ML20149H761

Affidavit of TC Feigenbaum Supporting Wihholding of Emergency Plan Info from Public Disclosure

ML20149H761
Person / Time
Site:	Seabrook
Issue date:	12/30/1987
From:	Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
Shared Package
ML20149H733	List: ML20149H730 ML20149H745 ML20149H761
References
OL, NUDOCS 8802220092
Download: ML20149H761 (11)

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9 ENCLOSURI 2 AFFIDAVIT OF T. C. FEICENBALH SUPPORTING THE WITHHOLDING OF EMERGESCY PLAN INFOP.MATION FROM PUBLIC DISCLOSURE SEABROOK STATION i

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t AFFIDAVIT I, Ted C. Feigenbaum, certify that I as a Vice President of New Hampshire Yankee Division of Public Service Company of New Hampshire and that I have been delegated responsibility to oversee the filing with the United States Nuclear Regulatory Commission, of additional information required for the NRC and FEMA full power review of the Seabrook Plan for Massachusetts Communities (the "Plan"), including the function of reviewing the contents thereof and det'eraining what information therein shou'id be withheld f rom public disclosure.

I fur-ther certify that, in the performance of those responsibilities, i have determined that the names, addresses or identities of the individuals and companies which have agreed to perform certain essential services in connection with the implementation of the Plan constitute confidential communications within the meaning of 10 CTR 52.790 of the Commission's regulations, the disclosure of which would be highly detrimental to the achievement of the purposes of the Plan, namely the ability to respond effectively in aid of the public health and safety in the event of an emergency. The materials we seek to withhold are noted on specially marked pages of the following.

(1) ; Emergency Plan, Appendix A -- names, loca-tions, and other information that would identify certain persons and organizations who have agreed or contracted to supply services, resources and f acilities to support l

the Plan; (2), Emergency Plan, Appendix C, letters of agreement -- names, letterheads, and other information i

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that would identify certain persons and organizations who have. agreed or contracted to supply services, resources and facilities to support the Plan; (3) ; Emergency Plan, Appendix M -- names, addresses,

and other information that would identify persons or organ-1:ations who have agreed or contracted to provide host f acilities and resources and services (road crews, buses, ambulance services).

In support of the foregoing, I believe that disclosure of such information would constitute an unwarranted invasion of personal pro-vacy for the individuals and entities involved; that such disclosure could potentially subject those persons to unnecessary contacts and interruption of their private lives by members of the public at large during the substantial periods when no activity relating to the Plan is ongoing and create a real potential f or undermining ef ficient implementation of the Plan during routine exercises of the Plan or 1

in the unlikely event or a real emergency at the Seabrook Station; I

and that such information is not essential to any verification of the compliance of the Plan with applicable regulatory requirements by anyone other than the Commission, FEMA or their raspective and necessary consultants.

In response to paragraph (b)(4) of 10 CFR 52.790, I further sub-mit:

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That the above identified confidential information has been held in confidence. by the Applicants and the indi-viduals and contractors insof ar as it relates to the Plan; l

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(ii)

That this inf ormation is of a type which is customarily halu in confidence by the Applicants because it relates to proprietary contractual relationships or af f ects the personal privacy of individuals; (iii)

That the inf ormation has been transmitted to and received by the Commission in confidence; (iv)

That this infor ation as it relates to the. Plan is not available in public sources; and (v)

That public disclosure or this inf ormation would cause substantial harm to the Applicants. Substantial time, effort and money has been expended in the development of this information which included preparation of the Plan and the negotiation and execution of the supporting contracts. As indicated above, premature disclosure of the information could undermine the viability of the Plan and the commitment of those entities and individuals to its successful implementation.

This information could not, as a practical matter, be properly acquired or duplicated by others and, if the inf ormation were disclosed by the Commis-sion, it would be extremely dif ficult for the Applicants to enlist other participants in the future to replace those whose participation was discouraged by such disclosures.

Ted C. Feige'nbaus i

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STATE OF NEW HAMPSHIRE December 30, 1987 Rockingham, ss Then appeared before se the above-described Ted C. Teigenbaum and i

made oath that he has read the foregoing affidavit and that the state-forth therein are true to the best of his knowledge.

ments set Before me.

bh:*b b bhwAu Beverly Q Silloway, Not% Public My Commission expires:

March 6, 1990 i

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ENCLOSURI 5 LOCATIONS OF AGRICULTURAL PRODUCERS IN INGESTION PATHWAY EFZ BY TOWNS / COMMUNITY SEABROCK STATION 1

APPENDIX L City Zie Action, MA 01720 Action, MA 01719 Amesbury, MA 01413 Andover, MA 01910 Arlington, MA 02174 Ayer, MA 01432 Aye r, MA 01433 Bedford, MA 01730 Belmont, MA 02178 Beverly, MA 01915 Billerica, MA 01730 Billerica, MA 01821 Billerica, MA 01862 Boston, MA 02210, 02118, 02202, 02105, 02110, 02116, 02123, 02108, 02199, 02114, 02109, 02131, 02117, 02109, 02021, 02115, 02125, 02124, 02111. 02134, 02130 02155, 02146 Boxborough, MA 01719 Boxford, MA 01921, 01885 Bradford, MA 01R30 1

Braintrae, MA 02184 Brookline, MA 01535, 02146, 02147, 01515, 02167 Burlington, MA 01803 Cambridge, MA 02140, 02139, 02138 i

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City

JJy, Carlisle, MA 01741 Chelmsford, MA 01824 Chelsea, MA 02150 Cochituate, MA 01760, 01778 Cohasset. MA 02025 Concord, MA 01742, 01034 Danvers, MA 01923,,01937 Dedham, MA 02026 Dove r, MA 02030 Dracut, MA 01826 Dunstable, MA 01827 Essex, MA 01929 Framingham, MA 01701, 01581 Georgetown, MA 01833 01oucester, MA 01930, 01939 Croton, MA 01450, 01472 Croveland, MA 01834 Hamilton, MA 01982, 01936 Harvard, MA 01944, 01451, 01453 Kingham, MA 02043 Hudson, MA 01746, 01745, 01749

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Ipswich, MA 01938, 01760, 02364 I

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Appendix L (continued)

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Zig Lawrence, MA 01840, 01842, 01843, 01845 Lexington, MA 02173 Lincoln, MA 01773 Littleton, MA 01460 Lowell, MA 01851, 01852, 01853, 01854 Lynn, MA 01905, 01901, 01903, 01902 Lynnfield, KA 01940 Magnolia, MA 01930 Malden, MA 02148, 01520 Manchester, MA 01944 Marblehead, MA 01945 Marlborough, MA 01752, 01330, 01246, 01756 Maynard, MA 01759, 01754

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i Medford, MA 02155 Melrose, MA 02176 i

Ferrimac, MA 01460 Methuen. HA 01844, 01018 Middletown, MA 01949 I

Milton, MA 02186, 02187, 02170 N. Andover, MA 01845 N. Reading, MA 01846, 01864 I

Appendix L (con 8&nued) g Zip _

Natick, MA 01760, 01776 Needham, MA 02192, 02090, 02194 Newbury, MA 01930, 01950, 01985, 01922 T

Newburyport, KA 01950 Newton, MA 02161, 02062, 02164, 02158, 02168, 02167, 02130, 02165, 02166, 02159, 02160 Peabody, MA 01960 Pepperell, MA 01463, 01437 Quincy, MA 02169, 02170, 03848 Reading MA 01867 Revere, MA 02151 Rockport, MA 01966 Rowley, MA 01969 Sales, MA 01970 Salisbury, MA 01950, 01952, 01959 f

S au gus, MA 01906 Scituate, MA 02050, 02066 Shirley, MA 01464 i

Somerville, MA 02143, 02144 Still River, MA 01467 Stoneham, MA 02180 Stow, MA 01775 Sudbury, MA 01776 Tewksbury, MA 01876 1

Appendix t (con 81nued) f

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City Zip Topsfield, MA 01983 Townsend, MA 01469, 01474 Tyngsboro, MA 01879 Wakefield, MA 01880 Waltham, MA 02154 Watertown, MA 02172 Wayland, MA 01778 Wenham, MA 01984 Vestford, MA 01886 Weston, MA 02193 Wilmington, MA 01887 Winchester, MA 01890 Winthrop, MA 02152

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Woburn, MA 01801 l

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