ML20244D617

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Applicant Rebuttal Testimony 18 (School Protective Actions).* Testimony Addresses Issues Re Spmc Procedures for Implementing Protective Action Recommendations for Schools & Use During FEMA June 1988 Exercise.Related Correspondence
ML20244D617
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Site: Seabrook  NextEra Energy icon.png
Issue date: 04/18/1989
From: Callendrello A, Sinclair M
AIDIKOFF ASSOCIATES, INC., PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
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ML20244D592 List:
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OL, NUDOCS 8904240032
Download: ML20244D617 (75)


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UNITED STATES OF AMERICA M"

NUCLEAR REGULATORY CCMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of

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PUBLIC SERVICE COMPANY OF

)

Docket Nos. 50-443-OL j

NEW HAMPSHIRE, et al.

)

50-444-OL

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)

(Seabrook Station, Units 1 and 2)

)

(Off-site Emergency

)

Planning Issues)

)

APPLICANTS' REBUTTAL TESTIMONY NO. 18 (SCHOOL PROTECTIVE ACTIONS)

Panel Members:

Anthony M.

Callendrello, Manager, Emergency Planning Licensing, New Hampshire Yankee Michael C.

Sinclair, Emergency Planning Specialist, Aidikoff Associates l

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i 8904240032 890418 PDR ADOCK 05000443?

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TABLE OF CONTENTS I.

INTRODUCTION 1

j II.

AVAILABILITY OF LOCAL BUSES 1-i III. ORO INTERFACE WITH SCHOOLS 3

IV.

PROTECTIVE ACTION RECOMMENDATIONS FOR SCHOOLS 9

V.

-SCHOOL EBS MESSAGES 15 VI.

BUS DISPATCH AND ESTIMATED TIME OF ARRIVAL 18 VII. DEMONSTRATION OF SCHOOL ~ BUS ROUTES 23 Attachment A:

NHY Records of Conversation with Administrative Assistant to Amesbury Superintendent of Schools Dated 11/17/88; with i

Newburyport Public School District Superintendent, 10/11/88; with Triton Regional School District Assistant Superintendent, 11/18/88 Attachment B:

FEMA Guidance Memorandum EX-3, Amendment Dated 3/7/88,.Page 4 Attachment C:

NHY Post-Exercise Records of Conversation With the Three Day Care Centers That Participated in the Exercise l

Attachment D:

Exercise Log, Amesbury School Liaison, Pages 1 to 9 Attachment E:

Controller Log, Joe Bisson, Page 4 Attachment F:

Controller Log, T.

Cotter, Pages 13, 15 Attachment G:

ORO EBS Message #3 Attachment H:

Exercise Log, Newburyport School Liaison, l

Page 6 Attachment I:

ORO News Release #6 _ _ _ _ _ _ _ _ _ _ _ _ _ _

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Attachment J:

Controller Log, C. MacDonald, Pages 1, 2,

3, 4

Attachment K:

Controller Log, Don Miller (2 Pages)

Attachment L:

Exercise Log, Salisbury School Liaison, Page 1 Attachment M:

NHY ORO Message Form - BCL-5, 1 Page; Controller Log, Amesbury. School Liaison, 1 Page l

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I.

INTRODUCTION

]

l This testimony addresses issues pertaining to seabrook

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)

Plan for Massachusetts Communities (SPMC) procedures for j

implementing protective action recommendations for schools and, in particular, their use during the FEMA Graded Exercise, June 1988,'as raised in Joint Intervenor (JI)

Contention 45 (Bases B, E, H, I, M, N,

& 0); MAG EX-9 (Basis B) ; MAG EX-10; MAG EX-11 (Bases B(2) and B(4) and D); and TOH/NECNP EX-2.

Issues raised in these bases which have been addressed in previously filed testimony before this Board are incorporated by reference as follows:

JI-45B, see Applicants' Rebuttal Testimony No. 6 (Protective Actions for Particular Populations) at page 27; JI-45E, page 29 ibid, JI-l l

45H, I,

pages 28, 37-42 ibid, JI-45M, pnge 42 ibid.

II.

AVAILABILITY OF LOCAL BUSES i

The SPMC provides that schools which can meet their own evacuation transportation needs from available resources may do so (SPMC, page 3.6-9), and that the Offsite Response Organization (ORO) resources will supplement those already l

available at the time of an emergency (IP 2.7, Section t

l

5. 3. 3. A and B).

However, the SPMC makes provisions to meet 100 percent of the needs of schools to support an evacuation l

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1 in the event that local transportation resources are unavailable.

In order to determine the extent to which ORO resources are required and to maximize the utilization of all available resourcos, at the ALERT classification school officials are contacted by the School Liaisons and asked to estimate their transportation needs.

Contracted school transportation arrangements are generally handled through the School District Superintendent's office which would contact the district's regular contracted bus provider to determine the availability of resources.

School officials should be in a position to respond with some information regarding their regularly contracted buses.

For example, the Triton Regional District has, as a

' stipulation in its contract with its bus provider, that when requested, the bus provider will respond within one hour.

The Newburyport Superintendent's Office has indicated that when requested, all contracted buses and drivers respond within one hour of an emergency call.

See Attachment A hereto.

Although provision of information such as the number of buses locally available is helpful to the ORO in providing transportation support, the ORO does not rely on this f

i I

information nor is it crucial to the effective implementation of an evacuation.

If information regarding contracted bus t

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availability is unavailable prior to an' evacuation recommendation, the ORO will utilize ~the pre-determined

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" default" values in Appendix M reflecting 100 percent of l

school enrollments as the basis for dispatching ORO buses to each school.

III. ORO INTERFACE WITH SCHOOLS The method of evaluating ORO's interface with schools during the Exercise was consistent with the FEMA Guidance Memorandum EX-3, Amendment dated 3/7/88 (page 4 provided as Attachment B hereto):

The Offsite response organization will demonstrate the capability "to interface with non-participating state and local government, but [this demonstration) does not include the use of stand-ins for the anticipated State and local responses While the controllers will not function as stand-ins, they will provide appropriate opportunities for the players to demonstrate the knowledge and interface capabilities of utility offsite response organization personnel."

In accordance with this guidance, the controllers did not act as if they were school personnel, but only ensured that the ORO Liaisons had l

adequate understanding of their liaison functions to enable j

them to implement their procedures.

The interaction between the schools and the ORO Liaisons was demonstrated through contact with a New Hampshire Yankee j

(NHY) telephone control cell where controllers received 1 1

t 4

emergency information and provided school and day care center scenario data.

The content of these phone conversations was described by ORO School Liaison, John Giarrusso, during his deposition on March 14, 1989 at 38.

"I informed them of my name and position on the ORO; explained to them the situation at Seabrook and that I was calling to verify their number of students, which I had in my Appendix M, whether that was correct, that's what they had enrolled that day, students, faculty, number of buses needed to service that school.

1 I asked them if they know about our EBS stations.

I told them what they were.

I gave them my phone number, again my name, and if they has any questions they could call be back and I would keep them informed of any change in anything at Seabrook and also asked along the time of their school closing.

To the best of my recollection,that's what I did."

The Controllers often asked questions and provided non-scenario information concerning school dismissal times and the progress of the evacuation.

The School Liaisons relayed this information, such as dismissal of the Merrimac School District, to the Emergency Operations Center (EOC) where it was factored into the emergency response.

A review of the exercise records shows that the phone calls to the schools lasted from 3 to 5 minutes depending on information to be ccnveyed.

The initial phone call, as described above, is made at the ALERT emergency classification when the school phones would not be busy due to parents calling about the Seabrook emergency.

Subsequent l

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updates parallel information directly available from Emergency Broadcast System (EBS).

In order to expedite school notification, the School Liaison procedure was revised in Amendment 6.

This revision which directs that the Liaison's assist each other in making phone calls (SPMC, IP 1.9, Section 5.2.4), addresses the issue raised by the Interveners which allege that the phone calls cannot be made in a timely manner.

During the Exercise the Amesbury School Liaison needed to make 38 calls, while four of the Liaisons need to make only 11 or less.

The revised procedure, using the updated school listing will have i

six Liaisons making 112 calls which should take 60 to 90 l

minutes.

Whether the Liaisons have time to complete their calls will depend primarily on how fast the emergency escalates and requires updated information to be provided.

Again, if the School Liaisons are unable to reach a school for whatever reason, the default values for transportation resources will be used as the basis for the response.

During the Exercise the School Liaisons performed their interface function as detailed in their procedures.

As discussed below, three real day care centers participated in the Exercise.

Since each was in a different town, and-two ORO shifts were exercised, six School Liaisons spoke to real day care operators.

In post Exercise communications all l

three day care operators felt the notifications and I

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i information received during the Exercise went well.

See Attachment C hereto.

School Liaisons continued to make calls until they completed their calls or the Controller directed an end to the calls.

See Exercise Scenario, Applicants' Exhibit 61, at 3.2.9)

Generally the calling period was limited to approximately one hour each time calls were required in response to the scenario.

During the Spring of 1988 all Massachusetts Emergency Planning Zone (EPZ) schools and day care centers were contacted requesting their participants in the upcoming Exercise.

See Applicants Rebuttal Testimony No. 23, Scope.

One school and three day care centers agreed to participate in the Seabrook Exercise.

This participation was to consist l

of receiving phone calls from ORO players during the Exercise and interviewing with FEMA evaluators the.following day.

The 3

three day care centers participated as scheduled, see Attachment C hereto, but the school, Seventh Day Adventist, was not in session because the exercise date was rescheduled from May to June 28, 1988.

The Interveners allege that the Amesbury School Liaison called the Seventh Day Adventist school at 11:17 a.m. and, when the phone was unanswered, the school was not recalled until 1:50 p.m.

The Liaisons's log, however, details that he called the school at 11:17, continued with other calls and then unsuccessfully attempted to recontact them at 11:40.. -.

__.._____._______________..__._______________________________________J

i See Attachment D hereto.

He notified the School Coordinator that he was unable to make contact with the school at this time.

After the GENERAL EMERGENCY was declared, the Liaison attempted to recontact the Seventh Day Adventist at 1:50 p.m.

i and again there was no answer.

The Liaison continued to make calls to inform the schools about the GENERAL EMERGENCY until 2:24 p.m. when he restarted his calls to inform the schools of the Protective Action Recommendation (PAR).

At 3:16 p.m.

the Controller told him that all his calls were complete.

l This inability to contact a school will result in the dispatch of buses based upon default values in Appendix M and would not affect the availability of transportation resources for the school.

The Interveners allege (MAG EX-10D) that the i

communications with the Horace Mann School were illogical and confused.

The following is a list of relevant entries in the log of the Amesbury School Liaison (Attachnient D hereto) :

11:38 Called Horace Mann School - transportation 0" -

Close 2:45, they have 102 students borrding.

1:25 Called Horace Mann School - informed of SAE.

2:07 Horace Mann School - Informed of G.E.

2:24 School children are to be held at school, hold their buses if possible and supply route guides.

l 2:54 Horace Mann School - Hold students and buses, need route guides.

Students were getting on buses.

I told them to unload and get into schools due to a release going out to sea. l

i 3:17 Route Guides arrive at 3:55,.we will be using our buses.

I must call schools and tell them i

to release buses.

3r33 Horace Mann School, told buses will arrive at 3:55, release their buses.

The above log entries detail a conscientious effort to keep the' Horace Mann School informed of emergency events.

The Interveners allege that the Amesbury School Liaison I

should have made congregate care arrangements for the Horace I

Mann " boarders".

The identification of these students as boarders was a mistake by the Controllers, these students attend an afternoon school session.

In any case, the provision for extended relocation of any students would take place at the School Host Facility where any students not picked up by parents or guardians would be transferred to

' Congregate Care.

This is not a responsibility of the School

.I Liaisons.

i The 2:54 p.m. entry is a summary of an extended conversation.

During this conversation the School Liaison j

informed the school official that the buses needed to wait

{

Y for the ORO Route Guide to take them to the Reception Center and that the students should wait inside the school because a radiological release had already begun.

Subsequently ORO was informed by Controllers that only the ORO buses were to be used to support the evacuation regardless of whether the 1

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schools had indicated the availability of their own transportation resources.

IV.

PROTECTIVE ACTION RECOMMENDATIONS FOR SCHOOLS The exercise activity relating to schools was intended' to demonstrate the ability of the ORO to make appropriate protective action decisions (Objective 11), to alert and inform the schools and the public (Objectives 12 and 13), and to implement appropriate protective actions for school children (Objective 19).

I 1

In each instance, the FEMA evaluators concluded that the overall objectives were met.

With regard to.the ORO's ability to make appropriate protective action decisions, the FEMA Exercise Report, Applicants' Exhibit 43F (hereinafter l

Exercise Report), states that the "NHY ORO EOC Staff performed in a very commendable and satisfactory manner."

(Exercise Report at page 221 of 428.)

A chronological review of the Exercise indicates that after a SITE AREA EMERGENCY (SAE) was declared at 11:46 a.m.,

the State of New Hampshire (NH), at 11:52 a.m.,

directed that NH EPZ school children be retained in school buildings until 5:00 p.m. pending further developments.

This precautionary decision, invoked under the discretionary authority section of the NHRERP, Vol.

1, Sec.

2.6, was made by decision-makers present within the NH EOC in Concord.

It was based on 'the time of day, plant conditions, and meteorological data which

i I

indicated a potential impact on NH EPZ communities in the immediate vicinity of Seabrook should a radiological release The intent of this move was to forestall the routine occur.

i dismissal of students and keep the students intact as a group if evacuation became necessary.

The specifics of this process relating to the NH EPZ are detailed in Applicants' Rebuttal Testimony No. 25 (New Hampshire Exercise Performance).

Concurrent with the actions being taken by the State of 4

New Hampshire, the NHY ORO was in the process of implementing the appropriate sections of the SPMC for the Massachusetts EPZ communities, cognizant of the SPMC requirement that concurrence to implement any protective actions must be obtained from the Commonwealth.

Schools were notified by the School Coordinator and School Liaisons of the ALERT declaration and subsequently of the SAE declarations.

Activities continued to ready the ORO for a response should it become necessary, including the mobilization of buses and drivers, and ORO Route Guides.

Under the SPMC the mobilization of ORO evacuation support resources occurs automatically in accordance with the emergency classification.

The speed with which the mobilization takes place is independent of any actions dictated by the ORO EOC.

The actual deployment of those resources to specific locations is a function of the PARS.,

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After the SAE declaration at 11:46 a.m., ORO held a noon ORO status briefing.

The ORO Radiological Health Advisor, as prescribed in his procedures, indicated that consideration should be given to precautionary actions fer schools (SPMC, 1

IP 2.5, Section 5.2.1) based upon plant conditions, wind j

direction and availability of transportation resources.

Since available data on plant conditions and meteorological information indicated there was no threat to the Massachusetts EPZ communities, i.e.,

there had been no release, wind speeds were low and winds were from the West blowing out to sea, there was no need for precautionary actions for schools and the decision was made to revisit the issue later.' See Attachment E hereto.

The subject of schools was addressed during the next ORO status meeting at 12:45 p.m.

At this time it was decided to convene a subsequent meeting to discuss schools upon completion of the status briefing.

See Attachment F hereto.

l The subsequent ORO meeting at 1:25 p.m initiated a discussion of school PARS for Amesbury and Salisbury, but again concluded there was no need for protective actions since there was no indication of a radiological release.

The ORO was told that schools would be closing between 2:30-3:00 p.m.,

and directed that the staff initiate discussions with the Commonwealth regarding any appropriate actions, such as i-

.y.

retaining _ students at the schocls.until ORO bus mobilization could be completed.

.The Intervenor's allege in MAG EX-11B(2) that upon declaration of the SAE at 71:05 a.m. early dismissal of schools would have been an appropriate PAR.

This assessment that protective actions were necessary at this time is inconsistent with the underlying basis of emergency planning and how it correlates with the emergency classification system.

The four emergency classifications identified by the NRC in NUREG-0654, Appendix 1 were developed in order to provide offsite authorities with an assessment of the potential risk to the public health and safety.

The class description for a SAE states that "Any releases (are) not expected to exceed EPA Protective Action Guideline exposure levels except near

-site boundary."

(NUREG-0654, Appendix 1, page 1-12).

In addition, the actions described for State and/or local authorities do not call for protective actions except for possible sheltering within 2 miles of the plant (id. 1-12).

There is no basis to assume that because a SAE has been declared and associated mobilization of emergency response personnel is appropriate that protective actions for the general population are, or will become, necessary.

i The precautionary action of early dismissal has inherent I

problems associated with latch-key children, availability of q

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I transportation resources and notification of parents.

Thus, as concluded by FEMA in Guidance Memorandum EV-2:

"the unique aspects of a radiological emergency place limits on i

the use of early dismissal as a viable protective action particularly in heavily populated areas."

(EV-2, pg. 12.)

l In review of exercise events, however, Applicants note that the decision to keep children in school at normal dismissal time needs to be evaluated in a timely manner prior to the normal end of the school day.

Future revisions of the Plan will' include this guidance.

Notification of a GENERAL EMERGENCY was received at 1:40 p.m.

followed by notification of a radiological release at 1:53 p.m.

The Governor's Representative A, at 2:05 p.m.,

l authorized evacuation of Amesbury and Salisbury, with sheltering in the remaining towns and delayed dismissal of all EPZ schools except Merrimac, which was known to have i

dismissed school.

(Exercise Report at 60 of 428.)

The associated ORO EBS message #3, Attachment G hereto, was broadcast at 2:20 p.m.

The basis of this PAR is described in Applicants' Rebuttal Testimony No. 26 (PAR Made By NHY ORO During the Exercise).

The SPMC procedures have the schools take the same protective actions as the general population.

School dismissal was delayed in towns to await ORO Route i

Guides and evacuation buses in Amesbury and Salisbury and implement sheltering in the other towns.

The Exercise _

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4 scenario resulted in the ORO buses being mobilized 1

immediately upon arrival of the Route Guides at the bus yards.

Early evacuation using ORO resources at the SAE was not an available option.

[

It would have been inappropr.iate at that point to send students home when parents in Amesbury and Salisbury (and the general public) were being advised to evacuate.

The alternative was to leave them in the schools under continuing adult supervision.

In the towns that were sheltering, the dose reduction factor of school facilities is considered to be as good or better than the residences to which the 1

students would have been sent and there was no assurance that anyone was home in case an evacuation was subsequently recommended.

The protective action decision was relayed to the School Coordinator and, in turn, to the School Liaisons (at 2:13 p.m.) and this information was relayed to the schools (Control Cell) by the School Liaisons beginning at approximately 2:15 p.m.

When the notifications reached schools in Newburyport and Merrimac, Controllers advised the School Liaisons that students in all of the Merrimac schools and those at four of the six Newburyport school facilities had been dismissed and were enroute home.

See Attachment H hereto.

The remaining schools in the Massachusetts EpZ' towns were reached in time to avert the dismissals and direct that L___.-______.

s.-

ll the students be retained to either await ORO buses or implement sheltering.

V.

SCHOOL EBS MESSAGES Interveners allege in MAG EX-100, MAG EX-9B and TOH/NECNP EX-2 that ORO EBS Message and News Releases contain

?-

inaccurate and inconsistent information.

ORO EBS Message #3 issued at 2:20 p.m. is. identical to ORO News Release #7 issued at 3:12 p.m.

Interveners assert-that a contradiction exists in page 2 of these messages which states that schoo'^ in Amesbury and Salisbury "are being evacuated" followed by language on the last page that Amesbury and Salisbury students "are currently being safely maintained,at school, where they will be-kept until it is determined that they can be safely moved."

See Attachment G hereto.

While it is acknowledged that there is some lack of precision in the quoted language of the EBS message, the information was adequate to inform parents that students were being protected at school until they could be evacuated.

In the case of the Newburyport schools, the EBS message indicated that Newburyport students were being maintained at school'when, in fact, four schools in that community had earlier dismissed students for the day (simulated).

At the time the EBS message was being released, ORO was unaware that school dismissals had begun in Newburyport.

The Exercise Report (Objective #13, Narrative Summary, pages 223-224 of

,r

.4 t-428) recognizes this inconsistency and attributes it:to

" disconnects between the NHY ORO staff and the Control Cells."

Specifically, a Controller independently. decided to create exercise data concerning the status of Newburyport schools.

However, as detailed in the Exercise Report, page 223 of 428, when the ORO was informed of this inconsistency via a phone call to the Rumor Control personnel at'the Joint Telephone. Information Center (JTIC), the information proceeded through'the organization and correct information was' issued in a subsequent EBS message.

ORO News Release #6, Attachment I hereto, was issued at 3:00 p.m.

This short summary news release, issued after ORO EBS #3, provided confirming information on the protective actions recommended.

The message identified the PAR for the towns and informed the parents that school dismissal was to be delayed except for Merrimac schools which had dismissed their students at their normal dismissal time of 2:15 p.m.

This news release was followed up 12 minutes later by News Release #7 which as described above provided greater detail.

on the status of the schools.

l These discrepancies in the EBS messages and news l

f releases would not have caused adverse effects on the health and safety of the students in EPZ schools.

In Newburyport and Merrimac, where the public was sheltering, students would j

have arrived home to their sheltering parents.

In Amesbury..

-_______--_____..-x.

4 i

e and Salisbury, where residents were evacuating, the students were being sheltered awaiting ORO buses.

Parents would have proceeded to the school host facility to await the arrival of their children.

Retaining the students at schools ensured they would not be sent to homes where parents had evacuated.

The ORO Evacuation Support Coordinator advised the School Coordinator at 3:00 p.m. that schools should be advised to release students to parents who showed up to pick up students, but otherwise to retain them for evacuation by ORO buses.

(Exercise Report at 63 of 428.)

While concurrent EBS messages advised parents not to pick up children at schools, this direction was aimed at avoiding conflicts that might arise due to protective actions being taken when parents might be trying to retrieve their youngsters at the school.

The SPMC does not rely upon parents picking up their children in school or day care as a means of evacuating these facilities.

Therefore, directing the parents n2t to go to the schools or day care does not affect the ability to evacuate these children.

EBS Message #3 (Attachment G) states that school children being evacuated will go to the Reception Center for "their town".

The last sentence of the paragraph which was redacted for the Exercise is where information is provided on the name/ location of the school host facility where the school children will be taken, This information was redacted _ _ _ _ _ _ - _ _ _ _ _ _

e for the Exercise but would be made available in the EBS message during an actual emergency.

In addition to this information being stated in an EBS message, it may he found in the Public Information Calendar (Applicants' Exhibit 40, page 3).

In fact, the host facility (school) is stated-by.

name and a map with directions provided in the Public Information Calendar which has been distributed to the public since the Exercise.

VI.

BUS DISPATCH AND' ESTIMATED TIME OF ARRIVAL The ORO Bus Dispatcher proceeds to the bus yards at a SITE AREA EMERGENCY or higher classification.

When directed by the Bus Company Liaison, the Bus Dispatcher deploys buses for an evacuation.

The Bus Dispatcher then notifies the Bus Company Liaison "when the last' vehicle has been dispatched and the estimated time of arrival of buses sent to schools I

(SPMC, IP 2.10, Sec. 5.2.4).

The' Bus Company Liaison is instructed to notify the School Coordinator of the

" estimated time of arrival of buses dispatched to requesting schools."

(SPMC, IP 2.10, Sec. 5.1.5.C).

This process was successfully demonstrated during the FEMA Graded Exercise.

During the Exercise the Bus Company Liaison (BCL) initiated phone contacts with the bus companies at 9:57 a.m.

At 10:47 a.m. When the BCL completed his calls, he was provided with a resource listing by the controller, detailing location of available buses.

When the SAE was declared at -

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11:46 a.m.

the BCL contacted the Staging Area to have the Bus Dispatchers sent to the bus yards.

See 11:48 entry of Attachment J hereto.

He then contacted the bus yards to have the bus drivers called in.

ORO Route Guides, mobilized at the SAE, reported to the ORO Staging Area.

After determining the necessary Route Guide assignments at 1:00 p.m.,

the BCL was given Exercise Message 8.2 - 22.E which detailed the bus and Route Guide assignments to be used for the Exercise.

These scenario assignments were different from those specified in the Bus Company Liaison's procedure (SPMC, IP 2.10).

The SPMC minimizes the time for mobilizing school transportation support by utilizing the school's own buses when available and dispatching ORO buses from the bus yard that can provide buses to the schools soonest.

While the SPMC has adequate resources to evacuate all the schools, the use of the schools own resources ensures that ORO's need to provide supplemental buses will be minimized and can be provided from bus yards in close proximity to the EPZ.

Therefore the arrival of the buses would have been more timely than the Exercise demonstrated because the buses would have come from a closer bus yard and the school's own buses would have been used as available.

The initial protective action recommendation at 2:00 p.m. called for the evacuation of the towns of Amesbury and Salisbury.

However at 2:17 p.m.,

at the Controllers l

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1 direction, the BCL contacted the Bus Dispatchers at each yard and had the buses mobilized for all the Massachusetts EPZ towns.

See Attachment J hereto.

The actual evacuation recommendation for the remaining four tcwns (ERPA E) was not made till 3:50 p.m.

(Exercise Report at 65 of 428.)

The Route Guides upon arrival at the bus yard were briefed and grouped on to buses with the FEMA Controller.

The Route Guides then took turns demonstrating their capability to guide the buses to schools, special population facilities and on evacuation bus routes.

(Exercise Scenario i

Section 3.2.6-8).

As a result of both the out of sequence mobilization of buses for ERPA E and the grouping of Route Guides on the buses, only two buses for schools were mobilized in sequence Vith the exercise time line.

These two buses were one from Parent bus company to Seventh Day Adventist School in Amesbury and the second bus was from Big W bus company to Salisbury Memorial School in Salisbury.

A review of player and Controller logs indicate that the dispatch of these two buses proceeded as follows:

I a -

Seventh Day Salisbury Memorial j

Amesbury Salisburv

. Bus Dispatcher 2:17 2:17 notified to roll buses Route Guides 2:53 3:15 arrive at bus yard Bus departs bus yard 3:10 3:37 for school Bus Dispatcher 3:10 3:45 notifies BCL of bus dispatch BCL notifies 3:26 3:47 School Coordinator-and Evac. Sup. Coor, of ETA Estimated Time of 3:50 4:45 of Arrival (ETA)

Bus arrives at

'3:45 5:22 school j

The estimated time of arrival (ETA) for the Seventh Day Adventist school was accurate.

The bus traveling to the Salisbury Memorial School encountered road construction which j

delayed arrival by approximately 15 minutes.

See 1600 entry to Attachment K hereto.

Discounting this travel delay the

)

ETA underestimated the 90 minute trip time by approximately 20 minutes.

Given that the Bus Company Liaison was only estimating travel distances off a map and estimating bus speeds, the arrival time estimate was reasonable.

The ETA is provided to the schools so that they may make timely preparations for their children and staff to board the f i t

- ~ - - _ _ - _ _ _ _ - - - _ _ _ _ _ - _

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buses.

The school bus ETAs are not issued as part of the EBS message for the general public.

The ETAs provided in tne EBS message are for the initiation of the transit dependent bus runs in the towns so that general population evacuees will know when to leave their homes and walk to the bus routes.

The ETA was transmitted from the School Coordinator to j

the School Liaisons who quickly relayed it to the Amesbury and Salisbury school officials (Control Cell personnel).

Since the Control Cell personnel were not at the schools they did not have any information concerning the time the two buses actually arrived.

Any bus arrival information reported i

by the Control Cell was created.by the controllers.

The delays in bus arrivals alleged in Intervenor testimony is erroneously based upon simulated data and not on the actual arrival of real buses running in sequence with the exercise time line.

The Bus Company Liaison developed an ETA for the schools in the remaining 4 towns (ERPA E) after these-towns were recommended to evacuate at about 4:00 p.m.

His estimated time of arrival for all'the remaining towns was 5:15.

See Attachment J hereto.

This time however was only intended to maintain scenario progress since there were no longer any buses left at the yards to be run in exercise sequence.

There was no relationship between this estimated time and the actual arrival times of any buses.

As previously described, l o

_______A_._______._________.__________________.___________________._.

F this information was relayed quickly to the school officials by the School Liaisons.

The Bus Company Liaison did not revise the school ETAs.

The second shift Salisbury School Liaison at 4:25 provided' the schools with a revised ETA of 5:15 p.m.

See Attachment L hereto.

This updated time was based upon the misunderstanding that the 5:15 ETA referred to all the towns and not only to the four ERPA E towns.

A similar misunderstanding took place when the Bus Company Liaison indicated that the Amesbury evacuation routes would begin at 4:05 p.m..

This information was miscommunicated to the Amesbury School Liaison as a revised ETA for the Amesbury schools.

See Attachment M hereto.

This misunderstanding will be addressed in future U aining.

VII. DEMONSTRATION OF SCHOOL BUS ROUTES The Exercise utilized four buses to demonstrate routes to seven schools and three buses were utilized to run seven day care routes involving 45 aay care facilities.

Thus a total of 14 route guides on seven buses demonstrated their ability to reach a total of 52 facilities, not counting the runs made to Reception Centers.

(Exercise Report at 233 of i

428.)

In the saven school runs made, three minor problems arose.

One involved a five-minute delay caused when a bus driver took a wrong turn once outside of the EPZ while..

.f enroute to a Reception Center.

Another involved a 15-minute delay enroute from the bus yard to the school caused by road construction.

The third resulted from a deviation from the prescribed route made by.the bus driver enroute from the school to the Reception Center.

There were no other problems identified for the seven routes demonstrated.

During the seven day care facility routes demonstrated, two problems were encountered.

In one instance there was a twenty minute delay when a bus driver mistakenly turned onto a dead end street.

(Exercise Report at 233 of 428.).The second incident involved the failure to locate one of the 45 day care centers due to a map inaccuracy.

Overall, there were 5 problems encountered on runs to 52 facilities.

These discrepancies and recommended corrective actions were noted by FEMA (Exercise Report at 233-234 of 428), and NHY has committed to implement corrective actions (Exercise Report at 290 of 428).

The problems identified will be addressed by upgrading maps to ensure clarity and accuracy and in NHY's ongoing training program for ORO and i

support personnel.

l a.

I i

ATTACHMENT A (NHY Records of Conversation with Administrative Assistant to Amesbury Superintendent of Schools Dated 11/17/88; with Newburyport Public School District Superintendent, 10/11/88; with Triton Regional School District Assistant Superintendent, 11/18/88) i

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CHRONOLOGICAL EVENT LOG I Positi:n; b ///;h $d- [Mw;.,d2 % Name: [ f p!Pr i ate: 4 ass;;ne: Fit;!' y: Am e r /hr-, i Time im/cm Activity 7'N h A d s&n A A w A M /Lt sa k D E a ztu ndu b lbX - at D Ak L. b ak & & a +- S U" 0h' WbY' /bY' + kYh \\/d 2 L.D n ~ & A L M a n \\ & % PA L z1 v a M 4 u d % % A & !,L M s.a M ~ w % & & 24D A nAJ %sL DAk.A xxJ/ \\ 2:ie RM4 - a A1L u-4 A R sn .v 1 (!R - JL z n L e's c. 3% %-n k -ad/bba A'# A. , i } w _-_ ' Attachment'D(Page8ofb E knenament 3 !? 3.2 Page

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/ pud m <0g*o,,, %. Namt* 3 ate: /, k i ft' Ass 1gnec Fac1! tty: I.S.,, f, Time am/cm { Activity i ~ IA1,mL Mjh Mc h J 3.47 2a Lsh~+ % 4,.a a g \\ 0 ) h e & f L J 7,'= y C n.

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Title:

0/2471.4.20

__________A_.__.____------

ATTACHMENT F (Controller Log, T.

Cotter, Pages 13, 15) i 1

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~Attachmsnt'F (Pega 1 of-2) i..

FORM 9.0

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SEABROOK STATION ENERGENCY PREPAREDNESS DRILL / EXERCISE CONTROLLER OBSERVATION SHEET (continued)

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'Attachmsnt F (Pcgs.2 of 2) l FORM 9.0 J."

SEABROOX STATION EMERGENCY PREPAREDNESS DRILL / EXERCISE CONTROLLER OBSERVATION SHEET (continued)

Evaluator Name:

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0-C Ce.i lu//A D/2471.4.20

ATTACHMENT G (ORO EBS Message #3) i

/ b h achment G (Page 1 of 4) 6 Page 1 of 4 i

GDERAL DEGENCY MESSAGE (EVAC 11ATICH AND SHELTERDG-SEASCHAL CI.OSURE OF BEACHES AND WTTnLTTE REFUGE) 1.

('(RELEASE OF-RADIQACnVE MATEKIAL) l f

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oate %=cie Released *****8 88 l

s Time > =m h Released k*****

2d fN 3

Relaaad by:

NHY OffsitetResponse Dir G E I

A GDERAL EMERGDCY was declared at ******p//

/.* -32 today at Seabrook Nuclear Power Station. A GDERAL DEGDCY means that events are in p.ug.c= s that ccx11d i

result in some significant release of radioactive mar.erials with releases expected to go beyond levels set by the United States Env:L.u mmii.al Protection Agency outside the Seabrook Station site boundary.

P6PM A release of radioactive material into the air occurred at ******.

'Ibe New Fa91_m Yankee Offsite Response Organization has been activated and is rc=5 paling to the problem. Macurnusetts gove.m.=d. officials have been notified.

'Ihe Governor of Masurtusetts se > -.a-ais the following:

Tmmediate evacuation is r" - " led far people in salichrry and Am=hw.

For Am=hW, the Reception Center is located at the Massachusetts Electric Facility at 1101 Turnpike Street in North Andover.

For alistury, the c

Reception Center is at the Maturhusetts Electric Facility at 44 River Street in Beverly.

?! 2-

'Ibe United States Coast Guard has been requested to enforce a ****** mile safety zcrut in the ocean waters near Seabrook Station. All offshore boaters near the plant are advised to relo:: ate or dock in waters further than ******

miles frcan the plant.

f/pg -

Fm= css at hameh and cark aran = fmn Ra14chtry to Plum Tm1and, irrliviirrr the Piuim-River National Wildlife Refum shoulel leave thew:a arman i nnmai ae 1y_.

'Ihere is a good rrsteihility for this -p.-,/ to prrrhr= a ud.oainating accident. It is ed usgly rammmanded that as a precaution, [=.auci leaving the towns told to evacuate go to their designated receptian centers for monitoring. -

{

/ Q tachmant G (Paga 2 of 4)

Page 2 of 4 GDGRAL DERENCY HESSAGE (EVACUATICH AND SHELTERING:

SDSONAL NMAE OF BEAOIES AND WTTnLTTI REFtJGE)

. (P2: LEASE OF RADIQACITVE MAITRIAL)

(cont.imund)

Services offered at the Reception Centers and remmanded for all evacuses include: merlitor2ng for cmtamination; d-uuuination if par== mag; informaticx1 and ma==arye cantars; and referral to ocsigregata care contars.

Persons in the rm=ndties directed to evacuata are advised to take the most cxalvenient roads south to main routes - Rauta 1, Rauta 1A, Interirtates-95

_or 495 - and travel south in the direction of the Reception Centars.

(TrafficguiceswillassistyoTu j

All schools within the ocasuunities directed to evacuata are baixxy evacuated to the designated Raceptim Centars for the community in which they are located. Parents should not drive to school to meet their children adace schools are now being evacuated and children are being taken safely by tus directly to their Receptical Centers. School children will than be sent to

'Ihe Hast Facility in A where they may be picked up.

I If you have been advised to evacuate but do not have your own w.--r wation and cannot get a ride frcan a neighbor or someone else, buses will travel along main emergency rautas to pick you up and take you to a Reception Centar. Wait for an announcement stating what time buses will begin traveling these c v cy routes in your cxamounity. For more information on the bus and evacuaticzi routas, look up the emergency information brochures about Seabrook Station which were mailed to you.

If you have a bedridden, handicapped or other person in your hczna who needs f

special evacuation help and who has not made previous arrangements with New Hampshire Yankee, please call' the New Hangshire Yankee Offsite Response F - v= cy Operations Centar at 555-1234. If you have already registered, there is no need to call now; help will soon be on its way.

All perscris in the area to be evacuated are urged to be good nei@au.. and help one another by sharing rides and helping others with problems.

If you know of any naith =1s or cc ^, 6. with language or hearing problems, please check on than to be sury they have been informed of the emergency and urd.=ued what they should do.

Before you leave your hczna or workplace,!make sure you have put out all fires and closed fir = plana riampars. Lock all doces when you leave. Take blankats agd pillows with you for your own use arx1 any medicines which you regularly take. Pack enough clothing for several days. If you are at Watk outside the evacuation area, but live inside it, you may return home to m14=h these chores and collect family members or ranaamary helmgings.

__,______i_________---------

a z

tachment G (Pago 3 of 4)

Page 3 of 4 GDEPAL EMERGENCY MESSAGE (EVACIATICE AND SHELTERDC SEASONAL CI.OSURE OF BEACHES AND WrTntTTE REEUGE)

(RELEASE OF RADIOACTIVE MATERIAL).

(ocritinued)

People living in the ernmanities of Meiw/ Newhnv/ West Newhwv/

Newburyport will be safer if they SHELTER IN PIACE imediately. 'Ihis means I

to remain indoors. Staying indoces will provida you with irud protection fra radioactive material released frcan Seabrook Station. 'Ib get

.j the greatest benefit from protection providad by shaltarang, you should taka the following actions:

o Sheltar indoors.

Make sure all windows and doors are closed tightly.

o If your are in your car, close all windows and vents while you travel o

to your destination.

Turn off all fans, heating er air conditioning systems if they brirg in o

outside air.

o Take a radio with you and nove to the rocan with fewest windows and l

doors.

Keep all members of your household indcors and stay tuned to your i

o local Ew f Br=4r-a=t System radio station.

c o

Roma.1.n indoors until told by local or state officials that it is safe l

to go outsida, or until further protactive actions are ra'rmnaridad.

I Schools, hospitals and other institutions in the oczeunities advised to shaltar are taking similar shaltaring actions. Officials have instructions for protecting the children or other perscris in their care until shaltaring is no longer n -==vy.

Parents and relatives are advised DE.t; to call the schools or other institution, nor to drive to the schools to attempt to pick up their children. Cmmunity safety will be battar protected if the adicols are permitted to conduct sheltering activities over the next several hours.

According to Stata officials, farmers and dairy operators in the cramunities of sm14 =hwv. ka==hwv. Marr4

. N=*=wv. West F ' "v, and Newburymrt, should:

Move all milk-producing livestock inside a barn or othcr shaltar.

Provide the animals with stcred fM and water and reduce sources of cutside air into their biildi_rgs. -

Move r=*=4da feed supplies indoces or cover them, if possible.

Store back-up suglies of water inside bi41 dings and cover outdoor walls, rainbarrels, tanks or other sources of collected water.

Please do not use the pbcria W in case of p u..crial emergency.

If you are at hcmia, look up the annual emergency information mailed to you.

If you are shaltaring at your udR*hla6m er other public hiilding, check the local **1ar*me book for additicrial information. 'Ihis information could be useful in ure.-.11ng future messages. -

{A chment G (Pago 4 of 4)

GDIERAL IMERGENCY MESSAGE (E. ACLL*' ION AND SHELTERDiG: Page 4 V

SEASONAL (WME OF BEACHES AND hrTnT.TTE REFTJGE (gRELEASE OF RADIOACTIVE MATERIAL)

(contmued)

If you are sheltermg at your wrkplace or other public local telephone took'for additional information.

,, check the.

useful in understanding future ratages.

This information c6uld be' Parents with children attending school within Newtury West Newbury and Newburvtrrt are advised that their children are currently being safely maintained at school, where they will be kept until is deterrined that they can be safely noved.

~v 2.is message acplies to all public, private and parochial schools arn preschool facilities within the affected area. To avoid confusion, p56.. h are urged Dgg to attempt to pick up their ellildren at schools within the affected area.

Ib repeat:

Seabrook Station has declared a General E=yency ccMition This m o<'e will be repeated every fifteen minutes or until new inferration is available.

official information.

Keep tuned to this ESS station for the latest If you are in any of the New Hammhire eastern Rockingham County ecmmunities, you should tune to a local radio station in New HamrrJ11re for news about your ccmmunity.

t 1

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ATTACHMENT H (Exercis.e Log, Newburyport School Liaison, Page 6) i i

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i Attachmsnt H (Pago 1 of 1)

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CHRONOLOGICAL EVENT LOG 1

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ATTACHMENT I (ORO News Release #6) 1 l

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.c Attachmnnt I (Paga 1 of 2)

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_.NTC NEWS RELEASE O

Massachusetts Offsite Resoonse Organization of New Hamosnire Yankee "IIIS IS A DRIII

'IHIS IS A CP"L

'ITES S A CRILL Release i 25 GDEPAL DERGENCY C:UIR;w1E Aci' IONS Pace 1 of 2

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-J NEh*INGICN, N.H. - 6/28/88 - At 2:05 c.n., New Hamosnire Yankee's offsite Response Organization (NHY CRO), urrier authority of the Governcr of Massachusetts, recommended that residents in the towns of' 91iehr/ and Aww/ be advised to evacuate due to the General Energency at the Seabrock Station Nuclear Pcwer Plant. Residents in the tcans of Merrirac, Neatury, West Neatury ard Neaturyport are advised to take shelter until advised bf 1ccal Ebercency Broadcast System radio statiers that instructions' nave c 2nced.

n addition, sencol dismissals vil1~be delayed in the tcans of Salis:urf, Anesorf, Neaturmf, West Heatury, ardsNeaturyport. Merrirac sencois sill d:.smiss at their ncrral dis =.tssal tira of 2r15 p.m.

~here have been releases of radioactive raterial frem the plant.

Inergency notificaticri sirens in the tcans of Salistury and kess"y /

Merr;.rac, Neatury, best.Neabury, Neaturym were sourded at 2:17 p.m.

1 Residents in Amh_q can evacuate to the receptien center at the Massacnusects Elev ic CW 1101 'n.:rnpike Road (Route 114), North udover, P.a.ss.

Residents in Salisburf can evacuate to the reception center at t".e Massachusetts. Electric C-W, 44 River Street,. Severly, Far,s.

Residents.are advised to take any-telormnas wnichethey would need to remain away frcm hcne fcr a fes days, incitrnna extra clothing, pe.M

i. ems and medical ite:s. 'Ihey should keeo their car ' radio tuned to an Emergency Brme% Syste!!r StatiCn.

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a.:7 Upon registration at the reception centers, if n-=,r, residents can travel to one of severaLL.uwie care facilities in Massachusetts if they havenootherplacetoseek(shelter.g Pets or farm arumin should be sheltered andj.left at home>with encuch feed.and water for several days.

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.s Residents who.have no mbans of L. arm,ation will ha evacuated by buses %hich. Vill be. arriving in their towns $

For the ilatest$nformatica, Mm residents should listen to their 1ccal E=.yury Broadcht System radio stations: WLYMM (92.5) arxi WHAV-AM (1490).

Accc @ to Peter Stroup, offsite Response Directcr, the re u.-24ation was rade due to the General EEs:u.gency at the Seab:tek Station Nuclear Power Plant, 'ahich was declared at 1:32 p.m. (

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NEV/$ lie [GX$E Massachusetts Offsite Response Organization of New Hamoshire Yankee Page 2 cf 2 A General E ercency is the hichest enercency classification trat applies to nuclear pcwer plants. This erercency classification involves an i

actual er irritnent st scantial failure of plant functions needed for the protection of 2a puclic.

NHY ORO enercency Annel are rescending to sucport this sheltering rew.a.friatien. NHY CR0 A nnel are staffin the Energency Operations Facility in Newingten, N.H., reception centers (, grWgate care centers and other erercencf facilities in P-nusetts.

j Tc address reers and questiens, toll-free nt=cers have been established fer Massachusetts residents. ?.ese snould be usea"to check questi nacle iricr:= len aceut t".e enercency.

l Tc receive irderacien, Massachusetts residents can call 1-800-111-2222.

For recorded i-icrracien en statien conditiens eniv, residents can call 1-603-111-2111.

For recorded iricrration c=ncerning Ma5SF'2"lSettS, residents Can Call 1-617-111-2112.

Fer recorded iriccation ccncerning New hmi*e, residents can call 1-603-111-2113.

Ma+am cf:the reila with cuestiens en t".e New Harrsni*e Yankea NHY CPO can call 1-800-111-2223. Memeers of-the nedia are urged.tc ccme to the Media Center in Newincten, N.H.

THIS IS A DRIII*

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ATTACHMENT J (Controller Log, C. MacDonald, Pages 1, 2,

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FORM 9.0 SEABROCX STATION EhERGENCY ::F8AREONE15

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Attachmont J (Paga 2 of 4)

FORM 9.0 SEABROOX STATION EMERGENCY PREPARE 0 NESS DRILL / EXERCISE CCNTROLLER OBSERVATION SHEET (continuec)

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FORM 9.0 SEABROCX STATICH EMERGENCY PREPAREDNE33 ORILL/ EXERCISE CONTROLLER OBSERVATION SHEET (continuec)

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Attachmsnt J (Paga 4'of 4)

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SEABROOX STATION EMERGENCY PREPAREDNESS DRILL / EXERCISE CONTROLLER OBSERVATION SHEET (continuec)

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ATTACHMENT K (Controller Log, Don Miller - 2 Pages) l i

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1 FORM 9.0 SEABROOX STATION EhERGENCY PREPARE 0HESS DRILL / EXERCISE CONTROLLER OBSERVATION SH bog hILLEk Evaluater Name:

JC U.M Orill/Exercisa Cate: hf69 8f

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4 Orill/Exere se ittle: JMto (Vattr4~.

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CESERV!.TI:MS/ COMMENTS Page _ cf _

NOTE:

Chservaticas snould incluce tr.e proper and effective use cf proce ecutcment ace ;;ersonnel.

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FORM 9.0 SEABROOX STATION EMERGENCY FRE.:AREDHESS CRILL/ EXERCISE CONTROLLER 055ERYATION SHEET (continued)

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ATTACHMENT L (Exercise Log, Salisbury School Liaison, Page 1)

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Attachment L (Page 1 of 1)

Amenoment !

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Log, Amesbury School Liaison,-1 Page) l r

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e NHY ORO MESSAGE FORM No. A LL-Y NHY ORO Title t.ocation Name From:

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Distribution of copies:

1 copy to addressee 1 copy to facility leader 1 copy retained by communicator / originator i

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Attachment M (Pago 2 of 2)

Amenoment 5 IP 3.3 Page 8 Rev. 0 Attacament 1 Page 1 of 1 C4RON0 LOGICAL EVENT LOG Position:

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