, Esq.

U.S. Nuclear Regulatory Commissioni Silvergato, Gertner, Daker 1717 H Street Pine, Good & Mizner Washington, DC 20555 88 Droad Street Boston, MA 02110

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N. mic Saf ety & Licensing Jane Doughty

,oard Panel U.S. Nuclear Regulatory Commission Seacoast Anti-Pollution Lwague 5 Merket Street 1717 H. Street Portsmouth, NH 03801 Washington, DC 20555 i

Paul McEachern, Esq. J.P. Nadeau Matthew T. Brock, Esq. Board of Selectmen  ;

Ghaines & McEachern 10 Central Road i 25 Maplewood Avenue Rye, NH 03870 L P.O. nox 360

, Portsmouth, NH 03801 ..,_

Sandra Gavutis, Chairperson Calvin A. Canney Board of Selectmen City Manager RFD 1, Box 1154 City Hall Route 107 l E. Kingston, NH 03827 126 Daniel Street Portsmouth, NH 03801 h

Senator Gordon J. Humphrey Edward Molin One Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attnt Herb Boynton) Newburyport, MA 01950 Donald E. Chick William Lord Town Manager Board of Selectmen Town of Exeter Town Hall 10 Front Street Friend Street  !

Exeter, NH 03833 Amesbury, MA 01913 Brentwood Board of Selectmen Gary W. Holmes, Esq. "

RFD Dalton Road Holmes & Ellis Brentwood. NH 03833 47 Winnacunnet Road Hampton, NH 03841 Philip Ahrens, Esq. Ellyn Weiss, Esq.

Assistant Attorney General Harmon 6 Weiss i

s Department of the Attorney General Suite 430 l State House Station #6 Washington, DC 20009 I August, ME 04333 1

Thomas G. Dignan, dag. Richard A. Hampe, Esq.  :

Ropes & Gray Hampe E McNicholas 225 Franklin Street 35 Pleasant Street  !

Boston, MA 02110 Concord, NM 03301 Beverly Hollingworth 209 Winnacunnet Road  !

Hampton, NH 03842 i i

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09/1'J/1990 1FJ3 *cca ECFS-E037Ct1 *cco 02!04171 P.26 r

L William Armstrong Michael Santosuosso, Chairman Civil Defense Director Board of Selectman Town of Exeter Jewell Street, RFD 2 10 Front Street South Hampton, 14H 03427 Exeter, NH 03833 Robert Carigg, Chairman Ann E. Goodman, Chairperson Board of Selectmen Board of Selectmen i Town Office 13-15 Newmarket Road Atlantic Avenue Durham, NH 03824 North Hampton, NH 03862

1. ~~ .. -

Allen Lampert Charles P. Graham, Esq.

Civil Defense Director Murphy and Graham Town of Brentwood 33 Low Street 20 Franklin Street Newburyport, MA 01950 Exeter. NH 03833 l

Gustave A. Linenberger, Jr.

l

, Atomic Safety 6 Licensing Board U.S. Nuclear Regulatory Commission 717 H. Street Washington, DC 20814 1

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/- n Mean I Assistant Attorney General  !

Nuclear Lefety Unit Dated: September 15, 1987 f

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