ML20206M601

Affidavit of RA Backus Re Encl Draft Affidavit Containing Info Conveyed to Author by D Laughton.Certificate of Svc Encl

ML20206M601
Person / Time
Site:	Seabrook
Issue date:	04/15/1987
From:	Backus R BACKUS, MEYER & SOLOMON, 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 8704200142
Download: ML20206M601 (5)

Text

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1. II AFFIDAVIT OF ROBERT A. BACKUS

1. My name is Robert A. Backus and I am counsel for i

intervenor Seacoast Anti-Pollution League.

2. There is attached to this Affidavit, a draf t affidavit containing~information conveyed to me by Mr. David Laughton, who signed a June 2,1986 letter of agreement contained in the NHRERP.

3. This date, Mr. Laughton's office informed me that he would not sign any affidavit although requested to do so. None-theless, I affirm, under oath, that the information in the draft affidavit is, to my knowledge, an accurate recitation of the information Mr. Laughton gave to me over the telephone on April 14.

Date: April 15,1987 Robert A. Backus STATE OF NEW HAMPSHIRE COUNTY OF HILLSBOROUGH Then personally appeared before me the above-named Robert A.

Backus and acknowledged that the foregoing statements by him subscribed are true and correct to the best of his knowledge and belief.

, Before me, l

. a.unL [

._iLLC OJtmt L Wotary-Publ-ic/ Justice of the Peace 42%2y50 3 l

0

AFFIDAVIT OF DAVID LAUGHTON

1. My name is David Laughton. I am the Secretary / Treasurer of Teamster Local 633, and I executed a June 2, 1986 Letter of Agreement, a copy of which is attached hereto.

2. My estimate of 1,500 teamster personnel with at least a light commercial license, referred to in the Letter of Agreement, is a conservative estimate of the number of members of Local 633 holding this type of license throughout the State of New Hampshire.

3. The numbers referred to include drivers for a wide variety of businesses, including companies such as United Parcel.

4. Teamster members as such always try to be of assistance to the community in the event of a civil emergency. However, I have no knowledge of.the actual number of teamsters that would be available at any particular time to drive buses into the Seabrook Evacuation Zone in the event of a radiological emergency.

5. Teamsters could only operate buses owned by private bus i companies with the permission of the management of those companies.

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[ I have no knowledge as to whether such permission exists.

l 6. Although our membership has discussed the concept of I assisting the public authorities in civil emergencies at our union ,

t meetings, and the subject has been addressed in our newsletter, I know of no actual survey of individual members of formal vote of the membership as a whole committing any particular number of members to' respond specifically to a radiological emergency at Seabrook.  !

I l

Date:

David Laughton l

i 'o STATE OF NEW HAMPSHIRE COUNTY OF Then personally appeared before me the above-named David Laughton and acknowledged that the foregoing statements by him subscribed are true and correct to the best of his knowledge and belief.

i Before me, Notary Public/

Justice of the Peace

i

/

CERTIFICATE OF SERVICE AND SERVICE LIST y

Joseph Flynn Asst.Gn.Cnsl. IIelen lloyt . Chm.

• Thomas Dignan, Esq.*

F;d. Emerg. Algmt . Agcy. Admn. Judge Ropes & Gray 500 C.St. So. West Atomic Safety & Lic Brd. 225 Franklin St.

Washington, DC 20472 USNRC Boston, MA 03110 Washington, DC 20555 C OL *.E ill UWC Office of Selectmen Dr. Jerry liarbour

• Docketing & Serv. Sec.

• Toun of flampton Falls Admin. Judge llampton Falls , NII 03844 Atomic Safety & Lic Brd. '8.pfQp 0ofg1t *g Secretary USmtC USNRC Washington, DC 20555 Washington, DC 20555 0FFM o r a a d /o f 00CKEhh3ait WICI.

Shenvin E. Turk, Esq. 5t' Jan@#d6tighty Office of Exec. Legl. Dr.

Dr. Gustave A. Linenberger

• Admin Judge SAPL USNRC Atomic Safety & Lic. Brd. 5 Market Street Washington, D.C. 20555 USNRC Portsmouth , NII 03801 Washington, DC 20555 Phillip Ahrens, Esq. Paul McEachern, Esq. George Dana Bisbee, Esq.

Asst. Atty. General 5!atthew Bruck, Esq. Attorney General's OFF.

State llouse , Sta. #6 25 Maplewood Ave. State of New Ilampshire Augusta, ME 04333 P.O. Box 300 Concord, N!! 03301 Portsnouth, MI 03801 i

Carol Sneider, Esq. , Asst. AG Diano Curran, Esq. William S. Lord One Ashburton Place, lia rmon , Weiss Board of Selectnen 19th Floor 20001 S Street NV Suite 430 Town IIall-Friend St.

Boston, MA 02108 Washington, DC 20009 Anesbury, MA 01913 Richard A. Ilanpe, Esq. Maynard Young, Chainnan Sandra Gavutis E2w llanpshire Civil Dinense Board of Selectnen Town of Kensington Agency 10 Central Ibad Box 1154 llampe & McNicholas Rye, NI 03870 East Kingston, N.II. 03827 35 Pleasant St.

Q)ncord, NI 03301 Judith !!. Mizner, Esq. Edward Thorms Mr. Pobert liarrison Silverglate, Gertner, FDIA Pres, & Chief Exec. Officer Baker, Fine, Good &,Blizner 442 J.W. McCormack (1031) PSCO 88 Broad Street Doston, MA 02109 P.O. Dox 330 Doston, In 02110 Manchester, MI 03105 lbberta Pevear State Ibp.-Town of llanpt Falls Drinkwater lload Ihtnpton Falls, NI 03344 L _-