ML20206M429

Affidavit of a Hutchinson Re Berry Transportation Co Response to State of Nh Civil Defense Request During Facility Emergency Exercise Carried Out in Feb 1986

ML20206M429
Person / Time
Site:	Seabrook
Issue date:	04/13/1987
From:	Hutchinson A SEACOAST ANTI-POLLUTION LEAGUE
To:
Shared Package
ML20206M223	List: ML20206M219 ML20206M278 ML20206M296 ML20206M302 ML20206M311 ML20206M326 ML20206M343 ML20206M380 ML20206M400 ML20206M429 ML20206M455 ML20206M496 ML20206M522 ML20206M544 ML20206M568 ML20206M601
References
OL, NUDOCS 8704200108
Download: ML20206M429 (2)

Text

I AFFIDAVIT

1. My name is Ann Hutchinson and I am Division Manager of Berry Transportation Company, North Hampton, New Hampshire.

2. Berry Transportation Company has signed a Letter Agreement with the State of New Hampshire stating that:

In the event of an emergency and in coordination with the State, and subject to driver avail' ability, Berry Transportation Company, Inc. will make all efforts to deploy its vehicles to those local emergency.

operations centers as requested by New Hampshire Civil Defense Agency.

3. I perscnally supervised the response of the Berry Transportation Company to requests by New Hampshire Civil Defense during the emergency exercise for Seabrook Sttation carried out in February, 1986.

4. Based on my experience during the course of that emergency exercise, it is my opinion that the nine drivers that Berry Transportation Company has promised to make "all efforts" to make available for emergency represent an absolute maximum and that, in an actual emergency, not all of these drivers may in fact be available.

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5. I base this opinion on the fact that of approxi-mately 57 Berry Transportation Company drivers that I attempted to contact to implement the RERP during the emergency exercise, only five stated they would be willing to carry out their assigned duties. The vast majority of drivers either were unavailable, refused to participate in the exercise, or stated that they would participate in the exercise in a limited capacity but would not implement the RERP in the event of an actual emergency at Seabrook Station.

Had the exercise been an actual emergency, I could not have obtained the nine drivers promised by Berry Transportation to implement the RERP.

6. Those bus and driver pairs actually attempting to implement the RERP further experienced mechanical problems, delays, miscommunications and lack of information from the State, and otherwise were unable to implement the RERP in accordance with the terms of that plan.

8704200108 870415 PDR ADOCK 05000443 G PDR

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7. It is my opinion that similar difficulties would arise in the event of an actual emergency at Seabrook and it is reasonable to expect that other bus companies employed to carry out the RERP would experience similar problems in implementing the plan in the event of an actual emergency.

Dated: April /3 , 1987 dbv Mw'c./m-. > v Ann Hutchinson STATE OF NEW HAMPSHIRE COUNTY OF ROCKINGHAM SS.

Personally appeared ANN HUTCHINSON and stated the above statements are true to the b'est of her knowledge, information and/or belief.

Subscribed and sworn to before me.

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% as Notary Public

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