ML20206M864

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Affidavit of a Hutchinson Re Difficulties That Might Be Encountered in Finding Bus Drivers Willing to Participate in Emergency Evacuation Plan.Certificate of Svc Encl
ML20206M864
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 04/13/1987
From: Hutchinson A
BERRY TRANSPORTATION CO., HAMPTON, NH
To:
Shared Package
ML20206M356 List:
References
OL, NUDOCS 8704200234
Download: ML20206M864 (5)
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AFFIDAVIT  :

1. My name is Ann Hutchinson and I am Division Manager l, of Berry Transportation Company, North Hampton, New Hampshire. #
2. Berry Transportation Company has signed a Letter i*

Agreement with the State of New Hampshire stating that:

In the event of an emergency and in '

coordination with the State,- and subject l to driver avail' ability, Berry Transportation Company, Inc. will make all efforts to deploy its vehicles to those local emergency j'}

3 operations centers as requested by 5 New Hampshire Civil Defense Agency. l

3. I personally superti' sed 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 [

y that Berry Transportation Company has promised to make "all i efforts" to make available for emergency represent an absolute maximum and that', in an actual emergency, not all of I 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 li to carry out their assigned duties.

drivers either were unavailable, refused to participate in The vast majority of -

[I.

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. t.

Had the exercisebeen an actual emergency, I could not have obtained the nine drivers promised by Berry Transportation -. [J to implement the RERP. ,,, [

6. Those bus and driver pairs actually attempting to f implement the RERP further experienced mechanical problems, L 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.

e704200234 870415 3 DR ADOCK 0500

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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.

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Dated: April /3, 1987 h hN '

Ann Hutchinson STATE OF NEW HAMPSHIRE COUNTY OF ROCKINGHAM SS.

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

Subscribed and sworn to before me.

. Notary Public N I

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l CERTIFICATE QE SERVICE I, Matthew T. Brock, one of the attorneys for the yn of Hampton herein, hereby ce rtify that on Aprill5,19 87, I ma rvice of the l following documents, TOWN OF HAMPTON ANSWER OPP G APPLICANTS' ,

MOTION FOR

SUMMARY

DISPOSITION (TOH IV) and TOWN OF HAMPTON ANSWER i OPPOSING APPLICANTS' MOTION FOR

SUMMARY

DIS gqq PYdE6VI) by depositing copies thereof with Express Mail, pre i d,~ for delivery to (or, where indicated, by depositing in the United States. mail, first class postage paid, addressed to): FFig,MhOir mu.NCH

  • Helen Hoyt, Esq., Chairmat Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission ,

East West Towers Building 4350 East West Highway Be thesda , MD 20814

  • Judge Gustave A. Linenberger, Jr.

Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814

  • Dr. Jerry Harbour Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission East West Towers Building l 4350 East West Highway Bethesda, MD 20814 i
  • Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555
  • Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission l Washington, D.C. 20555
  • Docketing and Service U.S. Nuclear Regulatory Commission Washington, D.C. 20555 SH AIN ES & McE ACHERN . ==cwas.o..t assoc >.m ano==r.,

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Mrs. Anne E. Goodman

  • Board of Selectmen j

! 13-15 Newmarket Road i i Durham, NH 03 842

! i l William S. Lord, Selectman Town Hall Friend Street Amesbury, MA 01 913 Jane Doughty Seacoast Anti-Pollution League 5 Market Street Portsmouth, NH 03 801 Rep. Roberta C. Pevear Drinkwater Road Hampton Falls, NH 03844

  • Philip Ahrens, Esq.

Assistant Attorney General Office of the Attorney General State House Station 6 Augusta, ME 04333

  • Thomas G. Dignan, Esq.

R.K. Gad II, Esq.

Ropes & Gray 225 Franklin Street Boston, MA 02110 Robert A. Backus, Esq.

Backus, Meyer & Solomon 111 Lowell Street Manchester, NH 03105

  • Sherwin E. Turk, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission {

Tenth Floor 7735 Old Georgetown Road Bethesda, MD 20814 Mr. Angie Machiros, Chairman Board of Selectmen Newbury, MA 01950 u

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I SH AINES & McE ACHERN = .aoerssma sas.ocaave a+to=%e.s

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l H.. Joseph Flynn,'Esq. ) i d '

! Office of General Counsel i Federal Emergency Management Agency l 500 C Street, S.W.

Washington, D.C. 20472

  • George Dana Bisbee, Esq. ,

Stephen E. Merrill, Esq.

Office of the Attorney General State House ' Annex Concord, NH 03301

  • Carol S. Sneider, Esq. -

Assistant Attorney General Department of the Attorney General One Ashburton Place 19th Floor Boston, MA 02108 .

Stanley W. Knowles Board of Selectmen P.O. Box 710 North Hampton, NH 03862 J.P. Nadeau, Selectman s Selectmen's Office 10 Central Road Rye, NH 03870 Richard E. Sullivan, Mayor City Hall Newburyport, MA 01950 Alf red V. Sargent, Chairman Board of Selectmen Town of Salisbury Salisbury, MA 01950 Senator Gordon J. Humphrey U.S. Senate Washington, D.C. 20510 (Attn: Tom Burack)

Michael Santosuooso, Chairman Board of Selectmen Jewell Street RFD 2 South Hampton, NH 03 827 3

f SH AINES & McE ACHERN = **cessseas associst.c/, ~onw.s

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Allen Lampert  ;

Civil Def ense Director f Town of Brentwood ..- .

Exeter, NH 03233  %(

Richard A. Hampe, Esq.

Hampe and McNicholas 4 35 Pleasant Street Concord, NH 03301 Gary W. Holmes, Esq.

Holmes & Ellis 47 Winnacunnet Road -

3', Hampton, NH 03842 William Armstrong -

' Civil Def ense Director

_' /. 10 Front Street

Exeter, NH 03833
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  • Calvin A. Canney e' i City Manager City Hall 126 Daniel Street Portsmouth, NH 03 801 .

Boston, MA 02109 Sandra Gavutis i Town of Kensington RFD 1, Box 1154 East Kensington, NH 03 827 Charles P. Graham, Esq.

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!k 'McKay, 100 MainMurphy Street& Graham Amesbury, MA 01913

  • Diane Curran, Esq.

Andrea C. Ferster, Esquire Harmon & Weiss

Suite 430 2001 S Street, N.W.

Washington, D.C. 20009-1125 t

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SH AINES & McE ACHERN . morssoo a6 assoosto. ano==rvs

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1 Robert Carrigg, Chairman '

Board of Selectmen i Town Office i l

Atlantic Avenue North Hampton, NH 03862 5cnator Gordon J. Humphrey One Eagle Square, Suite 507 Concord, NH 03301 (Attn: Herb Boynton)

Mr. Thomas H. Powers, III Town Manager

  • Town of Exeter 20 Front Street Tixater, NH 03833 Mr.' Peter Matthews Mayor City Hall Newburyport, MA 01950 Brentwood Board of Selectmen RFD Dalton Road Brentwood, NH 03833 Judith H. Mizner, Esquire Silvergate, Gertner, Baker, Fine, Good & Mizner 88 Broad Street Boston, MA 02110 I .<a  %

Matthew T. Brock

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ArrIDAVIT  !

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1. My name is Glen French, Pr e t of the Town of Hampton Chamber of Commerce. Ave *4vf,Deechic
2. That this Affidavit is given to provide population estimates for the Town of Bampton as relied upon and used by the i Bampton Chamber of Commerce in advising and conferring with area .

businesses.

3. That within the Town of Bampton-on a summer weekend, and ,

assuming a sunny day and favorable beach weather, the Bampton  ;

Chamber of Commerce would estimate the total number of persons -

within the town on a given day at 150,000 to 200,000. j

4. That within the Town of Hampton on a Fourth of July )

weekend, and assuming a sunny. day and favorable beach weather, the

'Bampton Chamber of Commerce would estimate the total population }

within the Town of Hampton on a Fourth of July weekend day at up  :

to 250,000 individuals.

Dated: February do , 1986 .

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', L. kw - M A .w.s k I j enFr%h t The State of New Hampshire February do , 1986 Rockingham, ss. 5 i

Personally appeared the above-named Glen French and swore to [

the truth of the foregoing statements based upon personal i knowledge, information and belief. .

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