ML20006F403
| ML20006F403 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/16/1990 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#190-9914 LBP-89-32, OL, NUDOCS 9002280003 | |
| Download: ML20006F403 (18) | |
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00CKETED February lhfNk990 l
UNITED STATES OF AMERICA 30 FSB 20 P3 :18 i
before the
- QFFICE DE SECRETARY 90 Chi.1,6l/ljyLi'VICf:
NUCLEAR REGULATORY COMMISSION In the Matter of
'PUBLIC SERVICE COMPANY Docket Nos. 50-443-OL OP NEW HAMPSHIRE, at al.
50-444-OL
-(Seabrook Station, Units 1 (Offsite Emergency and:2)
Planning and Safety Issues)
APPLICANT 8' RESPONSE TO INTERVENOR8' NOTION TO SUPPLEMENT APPLICATION FOR A STAY OF LBP-89-32 Under date of February 14, 1990, certain Intervenors herein have filed with the commission a document entitled "Intervenors' Motion to Supplement-Application for a Stay of LBP-89-32.
The basis for the request is a Motion to Reopen the Record filed by the Intervenors with the Appeal Board.
A copy _of the Motion to Reopen'is attached to the Motion to supplement.
The Motion to Supplement should be denied for the following reasons.
1.
It is late.
If'the Intervenors believed that the motion they have filed with the Appeal Board was a legitimate 1 basis for-a stay of LBP-89-32, they should have filed this motion back.on February 6, 1990, when they filed with the Appeal Board.
2.
The new application, like the old, suffers from the fact that no showing of irreparable harm has been made and there I
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9 has been no showing that the injury to Applicants if the stay is granted would be less than that which would be incurred by the Intervenors if the stay is denied.
Furthermore, the public interest does not favor further delay while litigation proceeds in the Seabrook proceeding.
3.
As to the likelihood of success, we attach hereto our response to the Motion to Reopen which we have filed with the Appeal Board.
This response illustrates that the basis for the Motion is gone because the State of New Hampshire has stated that the Applicants erred in the interpretation they made of the plan which formed the basis for the Motion to Reopen.
The response further illustrates.that even had the Applicants been correct, the Motion to Reopen should be denied for (a) failure to file an affidavit, and (b) lack of a demonstration of a significant safety issue or the likelihood that a different result would be reached.
Furthermore, the Motion to reopen was filed in the wrong forum.
The Motion to supplement should be denied.
If it is allowed, the stay requested should still be denied.
Respectfully submitted, A w.7 /
D t iff5 n, J r.
Thomhs G'.
f George H. Lewald Kathryn A. Selleck Jeffrey P. Trout Ropes & Gray one International Place Boston, MA 02110-2624 (617) 951-7000 Counsel for Applicants
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ATTACHMENT February 16, 1990 UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING APPEAL-BOARD In the Matter of PUBLIC SERVICE COMPANY Docket Nos. 50-443-OL OF NEW HAMPSHIRE, gt al.
50-444-OL
.(Seabrook Station, Units 1 (Offsite Emergency
~
and 2),
Planning Issues)
L APPLICANT 8' RESPONSB TO EMERGENCY NOTION OF INTERVENORS:
(1) TO CLARIFY THE STATUS OF THE APPEAL OF LEP-89-33 AND (2) TO REOPEN THE RECORD ON THE NERERP A8 TO THE NEED FOR SEELTERING IN CERTAIN CIRCUM 8TANCES Introduction i
Under date of February 1, 1990, certain Intervenors herein have filed a document styled:
" Emergency Motion of Intervenors:
L (1)-to Clarify the Status of the Appeal of LBP-89-33 and (2) to l
Reopen the Record on the NHRERP as to the Need for Sheltering in certain Circumstances" (Motion).
In addition, although not mentioned in the title, the document contains yet a third motion which is a motion for summary disposition.'
The gravamen of the l
l L
'To which there is a twenty-day response period.
Such a tag-along certainly does not help lend credence to the request for expedited consideration.
CLAREREP.SS s
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Motion is a document which the Applicants filed with the Licensing Board of February 1, 1990, in response to a Licensing Board Order directing the parties "to advise the Board on how to 2
proceed in accordance with the directives of ALAB-924 In that document, Applicants made two statements which gave rise to the Motion.
The first was the statement quoted at Page 3 of the Motion to the effect that LBP-89-33 is now the law of the case, the Intervenors having failed to preserve any appellate
-right as to that decision.
The second is apparently the following statement:
"During the hearings on the NHRERP, FEMA took the position, through its witness Joseph Keller, that evacuation (when physically possible) would always be the preferable protective action for the Seabrook beach population in light of, inter glia, the uncertainties of release composition and duration, the effects of groundshine, and the poor quality of the phelter available in the Seabrook beach area.
This FEMA position was vigorously contested by the Intervenors, both at trial and on appeal, and was upheld by bothtpaLicensingBoardandtheAppeal Board.
In October 1988, the NHRERP, Rev.
2, Vol.
4, Appendix F was revised to conform to the FEMA position that was litigated (and subsequently upheld):
at step IV.B.4 (General Emergency) it is recommended to evacuate ERPA A, an approximate two-mile radius that includes Hampton and Seabrook beaches, based on a declaration of a General Emergency subject only to constraints to evacuation.
This revision to bring the plan into conformity with the FEMA position was 2Memorandum and Order (recardina Issues Remanded in ALAB-1111 (Jan.-11, 1990) at 1.
3(Note 29 in orig). (ALAB-924] at 52-55.
'[ Note 31 in orig). Id. at 55-58..
1 i
13, 1988.[d and parties on served on the Boa October The effect of the chance-e is to eliminate shelterina as an ootion under the first of the two circumstances contemolated by the Aeneal Board.
Since shelterina is no lonaer a clanned orotective action option under those circumstances. no imolementina detail'is recuired in that case."'
In particular, it'is the'words set forth with emphasis upon which the Intervenors base the Motion.
Applicants address below the various requests included in the Motion.
I.
The Motion to Roonen Should be Danied Introduction Prior to addressing the merits of the Motion insofar as it is a motion to reopen, it would be well to focus upon two 3
introductory matters.
.The first is what the Applicants' filing was.
This filing was in response to a Licensing Board request to describe for the Licensing Board what steps needed to be taken in i
the event ALAB-924 is not reversed by the Commission and further proceedings (not.necessarily hearings) are necessary before the Licensing Board.
It was a disclosure of future positions to be taken and legal theories to be argued.
It was not a document which operated to make any change in NHRERP which, like any 5[ Note 32 in orig).
Egg Letter of G. Huntington, Assistant Attorney General of.New Hampshire, to Chairman I. Smith, Atomic Safety and Licensing Board, October 13, 1988, and enclosures thereto.-
'Anolicants' Resoonse to Licensina Board Order of January 11, 1990 (Feb. 1, 1990) at 9-10 (emphasis added).
'er document, speaks for itself.
The Applicants' filing represents
(
no more or less than a-lawyer's argument insofar as it purported-to. interpret the NHRERP.
l A second matter which has been lost sight of by the Intervenors is the nature of the Licensing Board decision which is on review before this Appeal Board.
A Licensing Board finding of adequacy with respect to a radiological emergency response plan is a predictive finding and it is anticipated that it may well be made before plans are complete.7 Egr contra it is not anticipated that an emergency plan will remain rigid.
- Indeed, L
emergency planning is an exercise which virtually dictates that l
changes to plans are constantly being made as it is adjusted to L
. changing conditions and emphases and advances in knowledge.
1' Thus, it may well be that an emergency. plan will, at FEMA's l
direction or upon a state's decision, change not only between the time ~a record closes and an initial decision is made but also between the time that decision is made and appeals within the agency and to the courts are exhausted.
It would indeed be bad policy to encourage the freezing of a plan during the often lengthy NRC appellate process by holding that every opponent of
-the plant in question can have an opportunity to obtain a delay with more hearings and proceedings every time a change is made.
What is legitimately up for review on the appeal of a Licensing Board ruling on an emergency plan is the issue of whether the IE.g.,
Louisiana Power and Licht Company (Waterford Steam Electric Station, Unit 3), ALAB-732, 17 NRC 1076, 1103-04 (1983),
and authorities there cited..
...,. ~
.~u a
u Li evidentiary record before that licensing board supports the overall predictive finding and the subsidiary findings which
. undergird it.
Any other rule means chaos and encourages delay in the implementation of changes which FEMA or the state deems l~
l necessary to further the goal of protecting the public health and safety.
In the case at bar, the evidentiary record on the NHRERP had long since closed when the Board was notified of the October, E
1988, changes by the State of New Hampshire.
The only job of the 1
Licensing Board was to decide whether the record before it, which clearly did contain the " puff release" shelter in place option, demonstrated the requisite reasonable assurance necessary for the L
required credictive finding.
And all that is before this Appeal
. Board on appeal is whether that evidentiary record supports that finding.
A.
The Appeal Board is Without Jurisdictiop to Entertain the-Notion Insofar as it is a Motion to Roonen.
Intervenors state that this Appeal Board has jurisdiction over the Motion insofar as it is a motion to reopen.8 The entire argument ignores the-fact that in its decision making the remand to the Licensing Board, the Appeal Board required the Licensing Board to deal with the implementing detail only "so long as" the sheltering options discussed remained in the plan.'
clearly, the Licensing Board was given authority, inter alia, to entertain the 8Motion at 14-15.
'ALAB-924 at 59..
I k
l issue of whether they should remain in the plan.
This argues for t
L the jurisdiction over the motion to reopen aspects of the Motion lying with the-Licensing Board.
Further, a petition for review seeking reversal of this Appeal Board's holding on beach shelter has been filed with the Commission, and thus, arguably, the.
jurisdiction to reopen the NHRERP phase of the Seabrook L
proceeding on the issue of interest lies with the Commission."
The one place it would seem not to lie, in the circumstances, is 7
with the Appeal Board.
B.
Whether the Applicants Were Right or Wrong on Their Reading of the NHRERP, the Motion Insofar as it is a Motion to Roonen should be Danied.
1.
Since the Applicants are Wrong, the Basis for the Motion is Gone.
After filing their response to the Licensing Board Order, the Applicants were in receipt of a communication in addition to the Motion at bar.
This was a communication from counsel for the State of New Hampshire who notified the Applicants that New Hampshire did not agree with the Applicants' statement that the October, 1988, changes had the effect of changing the planned-response in the event of a planned " puff release."
We anticipate that New Hampshire will be making a filing to that effect.
Applicants do of course acquiesce in that position for the simple reason that it is New Hampshire's plan and New Hampshire is the
" Egg Philadalchia Electric Comoany (Limerick Generating Station, Units l'and 2), ALAB-823, 22 NRC 773 (1985)..
.4
~ final arbiter of what the plan language does or does not mean.
New Hampshire's position of course' dooms the Motion insofar as it
~
is'a motion to reopen for the simple reason that its basic.
premise,~1 3.,
that the changes in October, 1988, changed the planned response to a planned " puff release", is gone..
2.
Even If the Applicants were Correct, the Motion still Should be Denied..
1 a.
The Absence of an Atfidavit is Fatal.
The Motion is unaccompanied by any affidavit as required by L
10 C.F.R. 5 2.734(b).
"(T]he Commission expects its adjudicatory
=
boards to enforce the section 2.734 requirements rigorously --
i. e '., to reject.out-of-hand reopening motions that do not meet those requirements-within their four corners.""
One of those requirements is "an' affidavit as required in S 2.734(b) l describing (1) the Intervenors' satisfaction of the three factors L
enumerated in i 2.734(a) and (2) the technical basis for the l.
Intervanors' proposed contention."12 Intervenors eschew the need for any1 affidavit on the theory that they can rely on the uncontradicted representations of Applicants' counsel and the decision in ALAB-924.13 To begin with, the statements of counsel as to interpretations of the NHRERP are not the stuff of which L
"Public Service Comoany of New Hamnshire (Seabrook Station,
-Units 1 and 2), ALAB-915, 29 NRC 427, 432 (1989).
12Lona Island Lichtina Co. (Shoreham Nuclear Power Station, Unit 1), 29 NRC 89, 93-94 (1989).
NMotion at 17-18..
..~
. affidavits are made.
More to the point, we understand they will be contradicted by the State.of New Hampshire.. ESA infra.
But even if=they were not and'were correct in full, this avails the
-Intervenors nothing.
The regulation'is clear:
"The motion must be accomoanied by one or more affidavits which set forth the factual and/or. technical bases for.the movant's claim that the criteria of naraaraoh-(a) of this section have been satisfied.
Each of the criteria must be separately addressed, with~a spegific explanation of why it has
.been met."
There is no leeway here.
The Motion must be accomoanied by an affidavit.
Each criterion must be seoarately addressed, with a specific explanation of why it has been met.
The criteria to be l'
L
. addressed include " timeliness" and " materially different result"
. as well as the existence of a significant safety issue.
The Intervenors' filing addresses none of these matters by affidavit.
And Applicants' filing and this Appeal Board's decision in ALAB-924 cannot serve as a surrogate for the affidavit."
The-absence of an affidavit is fatal.
L L
L "10 C.F.K $ 2.734(b) (emphases supplied).
"That agency or applicant documents might serve to substitute for an affidavit may have been an-acceptable practice when motions to reopen were governed by decisional authority.
l E
gag Vermont Yankee Nuclear Power Coro. (Vermont Yankee Nuclear L
Power Station), ALAB-124, 6 AEC 358, 364 (1973).
However, the requirement for an affidavit was specifically included in 10 C.F.R 5 2.734(b) and thus overruled that case law.
criteria for
'Recoenina Records in Formal Licensina Proceedinas, 51 Fed. Reg, 19535,.19537 (May 30, 1986). l m
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b.
There has Been no showing That There is a significant Safety guestion Involved..
The inclusion 211 BSD of a PAR of such low probability as is involved here-is simply not a significant safety issue.
More importantly,_ FEMA has approved the October, 1988 changes and-continues to find the plan adequate.
In light of these facts, there-is'neither a significant safety issue, nor a likelihood that.a different result would have been reached.'7 c.
The Motion is not Timely.
The_only argument that Intervenors make as to timeliness is that the Applicants.are estopped by their own actions from asserting that the Intervenors were on notice as of October, 1988,-of the plan change perceived by the Applicants.
Accepting arouendo that premise, the motion-still is not timely.
Applicants' counsel freely concede that they did not, until December 8, 1989, reach the conclusion as to the plan change they asserted in the February 1, 1990 filing.18 However, on
The low probability referred to in the text is D21 the low probability of the accident, but, rather, assuming the accident, the low probability of the occurrence of a planned " puff release" with people on the beach.
'7Egg Philadalchia Electric Co. (Limerick Station, Units 1 and 2), 23 NRC 130 (1986).
1aIntervenors suggest that Applicants had an obligation to advise the Licensing Board of the conclusion they had reached and its significance and to change a then extant proposed finding.
4.
December 8,'1989 Applicants filed with the Commission "Anolicants' Response to-Intervenors'-Immediate Effectiveness L
L Review Comments. Stav Reauests and Sucolement to Intervenors' Motion to Vacate Those Portions of LBP-89-32 Authorizina Issuangg l
of a Seabrook Operatina License."
In that document at Page 31 and.n.86 thereon it was made crystal clear that Applicants interpreted'the plan change of October, 1988', in the manner asserted.in the February 1, 1990 filing.
The text referred to the resolution between the State and FEMA of implementing detail b
and dropped a footnote at that point as follows:
"" Letter Huntington to Judge Ivan W. Smith (October 13, 1988).
That resolution makes l
evacuation the recommended protective action within 2 miles-in all circumstances except 1
when' impediments make evacuation impossible."
E (Emphasis added.)
At a minimum that is when the clock started to run on this matter for the Intervenors, assuming the Applicants' interpretation had However, the conclusion had not been reached as of those dates.
-And, in any event, the notice from the New Hampshire Assistant Attorney General accomplished all of the notice that is required and-the proposed finding still stood on the record as made.
Intervenors also point to an Appeal Board argument and suggest a disclosure should have been made.
However, a review of that transcript will~ reveal that what was being inquired of was-the contents of the Licensing Board decision not the extant contents of the plan.
Had the interpretation suggested in the February 1, 1990 filing been made as of that time, and assuming perfect memory, the " disclosure" would have been made.
Nor had the interpretation been made as of the time the Petition to Review ALAB-924 was filed when a reference was made therein to the " puff
' release" shelter option.
Aeolicants' Petition for Review of ALAB-924 (Nov. 10, 1989) at 9.
Actually, none of this relieves the Intervenors of their burden of showing that they did not know (which apparently they did not)~and that they should n21 have known.
If Applicants' suggested reading of NHRERP had been correct, then the Intervenors would have been charged with knowledge of it as of October 13, 1988..
been correct.
The, Motion was'not filed until two months (60 days) later. 'Intervenors' statement at Page 2 of the Motion,.in referring to the Applicants February 1, 1990 filing: "Further, astoundingly the Applicants now assert 12I thi first 1131 that an
' October 10, 1988 plan revision to the NHRERP effectively eliminated (the puff release shelter in place option]" is simply in error.
The Motion insofar as it is a motion to reopen is not-timely.
The Motion insofar as it is a motion to reopen should be denied, and the accompanying motion for summary disposition is therefore moot.
II.
INSOFAR AS THE NOTION SEBR8 A DECLARATION TRAT THE INTERVENORS RAVE PRE 8ERVED THEIR APPELLATE RIGHTS AS TO LBP-89-33, IT SHOULD ALSO BE DENIED.
That portion of the Motion which seeks clarification of the status of the " appeal" of LBP-89-33-should also be denied.
There are two prerequisites to the preservation of a matter on appeal from a licensing board decision:
the filing of a notice of appeal and the filing of a brief in support thereof.
Litigant-invented motions for " mandamus" (a remedy not found in the Commission's rules of practice) or its equivalent do not get the jobTdone.
And comments filed in connection with an immediate effectiveness review likewise do not preserve appellate rights.
The Commission may, indeed, properly disregard any comments made
Indeed, if one reviews the supplemental mandamus-type motion, one finds no reference to LBP-89-33 in the moving part of the motion.
.Thus, even if one could preserve an appellate right by such a device, they simply have not.
to it arguing that LBP-89-33 is in error.
The error has not been preserved.except.to the extent that the Appeal Board elects to take aug soonte review of it.
In addition, the argument that this Appeal Board had its jurisdiction over LBP-89-33 taken away by the commissionto is wrong.
The commission took onl'y'the Motion to Vacate and' directed stay motions to be filed with it.
The normal review of LBP-89-32 (and LBP-89-33) were left with the Appeal Board.
The Motion insofar as it is a motion to clarify appellate rights should be denied.
Respectfully submitted,.
Thomas C. fffgnan, Jr.
George H. Lewald Kathryn A. Selleck Jeffrey P. Trout
' Ropes'& Gray One International Place Boston, MA 02110-2624 (617) 951-7000 counsel for Applicants toMotion at 5..
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DOCKL'IED USNRC CERTIFICATE OF SERVigE I, Thomas G. Dignan, Jr., one of the attorneys f59 DEB 20 P3 :18
. Applicants herein, hereby certify that on February 16, 1990, I madeserviceofthewithindocumentbydepositingcop}pp,.phereoq[
with Federal Express, prepaid, for delivery to (or wygggggjy
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indicated, by depositing in the United States mail, firstBcians postage paid, addressed to) the individuals listed below:
Kenneth M. Carr,-Chairman Thomas M. Roberts, Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission One White Flint North One White Flint North 11555 Rockville-Pike 11555 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 Forrest J. Remick, Commissioner James R. Curtiss, Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission ~
Commission One White Flint North One White Flint North 11555 Rockville Pike 11555 Rockville Pike Rockville, MD_
20852 Rockville, MD 20852 Kenneth C. Rogers, Commissioner William C.
Parler, Esquire U.S.
Nuclear Regulatory General-Counsel Commission Office of the General Counsel One White Flint North One White Flint North 11555 Rockville Pike 11555 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 G.' Paul Bollwerk, III, Chairman Howard A. Wilber Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Appeal Panel U.S.: Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Alan S. Rosenthal,. Esquire Thomas S. Moore Atomic Safety and Licensing Atomic Safety and Licensing Appeal ~ Panel Appeal Panel U.S., Nuclear Regulatory U.S. Nuclear Regulatory
- Commission Commission East West. Towers Building East West Towers Building 4350-East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 I
I i
t Administrative Judge Ivan Smith Administrative Judge Kenneth A.
Chairman, Atomic Safety and McCollom.
1 Licensing Board 1107 West Knapp Street U.S.
Nuclear Regulatory Stillwater, OK 74075 j
Commission East West Towers Building 4350 East West Highway Bethesda,- MD 20814 Administrative Judge Richard F.
H. Joseph Flynn, Esquire Cole, Atomic. Safety and Office of General Counsel Licensing Board Federal Emergency Management U.S. Nuclear Regulatory Agency Commission 500 C Street, S.W.
East West Towers Building Washington, DC 20472 4350 East West Highway Bethesda, MD 20814 Mr. Richard R.
Donovan Diane Curran, Esquire
(
Federal Emergency Management Andrea C.
Ferster, Esquire Agency Harmon, curran & Tousley Federal Regional Center Suite 430 L
130 228th Street, S.W.
2001 S Street, N.W.
l Bothell, WA 98021-9796 Washington, DC 20009 Robert R.
Pierce, Esquire George Dana Bisbee, Esquire.
Atomic Safety and Licensing Associate Attorney General l
Board Office of the Attorney General l
.U.S.
Nuclear Regulatory 25 Capitol Street L
Commission Concord, NH 03301-6397
' East Wcst Towers Building 4350 East West Highway l
Bethesda, MD 20814 L
?
Adjudicatory File Mitzi A. Young, Esquire L
Atomic Safety and Licensing Edwin J. Reis, Esquire Board Panel Docket (2 copies)
Office of the General Counsel l
U.S. Nuclear Regulatory U.S. Nuclear Regulatory l~
Commission Commission East West Towers Building One White Flint North, 15th Fl.
4350~ East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852 E
- Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Backus, Meyer & Solomon L
U.S. Nuclear Regulatory 116 Lowell Street i
Commission P.O.
Box 516 Washington, DC 20555 Manchester, NH 03105 l
., ' '/
Philip Ahrens, Esquire Suzanne P. Egan, City Solicitor Assistant Attorney General Lagoulis, Hill-Whilton &
Department of the Attorney Rotondi General' 79 State Street Augusta, ME 04333 Newburyport, MA 01950 Paul McEachern, Esquire John Traficonte,-Esquire Shaines & McEachern Assistant Attorney General 1
Maplewood Avenue Department of the Attorney P.O.
Box 360 General Portsmouth, NH 03801 One Ashburton Place, 19th Floor Boston, MA- 02108
- Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S.
Senate Lagoulis, Hill-Whilton &
Washington, DC 20510 Rotondi (Attn:
Tom Burack) 79 State Street Newburyport, MA 01950
- Senator Gordon J. Humphrey Barbara J. Saint Andre, Esquire
'One Eagle Square, Suite 507 Kopelman and Paige, P.C.
Concord, NH 03301 77 Franklin Street (Attn:
Herb Boynton)-
Boston, MA 02110 Ashod N. Amirian, Esquire Judith H. Mizne't, Esquire 145 South Main Street 79 State Street, 2nd Floor P.O.
Box 38 Newburyport, MA 01950 Bradford, MA 01835 Gary W. Holmes, Esquire Marjorie Nordlinger, Esquire Holmes & Ells Office of the General Counsel 47 Winnacunnet Road One White Flint North Hampton, NH.03842 11555 Rockville Pike Rockville,-MD 20852 Mr. Jack-Dolan Federal' Emergency Management Agency Region I-J.W. McCormack Post Office &
Courthouse Building, Room 442 Boston, MA 02109
'i 4 v.
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George Iverson,.. Director N.H. Office of Emergency Management
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State House' office Park South-i 107 Pleasant. Street Concord,1NH 03301-1 Thomss G.". Dig 6 n, Jr.
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