ML20140F277

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Forwards Draft Criteria for State Consideration Re NRC Funding of Agreement State Travel,Training & Technical Assistance Costs in Those Instances Where Agreement State Demonstrates That State Funds Not Available
ML20140F277
Person / Time
Issue date: 06/09/1997
From: Bangart R
NRC OFFICE OF STATE PROGRAMS (OSP)
To:
GENERAL, OHIO, STATE OF, OKLAHOMA, STATE OF, PENNSYLVANIA, COMMONWEALTH OF
References
SP-97-040, SP-97-40, NUDOCS 9706130027
Download: ML20140F277 (19)


Text

_. _ -

t ALL AGREEMENT S'TATES

'JM 0 91907 OHIO, OKLAHOMA, PENNSYLVANIA l

TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORMATION (SP-97-040 )

Your attention is invited to the enclosed correspondence which contains:

INCIDENT AND EVENT INFORMATION.........

PROGRAM MANAGEMENT INFORMATION...

l TRAINING COURSE INFORMATION..............

L l

' TECHNICAL INFORMATION........................XX GUIDELINES FOR PAYING FOR l

STATE TRAINING AND TRAVEL EXPENSES FOR COMMENT l

O TH ER IN FO R M ATIO N................................

Supplementary information: The Commission in Staff Requirements Memorandum (SRM) dated March 19,1997 (Enclosure 1), directed the staff to develop criteria that will be used to allow NRC funding of Agreement State travel, training, and technical assistance costs in those instances where Agreement States demonstrate that State funds are not available or cannot be used for these purposes. The staff has developed draft criteria (Enclosure 2) for State consideration. The staff developed the criteria consistent with the Commission direction that the criteria should not be " pro forma" approvals.

Please provide comments by letter or e-mail by June 20,1997, to the contact listed below.

I We apologize for the short comment period.

[

POINTS OF CONTACT:

Dennis M. Sollenberger TELEPHONE:

(301) 415-2819 FAX:

(301) 415-3502 l

INTERNET:

DMS4@NRC. GOV D

RICHARD L RT Richard L. Bangart, Director Office of State Programs

Enclosures:

As stated llllllllllllll11115!lllllllllll 130003 l

Distributign:

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OFFICE OSPg l OSP:Q NAME DSollenbergehkk PLohaus W #

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1 UNITED STATES g

j NUCLEAR REGULATORY COMMISSION J

,2 WASHINGTON. D.C. 20666-0001 i

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June 9, 1997 TIME SENSITIVE INFORMATION l

ALL AGREEMENT STATES I

l' OHIO, OKLAHOMA, PENNSYLVANIA i

TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORMATION (SP-97-040)

Your attention is invited to the enclosed correspondence which contains:

INCIDENT AND EVENT INFORMATION.........

PROGRAM MANAGEMENT INFORMATION...

l TRAINING COURSE INFORMATION..............

l l

TECHNICAL INFORMATION........................XX GUIDELINES FOR PAYING FOR STATE TRAINING AND TRAVEL i

EXPENSES FOR COMMENT l

OT H E R I N FO R M ATI O N...............................

i

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I Supplementary Information: The Commission in Staff Requirements Memorandum (SRM) dated March 19,1997 (Enclosure 1), directed the staff to develop criteria that will be used 4

to allow NRC funding of Agreement State travel, training, and technical assistance costs in those instances where Agreement States demonstrate that State funds are not available or cannot be used for these purposes. The staff has developed draft criteria (Enclosure 2) for l

State consideration. The staff developed the criteria consistent with the Commission direction that the criteria should not be " pro forma" approvals.

Please provide comments by letter or e-mail' by June 20,1997, to the contact listed below.

We apologize for the short comment period.

POINTS OF CONTACT:

Dennis M. Sollenberger TELEPHONE:

(301) 415-2819 FAX:

(301) 415-3502 INTERNET:

DMS4@NRC. GOV k&ll k

Richard L. Bangart, Direct 9 Office of State Programs (

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Enclosures:

As stated t

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UNITED STATES k

NUCLEAR REGULATORY COMMISSION

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WASHWGTON, D.C. 20$55 0001

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March 19, 1997 sacartAny 1

MEMORANDUM TO:

L. Joseph Callan Executive Director for Operations Karen D. Cyr General Counsel Ronald Scroggins Act g Chief Financial Officer

/$-Q__

u-FROM:

J h, C. Hoyle', Secretary

SUBJECT:

STAFF REQUIREMENTS - COMSECY-96-054 - NRC's RELATIONSHIP WITH AGREEMENT STATES (DSI 4)

The Commission continues to support its preliminary view to i

continue the current Agreement States Program, including adopting current initiatives (Option 3), subject to the following additions and modifications.

With regard to the funding of Agreement State travel, training, and technical assistance, the Commission modifies the present policy to allow NRC funding of such costs in those instances where Agreement States demonstrate that state funds are not available or cannot be used for these purposes.

The staff should develop criteria, for the Commission's consideration, for making this determination.

The criteria should be stringent enough to provide adequate assurance to the Commission that the state has thoroughly explored funding alternatives available to the state and a determination by a high ranking state official (e.g.,

state agency head or chief financial officer) has been made that funds are not available.

In such cases, states should also explore partial funding of costs.

Such an approach must be designed to ensure that such certifications are not apro forma" and that use of NRC-licensee funds for these purposes are in the public interest.

The staff's proposals should provide for funding and should be provided to the Commission in a time frame that would allow implementation of the modified policy beginning in FY-98.

Otherwise, training should be made available on a " space available" basis with Agreement States funding their own travel and per diem costs.

(EBO/C-FO)

(SP/CFO)

(SECY Suspense:

7/11/97) 9700061 Staff should develop guidance for offering assistance to states on a case-by-case basis that would help the states' agencies ENCLOSURE 1

t 2

identify and clarify their training needs to their appropriate authorities, e.g., the State Cabinet Secretary or legislative body.

NRC should be prepared to offer such help 'e.g.,

a letter) if requested by the Agreement States.

(EDO) (SP)

(SECY Suspense:

9/30/97) 9700062 The staff should also examine cost-effective alternatives for providing training and technical assistance to Agreen.ent States.

..The staff should provide the Commission with a report. on cvailable alternatives and recommendations for assuring that NRC training and technical assistance are provided in a cost-cffective manner.

(Ese) (SP/AEOD)

(SECY Suspense:

9/30/97) 9700062 Public comment on the use of seed money or other tangible benefits to encourage states to become Agreement States did not cupport the concept.

The Commission finds that the use of such incentives is inappropriate and inconsistent with the intended role of the NRC as it fulfills its mission under the Atomic Energy Act.

The Commission believes that the NRC should continue to respond to incoming requests from individual States that express an interest in pursuing Agreement State status and work with each State to achieve this goal.

For the longer term, the NRC should request Congress to enact legislation that would exclude Agreement State funding from NRC's user fee base and provide a separate appropriation to cover these costs.

It is the Commission's view that the Agreement States themselves should be more proactive on this matter.

Moreover, to the degree that funding for the Agreement States program remains in the user fee base, the Agreement States should be more forthcoming with methodologies for bearing a larger share of the costs.

(CFO/OGC/EDO)

(SECY Suspense:

9/30/97) 9700063 SP In the absence of specific comments on the'related issue of whether to continue NRC's Independent Radiation Monitoring Program (IRMP), the Commission requests that the staff evaluate the cost effectiveness of the program and make recommendations on the pros and cons of continuing with the program.

(E50)

(NRR)

(SECY Suspense:

7/11/97) 9700064 cc: Chairman Jackson Commissioner Rogers Commissioner Dieus Commissioner McGaffigan Commissioner Diaz D. Rathbun (OCA)

H. Bell (OIG)

A. Galante (CIO)

W. Beecher (OPA)

CRITERIA TO EVALUATE AGREEMENT STATE TRAINING, TRAVEL, AND TECHNICAL ASSISTANCE FUNDING NEEDS By SRM dated March 19,1997, the Commission directed the staff to develop criteria to determine when Agreement States have demonstrated that State funds are not available or cannot be used for the purposes of training, travel, and technical assistance. The direction was that the criteria should be stringent enough to provide adequate assurance to the Commission that the State has thoroughly explored funding alternatives available to the State and a determination by a high ranking State official (e.g.. State agency head or chief financial officer) has been made that funds are not available. In such cases, States should also explore partial funding of costs. Such an approach must be designed to ensure that such certifications are not " pro forma" and that use of NRC-!icensee funds for these purposes are in the public interest. The staff's prcposals should provide for funding and should be provided to the Commission in a time frame that would allow implementation of the modified policy beginning in fiscal year 1998. Otherwise, training should be made available on a " space available" basis with Agreement States funding their own travel and per diem costs.

The staff understanding is that as a minimum the NRC will make training available to the Agreement States on a space available basis with NRC funding (at least in part) for States that have met the criteria developed by the staff. The staff veill continue to schedule the training courses to meet NRC training needs and only schedule courses to accommodate Agreement State training needs following Commission approval of the criteria and direction to schedule additional courses to accommodate any additional need. The staff does not plan to schedule these additional courses in the future unless the demand would fill the additional courses.

The staff's approach to the development of criteria has focused on four key areas: (1) a State determination of need for training and availability of State funds to meet that need; (2) a State demonstration of need for NRC assistance in funding the State need; (3) the NRC evaluation of the State request against NRC criteria and. logic diagram; and (4) the availability of NRC funds to meet the sum of the State requests. Each area is discussed in further detail below. Each request from a State would need to include information identified in items 1 and 2.

To facilitate preparation of a State request, the staff has developed a questionnaire that the State will need to complete and submit, along with the statement on availability of funds, to the NRC in order to be considered for financial assistance in the training area. A table Submission of for tracking this information is also included at the end of this document.

information identified in the questionnaire, at a minimum, would be necessary for NRC to make a decision on funding.

1.

DETERMINATION OF'NEED FOR TRAINING Each State should have or be developing a training program that would address items a and b below. A State should also examine a range of options or sources for fulfilling its training needs (item c below). This information should provide the basis for the State's ENCLOSU92 2

i development of a realistic estimate of their training needs and costs to accomplish their training program. The Agreement State Radiation Control Program (RCP) should use this estimate to develop their State'a budget request (item d below).

Therefore, the RCP should consider and address the items listed below in determining their need for training; in estimating the funds required to meet their training needs; and in determining whether their necds, or a portion of their needs, are met by their current budget.

a.

Documented training policy and qualification requirements to include:

Qualification of new staff.

Routine training (e.g., refresher and specialty training) of existing staff.

b.

Training critical to performance of program:

IMPEP finding regarding training of staff.

Needed to address a program weakness or deficiency.

c.

Sources of training:

NRC training courses, workshops and meetings.

Has the State evaluated other alternatives to meet their training need?

Did the State find no alternatives or the alternatives do not meet State needs?

d.

Docurnented financial information that includes The number of individuals that need specific training courses not available in-house.

The number of courses and spaces in courses that the State can fund and those that cannot be funded given the current budget allocation for training and travel.

The total training and travel budget approved for the RCP and the portion of this budget allocated for the radioactive materials program. This should be presented in total dollars and in the percentage of the budgeted amount and the percentage of the anticipated need.

2.

DEMONSTRATION OF STATE NEED FOR NRC FUNDING a.

The Agreement State should submit a certification by a high ranking official, such as the agency head or chief financial officer, that funds are not available. This 2

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would need to be done each State fiscal year following the legislative approval and signing of the budget appropriation for the RCP.

This certification should include certain demonstrations by the RCP such as:

The State has authority to spend funds on training and out-of-State travel, or

)

has requested such authority.

The submitted budget for the RCP included requests for the funds to meet l

the training and travel needs of the program.

l The agency management supported the budget submittal.

The legislature has taken action on the budget submittal, but failed to approve the budget request in the training and travel area, or approved only a portion of this budget area.

b.

The submission of the demonstration of need will need to be done each State fiscal year, at a minimum, following the legislative approval and signing of the budget for the RCP. This would allow the maximum time for NRC planning before actual training, travel or technical assistance requests would be submitted.

c.

The timing for the State's submission of the information needed by NRC to complete evaluation of the request should be as soon as possible after the legislature or administration approval decisions or when another unfunded training need is identified. Considerations include:

Most State fiscal years do not coincide with the NRC fiscal year. Thus, the NRC will need to allocate funds for States based on the State fiscal year or it may leave gaps in the training for individual States.

When a State receives a decision on their budget and funding for training, travel and technical assistance and they identify it's not sufficient, they will likely not have much time prior to the beginning of their fiscal year.

Any other time they identify a training need which cannot be met or fulfilled, they willlikely not have any significant lead time.

i 3.

EVALUATION OF STATE REQUESTS / DEMONSTRATION OF NEED AGAINST NRC CRITERIA The NRC staff would first evaluate the State's request / demonstration of need for NRC funding to determine whether the State has legal authority to spend State funds for training, travel and technical assistance. Requests from States that have authority, or have requested authority, would then be evaluated against a set of additional criteria. The flow diagram (see page 6) presents the logic flow to be applied. The evaluation will be made against the following criteria.

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Draft Evaluation Criteria a.

The Agreement State has legal authority to spend State funds for training and travel out-of-State. In cases where an Agreement State does not have legal authority, the Agreement State has requested authority.to spend State funds for out-of-State training and travel.

Agreement States programs that do not have authority to spend State funds on training and out-of-State travel, and do not request such authority, will not be funded, and would not be evaluated further. NRC would further evaluate requests from Agreement States having legislative authority and Agreement States that do not have authority to spend State funds for this purpose, but have requested this authority. Requests vrould be evaluated applying each of the additional criteria below. Amounts would be based on NRC review of the State's estimate based on their documented program, I

b.

The Agreement State has requested funding to cover the required training and travel funds, but was denied funding for training and travel out-of-State, in whole or in p art.

c.

The State agency head (cabinet level) or chief financial office for the State has made and submitted a determination that State funds are not available for training and travel out-of-State, or are insufficient as described in Criterion e. below. After review, NRC concurs that funds available for. 't-of-State training and travel are insufficient to satisfy Agreement State program training needs.

I d.

The Agreement State RCP has limited funds. Of the requested budget amount of for Agreement State program training, the State funded

, and, therefore, i

the RCP can fund percent of its needed training and travel expenses.

e.

If the State has funded at least 90 percent of its projected training needs, NRC will not provide any additional support. If State funding is less than 90 percent cf its l

projected need, the NRC will further evaluate providing funding assistance. The NRC will evaluate funding up to an amount that is approximately the difference between 90 percent of the RCP Agreement State program training, travel and technical assistance budget projection and the actual State funding approved. This assumes that in any given year the program would.not deteriorate based on the 90 percent level.

The NRC will evaluate each Agreement State's funding request that submits the information needed to rnake the abovi, findings. The approval for partial funding will be limited to the State's budget period (1 or 2 years). Without submittal of new budget information, the NRC funding for training and travel for that State will terminate. The NRC will consider unanticipated training needs when fully supported by documentation and cost estimates, if the need covers several years, the need should be incorporated into the next year's budget estimate for the RCP.

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4.

DETERMINATION OF AVAILABILITY OF NRC FUNDS The Commission direction reduced the funding available for Agreement State training, travel and technical assistance to a limited portion of the funding previously allocated to

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the Office of State Programs (OSP). Therefore, the OSP will need to evaluate the total number of requests for training and travel assistance and determine if the requests exceed the allocated funding, if this is the case, then OSP will need to prorate the approvals.

NRC would need to prorate the funding in an equitable manner which could be based on:

l Evenly distribute to those in need.

Distribute so that each State would have the same percentage of its overall training and travel need met, l

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Distribute so that the States with the most urgent needs would be met first. The ranking of need could be based on (1) new staff meeting minimum training requirements, (2) specialty training to meet a program deficiency, (3) special training to broaden the program depth, and (4) refresher training for experienced staff.

l The NRC staff considers that distribution of funds, based on the percentage of the training need being met together witta urgency of need, as the most equitable method of distribution of funds if the total need exceeds the budgeted amount.

The staff will also need to establish a system of evaluation and database to track the financial status of training and travel money for the Agreement State program so that any trends and ongoing short falls in training can be identified and addressed in the budget l

planning process. One of the areas that needs to be tracked is the number of applicants that were not trained. Since the fiscal years for most Agreement States do not coincide with the NRC fiscal year, NRC will need to make estimates, based on past experience, for the budget process to accommodate the fluctuations in the need for funding by the States.

Many States operate on fiscal years that run from July 1 to June 30. There are also a number of States that operate on biennial budgets. For the biennial States, their status will be determined for the entire two-year period unless they receive supplemental funding for training and travel.

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LOGIC FLOW DIAGRAM FOR FUNDING OF AGREEMENT STATE TRAINING, TRAVEL AND TECHNICAL ASSISTANCE l

i Does the State have Has the RCP requested No NRC funding l

authority to fund training, No, authority to fund No assistance.

travel and technical r training, travel and assistance?

technical assistance?

l

,Yes Yes Has the State requested funding for training, travel, No n

and technical assistance?

r

,Yes 1

Was at least 90% of Yes j-g g

request appropriated?

7 gpNo,,

l Has a high ranking State No official certified need for assistance from NRC7 es NRC will consider funding of difference between appropriated amount and 90% of budgeted amount limited to prorated amount if the total from all States is greater than OSP budgeted amount.

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DRAFT OUESTIONNAIRE FOR AGREEMENT STATE TRAINING, TRAVEL, AND TECHNICAL ASSISTANCE FUNDING This questionnaire was developed to collect the information needed to make a decision on whether NRC will fund all or a portion of an individual Agreement State's training and/or travel needs. Please complete the following information and submit it to the contact specified below. Without this information, NRC will not be able make a decision on whether to fund your travel and training requests. Thank you for your assistance, t

1.

The State of is on an annual or biennial budget cycle with the p

current fiscal year beginning on and ending on l

2.

Have you been authorized to spend State funds:

for travel to meetings out-of-State?

Yes No for training including travel to training out-of-State?

Yes No i

3.

Given sufficient funding, is travel and training limited if the State is paying for it?

Yes No l

t This question is to clarify the State's policy not the funding issue.

l 4.

Did you request full funding for your training and travel needs in your budget?

Yes No Did your management support your request by submitting it to your legislature?

Yes No l

Did your legislature act on your training / travel request?

Yes No Did your legislature support your request?

In full _

in part _

No support _

S.

What was your total RCP budget?

6.

What was your estimate for the Agreement State training, travel and technical assistance needs?

7.

What was the RCP training and travel funding request for the Agreement State program?

8.

What was the level of funding for training, travel and technical assistance approved by your legislature?

9.

Are there any special considerations that you would like NRC to consider in

)

determining potential assistance in the training, travel, and technical assistance i

areas? Please explain below.

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lNFORMATION !JEEDS FrP NRC DETERMINATION OF FINANCIAL ASSISTANCE IN THE TRAINING, TRAVEL., AND TECHNICAL ASSISTANCE AREAS STATE' Cycle RCP Bdgt' TRNG Est*

TRNG Bdgt' Comments' 2

' ALABAMA 1,1, ARIZONA 1 M.

ARKANSAS 2,2, CALIFORNIA 1.1 COLORADO 1,1, FLORIDA 1,1, GEORGIA 1,1, IOWA 1.1, ILLINOIS 1,1, KANSAS 1,1,7/1 KENTUCKY 2,2, LOUISIANA 1.1, MAINE 1,2, MARYLAND 1,1, MASSACilUSLTTS l.1, MISSISSIPPI l.1, NEBRASKA l.2, NEBRASKA -(LLW) 1,2, NEVADA 2,2, NEW llAMPSHIRE 1,2, NEW MEXICO 1,1, NYDil 1,1, NYDOL 1,1,

' NYDEC 1,1, NYC 1,1, NORTil CAROLINA 2.2, NORTH DAKOTA 2.2, OREGON 2.2, RilODE ISLAND 1,1, SOUTil CAROLINA 1.1, SOUTil CAROLINA - (LLW) 1,1, 4

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STATE' Cycle RCP Bdgt' TRNG Est*

TRNG Bdgt' Comments' l

2 TENNESSEE 1.1 TEXAS-BRC 2.2.7/a l

TEXAS-TNRCC 2.2.7/1 UTAll I.l.

WASilINGTON 1,2 l

0 111 o 1.2, OKLAIIOMA 1.1 l

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PENNSYLVANIA 1.1 l

The States listed are current Agreement States and the last three are those States which l

have submitted a letter of intent to become an Agreement State.

l This column includes the legislative cycle, the budget cycle, and the beginning date for 2

the budget, respectively (L,B,M/D). An M in the B space indicates that the State has a j

mixed budget cycle and NRC needs additional information from the State to determine l

whether the RCP budget is on an annual or biennial cycle.

8 RCP Bdgt - This column is for the Radiation Control Program (RCP) Budget for the Agreement State program, i

4 TRNG EST - This column is for the estimate of the training costs for the Agreement State program. We recognize that this will only be a portion of the overall training costs for the RCP; however, NRC will only address this aspect of the RCP training program under this j

l assessment.

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TRNG Bdgt - This column contains the amount the RCP budgeted for the Agreement 5

State program training.

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% - This column will contain the percentage of the estimated training budget that was l

funded by the State. This will give the NRC a quick estimate of those States that might j

need assistance in funding their training, travel and technical assistance.

7 Comments - This column is reserved for comments such as special conditions or special hardships that have been identified by the State.

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TIME SENSITIVE INFORMATION U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF STATE PROGRAMS OFFICE OF STATE PROGRAMS FAX: (301) 415-3502 NUMBER OF PAGES: 13 including this page l

DATE:

JUNE 9,1997 l

TO:

RADIATION CONTROL PROGRAM DIRECTORS IN l

AGREEMENT STATES, OHIO, OKLAHOMA, PENNSYLVANIA NRC REGIONAL STATE AGREEMENTS OFFICERS NRC REGIONAL STATE LIAISON OFFICERS FROM:

PAUL H. LOHAUS, DEPUTY DIRECTOR OFFICE OF STATE PROGRAMS l

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SUBJECT:

SP-97-040 GUIDELINES FOR PAYING FOR STATE TRAINING AND TRAVEL EXPENSES FOR COMMENT BY " JUNE 20,1997" VERIFICATION - 415-3340

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DATE TIME DESTINATION STATION PO.

DURATION MODE RESULT 32465 6-09 18:15 610 337 5324 13 O*06'10" NORt1.E OK 32466 18:21 404 562 4955 13 O*O6'13" NORM.E OK 32467 18:28 7085151096 13 O*12'06" NORM.E OK 32468 18:40 817 860 8122 13 O*06'30" NORM.E OK 32469 18:47 5109750381 13 O*06'23" NORM.E OK 32470 18:54 334 613 5387 13 O'11'26" NORM.E OK 32471 19:05 6024370705 13 O*08'18*

NORMAL OK 32472 19:14 50166124G8 13 O*06'58" tORM.E OK 32473 19:21 0111916 3243610 13 O'06'07" tORM.E OK 32474 19:28 303 343 3697 13 O'06'39" tORM.E OK fl N 'CN YO 32475 19:35 904 487 0435 2

O'02'04" NORM.E UO10 32476 19:37 404 362 2653 13 O*06'11" NORM.E OK 32477 19:44 217 524 4724 13 O*06'12" tORM.E OK 32478 19:50 515 242 6284 13 O*06'11" tORM.E OK 32479 19:57 913 296 0984 13 O*06'50" tORM.E OK 502 564 6533 h b ~ O b %d 32480 20:04

/

3 O'02'21" NORM.E UO10 32481 20:07 LOUISIANA 13 O*07'06" NORM.E OK 32482 20:14 MAINE 13 O'08'12*

NORt1AL OK 32483 20:23 410 631 3198 13 O*06'38" NORMAL OK 32484 20:30 601+354+6167 13 O*08'38" NORMAL OK 32485 20:38 402 471 9449 13 O'06'07" NORM.E OK 32486 20:45 7026875751 13 O*08'40" NORMAL OK 32487 20:54 603 225 2325 13 O*06'17*

NORM.E OK 32488 21:01 5058271544 13 O'08'10" NORMAL OK 32489 21:09 518 458 6434 13 0"06'13" NORM.E OK 304 2*52*40" l

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DATE TIME DESTINATION STATION PG, DURATION MODE RESLt T 32490 6-09 21:16 919 571 4148 13 O'06'10" NORM.E OK 32491 21:22 701 328 5200 13 O'06*04" NORM.E OK 32492 21:29 503 731 4081 13 O'06*04" NORM.E OK 32493 21:35 401 277 2456 13 O*11'14" NORt1.E OK 32494 21:47 8037371412 13 O'06'13" NORt1. E OK 32495 21:53 615 532 7938 13 O*06'10" NORt1.E OK 32496 22:00 5128346708 13 O'06'44" NORt1. E OK 32497 22:07 801 533 4097 13 O'07*10" NORM.E OK 32498 22:14 360 753 1496 13 O'06*04" NORM.E OK 32499 22:21 518 457 2225 13 O*06'10' NORM.E OK 32500 22:27 518 457 5545 13 O'06'50" NORt1.E OK 32501 22:35 NEW YORK CITY 13 O'06'13" NORM.E OK 32502 22:41 502 227 7862 13 O'06'47*

NORMAL OK 32503 22:48 AECB (613) 995-5086 13 O'06'35" NORMAL OK 32504 22:55 WASHINGTON DC 13 O'06'05" NORM.E OK 32505 23:02 7996726 13 O'06*07" NORM.E OK 32506 23:08 217 782 1328 13 O*07*10" NORM.E OK 32507 23:16 512 239 6362 13 O*06'14" NORM.E OK 32508 23:22 4024714840 13 O*08'06" NORMAL OK 32509 23:31 912 262 3143 13 O*06'42" NORMAL OK 260 2'14'52" l

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06-10-1997(TUE> 08:34 C

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DATE TIME DESTINATION STATION PO.

DURATION MODE RESULT 32514 6-10 08:28 904 487 0435 13 O'06'38" NORM.E OK hg 13 O'06'38" I

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,,_10-1997<Tue> 06:13 l

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TRANSMIT 3

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DATE Tlt1E DESTINATION STATION PG.

DURATION MODE RESULT 32512 6-10 08:07 502 564 6533 13 O'06*17" NORM.E OK

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TRANSMIT 3

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DATE tit 1E DESTINATION STATION PG.

DURATION t10DE RESULT 32463 6-09 15:19

NYSERDA, 13 O'07*11" NORt1AL OK

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< TRANSACTION REPORT >

,_,,_1,,,,,

1,,1,

[

BROAOCAST 3

NO.

DATE TIPE DESTINATION STATION PO.

DURATION MODE RESULT 32458 6-09 14:35 OHIO 13 O*06'09" NORM.E OK l

32459 14:43 405 271 8425 13 O*06'02" NORM.E OK 32460 14:49 6177272098

,f 13 O'06*58*

NORM E OK 32461 15:12 PENNSYLVANIA "C/_ P/jg O

UOOO 39 O'19'09" i

i

< TRANSACTION REPORT >

0s-10-1927<Tue> 07:57 C

TRANSMIT 3

NO.

DATE TIME DESTINATION STATION PO.

DURATION MODE RESULT 32511 6-10 07:50 PENNSYLVANIA 13 O*06'22' NORM.E OK

((p 13 O'06'22" 1

l i

1 l

!