ML19350B495

Affidavit Re Potential Problems W/Evacuation of Residents of Salisbury,Ma.Certificate of Svc Encl

ML19350B495
Person / Time
Site:	Seabrook
Issue date:	03/06/1981
From:	Olivera E SALISBURY, MA
To:
Shared Package
ML19350B478	List: ML19350B477 ML19350B480 ML19350B485 ML19350B489 ML19350B495
References
NUDOCS 8103200659
Download: ML19350B495 (5)

Text

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O AFFIDAVIT OF EDWIN OLIVERA I, Edwin Olivera, Police Chief of the Town of Salisbury do hereby depose and say as follows:

1. Salisbury is a Massachusetts town within ten miles of the site of the nuclear reactor under construction in Seabrook, New Hampshire.

2. Its permanent population of approximately 5,600 residents increases by over 10,000 people between Memorial Day and Labor Day. It is additionally visited by 1,000 - 5,000 motorists daily during the above summer vs. cation period.

3. This large increase in populat'.on and daily influx of beachgoers creates severe congestion a*ong the single access road to our beach. This one-lane access road is fed by Routes 1, 110 and Interstates 495 and 95.

4. At this " feeding" point, Salisbury Square, there is a bottleneck which causes traffic congestion and back-up.

5. These same roads are also used by beachgoers on their way south from Hampton Beach. In an evacuation situation, the concestion will be worsened by this southward evacuation.

6. In normal peak season, traffic emergency vehicles suffer great delay and are caught up in the slow traffic.

7. In the Salisbury area, the state reservation camping area and the three trailer parks are frequented by, among others, French Canadians who do not. understand English.

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8. The-Greenleaf Manor Nursing Home and other housing for the elderly are within ten miles of Seabrook. The two schools in Salisbury are between five and seven miles from Seabrook.

9. I estimate that 1001 evacuation of Salisbury would take at least eight hours.

10. Our biggest evacuation problem is access to and from the beach.

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11. As an official who would be involved in effectuating i any actual evacuation, I f eel that the issue of emergency evacuation planning should be addressed at the earliest possible time.

Signed under the pains and penalties of perjury this 6th day of March, 1981.

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Commonwealth of Massachusetts ,

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i Suffolk, ss.

l Edwin Olivera appeared before me and swore that he has read this affidavit and that the statements contained in it are i true to the best of his knowledge and belief, j- Before me, L T 's 1_

Notary Public I

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CERTIFICATE OF SERVICE I , JO ANN S HO TWELL , hereby certify that the foregoing

" Memorandum of the Commonwealth of Aassachusetts in Support of Seacoast Anti-Pollution League 's Request for an Order to Show Cause Dated June 30, 1980" was served upon the following by depositing copies thereof in the United Staes Mail, postage prepaid, this 13th day of March, 1981:

John Ahearne, Chairman Roy P. Lessy, Esquire Victor Gilinsky, Commissioner Office of the Executive Legal Richard T. Kennedy, Commissioner Di rec tor U.S. Nuclear Regu'.atory Commission U.S. Nuclear Regulatory Comm'n Washing ton, D.C. 20555 Washing ton, D.C. 20555 Samuel Chilk, Secretary E. Tupper Kinder, Esquire U.S. Nuclear Regulatory Comm'n Assistant Attorney General Washington, D.C. 20555 Environmental Protection Division Office of the Attorney General Alan S. Rosenthal, Chairman 208 State House Annex Atomic Safety and Licensing Concord, New Hampshire 03301 Appeal Board U.S. Nuclear Regulatory Comm'n Ellyn R. Weiss, Esquire Washing ton, D.C. 20555 Karen P. Sheldon, Esquire Sheldon, Harmon, Roisman, & Weiss Dr. John H. Buck 1725 I Street., N.W. Suite 506 Atomic Safety and Licensing Washington, D.C. 20006 Appeal Board U.S. Nuclear Regulatory Comm'n Atomic Safety and Licensing Washing ton, D.C. 20555 Board Panel U.S. Nuclear Regulatory Comm'n Michael C. Farrar, Esquire Washing ton, D.C. 20555 Atomic Safety and Licensing Board Panel Dr. Ernest O. Salo U.S. Nuclear Regulatory Comm'n Professor of Fisheries Research Washing ton, D.C. 20555 Institute College of Fisheries Ivan W. Smith, Esquire University of Washington Atomic Safety and Licensing Seattle, Washington Board Panel U.S. Nuclear Regulatory Comm'n Thomas Dignan, Esquire Washing ton, D.C. 20555 Ropes and Gray 225 Franklin Street Dr. Marvin M. Mann Boston, Mass. 02110 Atomic Safety and Licensing Board Panel Leonard Bickwit, Esquire U.S. Nuclear Regulatory Comm'n Office of the General Counsel Washington, D.C. 20555 Washington, D.C. 20555

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• Docket and Service Section Robert A. Backus, Esq.

Office of the Secretary O'Neill, Backus, & Spielman U.S. Nuclear Regulatory Comm'n 315 Lowell Street Washing ton, D.C. 21555 Manchester, New Hampshire 1

l Joseph F. Tubridy, Esquire Dr. Kenneth A. McCollum 4100 Cathedral Avenue, N.W. 1107 West Knapp Street Washington, D.C. 20016 Stillwater, Okalhoma 74074

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By: C ~-

JO.ANM SHOTWELL

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Assistant Attorney General Environmental Protection Division Public Protection Bureau Department of the Attorney General One Ashburton Place, 19th Floor

-Boston, Massachusetts 02108

(617) 727-2265 4

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