ML20236V730
| ML20236V730 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/30/1987 |
| From: | Guadagna S NATIONAL SCHOOL BUS SERVICE, INC., NEW HAMPSHIRE, STATE OF |
| To: | |
| Shared Package | |
| ML20236V731 | List: |
| References | |
| CON-#487-4973 OL, NUDOCS 8712070033 | |
| Download: ML20236V730 (3) | |
Text
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QLAIED CORRESf0f(DM 00LKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 37 EC -3 P3 :29 before the l
OFFICE Of 5EJtRnY.
i ATOMIC SAFETY AND LICENSING BOARD 00CKEigrggUtviCL i
In the Matter of
)
November 30, 1987
)
PUBLIC SERVICE COMMNY OF
)
Docket Nos. 50-443-OL NEW HAMPSHIRE, e.
41.
)
50-444-OL
)
Off-site Emergency (Seabrook Station, Units 1 & 2)
)
Planning Issues
)
BEBUTT6L TESTIMONY QE S6L E GU6D6GU6 Q:
Please state your name and occupation.
A:
My name is Sal P. Guadagna.
I am Director of Operations for National School Bus Service, Inc. (National) for the New England region.
Q:
What is the purpose of your testimony?
A:
The purpose of my testimony is to discuss the three (3)
Letters of Agreement that I signed on April 22, 1987, on behalf of National, with the "ew Hampshire Emergency Management Agency.
Copies of these Agreements, as taken f rom my file, are attached to this testimony and were designated as Exhibits lA, 1B, and 1C for my deposition given in this proceeding on October 27, 1987.
T.ese three (3) Letters of Agreement were signed by me f or National concerning three f acilities of National:
Ber ry Transportation, a division of National School Bus Service, Inc.,
formerly Berry Transportation h,
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Company (Berry); Marinel, a division of National School Bus Service, Inc., f ormerly Marinel Transportation, Inc., (Marinel) and National 1
School Bus Service, Inc. of North Chelmsford, Massachusetts, formerly Marinel,- (North Chelmsf ord).
At the time I signed each of these Letters of Agreement, to the best of my knowledge and belief the number of drivers indicated on each agreement as "available" to drive ousec in the event of a an emergency at Seabrook Station was blank.
I have no memory of either.
myself or anyone on my staff at any time filling in the number of "available" bus drivers to drive in the event of a radiological emergency at Seabrook.
My belief is f urther supported by the f act that it is my practice, if I had filled in the numbers of available bus drivers in each agreement, to have filled in the same numbers on my own file copies.
My own file copies concerning available drivers, for each of these three (3) agreementc, however, are blank.
Finally, at the time I signed each of these Letters of Agreement in April, I had taken no poll or survey of bus drivers to determine who would volunteer to drive in the event of an emergency at seabrook.
I theref ore did not know then, nor do I know now, how many drivers would actually be available to drive in an emergency.
I understand that Letters of Agreement have been admitted into this proceeding, identical to those three (3) that I signed on April 22, 1987, except that the numbers of the "available" drivers have 2
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l' been filled in:
"65" for Berry, "65" for Marinel, and "170" for North Chelmsf ord.
These Agreements are Exhibits 1, 2, and 3 in my deposition.
I must note that the " sixty-five" (65) numbers contained in the Berry and Marinel Letters of Agreement, which are hand written, look like they could be my writing.
The handwritten number One Hundred Seventy (170), however, in the North Chelmsf ord Letter of Agreement' does not at all look like my handwriting.
Based upon my discussion above, theref ore, I conclude it is more likely than not that the numbers of available bus drivers were blank when I signed the three (3) Letters of Agreement.
At no time have I ever known the specific number of drivers who may be available f rom National to drive buses in the event of an emergency at Seabrook.
Any drivers willing to perf orm this f unction will do so on a strictly volunteer basis and I have no idea how many volunteers would in f act be available.
For purposes of completeness, I would also offer, as part of my testimony, my deposition, in its entirety, taken on October 27, 1987, including deposition exhibits.
At my deposition, I was questioned by a number of attorneys in this case concerning the availability of drivers to be provided by National and I wish my testimony in this case to be accurate and complete.
Dated:
November 30, 1987 3
SHAINES 6:McCACHERN = PROFES$10NAL ASSOCIATION 76 MAPLEWOOD AVENUE'. P. O BOM B60 POR'5 MOUTH N H C3801
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