ML20248G960

Testimony of Gw Sikich & J Paolillo on Behalf of Atty General Jm Shannon,Town of Hampton (Toh),New England Coalition on Nuclear Pollution (Necnp) & Seacoast Anti-Pollution League Re....* Related Correspondence

ML20248G960
Person / Time
Site:	Seabrook
Issue date:	04/10/1989
From:	Paolillo J, Sikich G HAMPTON, NH, MASSACHUSETTS, COMMONWEALTH OF, NEW ENGLAND COALITION ON NUCLEAR POLLUTION, SEACOAST ANTI-POLLUTION LEAGUE
To:
Shared Package
ML20248G923	List: ML20248G919 ML20248G925 ML20248G930 ML20248G934 ML20248G943 ML20248G946 ML20248G960 ML20248H161 ML20248H205 ML20248H267 ML20248H319 ML20248H661 ML20248H688
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OL, NUDOCS 8904140016
Download: ML20248G960 (187)

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1 30 COgAE.SFOWM C0tMEiim i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '89 APR 11 P5 :59 ATOMIC SAFETY AND LICENSING BOARD ,

gE6;6.! i Before the Administrative Juoges: - "

1 3

Ivan W. Smith, Chairman 0 Dr. Richard F. Cole Kenneth A. McCollom l l

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In the Matter of ) Docket Nos. 50-443-OL l

) 50-444-OL- {

i PUBLIC SERVICE COMPANY ) (Off-Site EP) .{

OF NEW HAMPSHIRE, _E _T _A L .

)

(Seabrook Station, Units 1 and 2) ) April 10, 1989- l

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TESTIMONY OF GEARY W. SIKICH AND i

' JOHN PAOLILLO ON BEHALF OF ATTOR1EY GENERAL '

JAMES M. SHANNON, TOWN OF HAMPTON, NEW ENGLAND COALITION ON NUCLEAR POLLUTION AND SEACOAST I ANTI-POLLUTION LEAGUE REGARDING TOH/NECNP EX 1(a) AND (b)

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l Department of the Attorney General Nuclear Safety Unit Public Protecton Bureau One Ashburton Place Boston, Massachusetts 02108 j (617) 727-2200 YSock @l@gf 0 enA

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UNITED STATES OF AMERICA' I NUCLEAR REGULATORY COMMISSION

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1 ATOMIC SAFETY AND LICENSING BOARD j I

Before the Administrative' Judges: l l

Ivan W. Smith, Chairman i Dr. Richard F. Cole l Kenneth A.'McCollom

)

l l 1

) l In the Matter of -) Docket Nos. 50-443-OL,

) 50-444-OL PUBLIC SERVICE COMPANY ) (Off-Site EP) j OF NEW HAMPSHIRE, EI AL. ).

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(Seabrook Station, Units 1 and 2)- ) April 10,.1989

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TESTIMONY OF GEARY W. SIKICH AND JOHN PAOLILLO ON BEHALF OF ATTORNEY GENERAL JAMES M. SHANNON, TOWN OF HAMPTON, NEW ENGLAND COALITION ON NUCLEAR POLLUTION AND SEACOAST ANTI-POLLUTION LEAGUE REGARDING TOH/NECNP EX 1(a) AND (b)

PROCEEDINGS Q.1. Please state your name, occupation and experience.

(Sikich) My name is Geary W.. Sikich. I am the managing director for Emergency and Environmental Advisory Services for the firm of Laventhol and Horwath. I am responsible for their consultingLservices with'regards to emergency ~ advisory' services and environmental advisory services.

(Paolillo) My name is John Paolillo. I am an investigator for the Massachusetts Attorney General's office.

O Q.2. Please summarize your testimony. j A.2. (Sikich) I will testify as an expertt witness in support of Contention TOH/NECNP EX l(a) and (b). I will opine that the scope of the June 28-29, 1988 pre-license. Exercise of the New Hampshire Radiological Emergency Response Plan (Plan ~or NHRERP) was so limited'that it could not and did not yield valid or meaningful'results.regarding.the capability to l

implement the' plan,' procedures, or protective actions involving j i

New Hampshire students.and school personnel. In addition, I l will testify that the'Exerciseidid not' address the availability, training, capability, or. adequacy of performance i

of school personnel, that the Exercise did not evaluate major i

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portions of emergency response capabilities and responsibilities involving New Hampshire schools, as described in the Emergency Response Plan for each school, and that the 1 i

Exercise did not meet with my understanding of a " full .

participation" Exercise, as addressed in 10 CFR Part 50, Appendix E IV.F.1.

Finally, I will testify that FEMA is in error in finding that the Exercise met OBJECTIVE 19, . which. required a l

demonstration of the ab.ility and resources necessary to implement appropriate protective actions for school children within the plume EpZ. I (paolillo) I will testify that I conducted interviews of certain New Hampshire schop1 personnel. These interviews are contained in Attachment 9 to this testimony, and to my knowledge are true and accurate.

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0.3. please summarize your past professional experience.

and education.

A.3. (Sikich) A narrative summary of my past professional and educational experience.has previously been filed in this proceeding. This summary, together with my curriculum vitae, g l i are included in Attachment 1 to this: testimony. In addition, l

for purposes'of'this testimony, I wish to highlight certain of my experiences regarding the' preparation, conduct, and evaluation.of-emergency Exercises for nuclear power facilities.

( In 1980 and 1981, I consulted on emergency planning _;

and exercise, development.and-evacuation for Detroit Edison at the FERMI 2 nuclear Power plant. I was responsible for all emergency response training for compliance ~with Nuclear Regulatory Commission emergency preparedness regulations.

I While at Detroit Edison, I also participated in j designing the scenario for that facility's first pre-license Exercise, in consultation with utility, state, and FEMA officials. I was also involved in evaluating the performance of various facilities and response organizations in the Exercise, and evaluating compliance with FEMA and NRC

-regulatory requirements.

Subsequently, I consulted to Texas Utilities regarding the. Comanche Peak nuclear power plant where I was involved with preparing the initial pre-license exercise scenario which was submitted to-the Nuclear Regulatory Commission and coordinated with the Federal Emergency Management Agency

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1 In assisting in the development of the Exercise scenario, and emergency plans and programs for this facility, j as with others, I routinely reviewed the regulatory requirements in NUREG-0654 and the Code of Federal Regulations, as appropriate, which describe the elements for an emergency plan. For Comanche Peak I was' involved in evaluating the management functions performed by personnel at various i

facilities that respond during an emergency. I evaluated such j aspects as off-site notifications, protective action recommendations and communications. ,

In 1985 and 1986, I was engaged as a consultant to Carolina Power and Light to provide emergency planning services at the Shearon Harris Plant. I assisted a former NRC site inspector who was developing the scenario. I also oversaw j several consultants involved in the development of pre-exercise scenarios and evaluation process and in preparing the evaluation criteria for the full participation exercise. I also performed controller / evaluator functions during the full i

participation exercise. t 1

l In 1986, I was engaged as a consultant to Georgia j Power Company for the Vogtle I project, that conducted its full  !

i scale, full' participation Exercise in April of that year. My j

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involvement included coordination with FEMA evaluators in one  !

i of the South Carolina counties, in which I acted as evaluator i i

for the particular county to evaluate and review Exercise }

performance.

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4 In general, for each Exercise in which I have been involved, I have regularly interacted with representatives of the NRC and FEMA, and have acquired a working knowledge of the Exercise evaluation process, procedures and criteria by which the NRC and FEMA grade the Exercise. In my involvement in 1

emergency exercises, scenario development, and evaluation of l

exercise performance, I focused on the management function in j emergency response. In this regard, I was concerned with i

notification and communications involving entities such as )

off-site response groups, schools, and special facilities.I I

have also evaluated the process of protective action decision-making, and how PARS are transmitted to the affected entities responsible for taking action from an off-site perspective.

A.3. (Paolillo) My name is John Paolillo. I am employed as an Investigator for the Public Protection Bureau of the Massachusetts Attorney General's Office. I have a B.A. in Mathematics from Boston College. After graduating in 1987, I l

l was a Research Assistant for the Middlesex County (Massachusetts) court system. I came to the Attorney General's  !

Office in December, 1988 and have worked as an investigator for the Public Protection Bureau since that date. -

Q.4. Please explain the purpose of a pre-license Exercise for a nuclear power facility.

l A.4. (Sikich) In my view, the purpose of a pre-license 1 1 exercise is to test the ability of the on-site and off-site l l

l organizations to adequately protect the plant personnel and the i

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general public;under simulated emergency conditions. A d 1

pre-license exercise is designed to test the functions and roles of personnel who would respond in an emergency, both from the on-site perspective.and the off-site perspective, including specific groups who normally perform emergency functions, such

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.. j as police, as well as groups that would not normally perform i I

An exercise emergency functions, such as school personnel.

i' should test communication linkages between those entities

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identified in the plan to see how these entities and individuals analyze information and respond.

.l In addition, an exercise should measure the appropriateness of the response of emergency personnel, and their ability to protect the public at large as well as plant personnel. In my view, this opinion is consistent with 10 CFR ,

J Part 50, Appendix E. IV.F.1, that is cited in the Contention.

That regulation provides in part:

1. A full participation exercise which tests as much of  !

the licensee, state and local emergency plans as is  !

reasonably achievable without mandatory public I participation shall be conducted for each site at I which a power reactor is located for which the first operating license for that site is issued after July l 13, 1982. l

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" Full participation" when used in conjunction with emergency preparedness exercises for_a particular site means appropriate offsite local and State. authorities and licensee personnel physically and actively take part in testing their integrated capability to adequately assess and respond to an accident at a commercial nuclear power plant. " Full participation" includes testing the major observable portions of the onsite and offsite emergency plans and mobilization of l' State, local and licensee personnel and other r L resources in sufficient numbers to verify the capability to respond to the accident scenario.

4 An exercise, therefore, must demonstrate sufficient involvement, coordination, and " play" among utility, government

- and "other resources" to meet these full participation

. objectives.

An. Exercise also-must demonstrate the ability of the emergency response organization to appropriately integrate an emergency response through,such activities as communications, protective actions, emergency classifications, and activation of.off-site' facilities.

The Exercise should test the major portions of each

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emergency response organization to demonstrate.an adequate ability to protect plant personnel and to protect the general l

public.

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The Exercise should also test the major portions of the plans and emergency resources to-ensure the on-site

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response and the off-site response are fully integrated. The i

flow'of information and action among the response organizations i 1

should be clear, well defined, easily and readily understood by all organizations that form a part of the emergency response. i The personnel from each emergency response organization must participate in sufficient numbers during an exercise to demonstrate that they have adequate training, can perform under l

simulated emergency conditions, and have the capability to provide an efficient and coordinated response in an actual I emergency. An exercise must verify this capability to respond to the Exercise scenario.

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1 Q.5. please state the purpose of your testimony.

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A.S. (Sikich, Paolillo) The. purpose of our testimony is to support Contention TOH/NECNP 1(a):and (b) (Contention). A copy of the contention is included as Attachment 2. ,

I (Sikich) The Contention alleges that the' scope of j 1

the June 28, 29, 1988 exerciso for Seabrook' Station did not provide an evaulation of major observable portions of emergency )

response capabilities involving New Hampshire schools, and did 1

not address the availability,' training, capability or adequacy j of performance of school personnel, who are relied on in the l NHRERP to protect students'in a radiological emergency. I agree with these allegations. My opinion is based upon my knowledge, experience, and understanding of the purposes of a pre-license exercise, to which I have already testified. I also reviewed school plans contained in Attachment 5 to this testimony. My opinion is also consistent with my understanding )

j of certain guidance provided by FEMA as to the proper conduct l l

and level of participation involving schools and school personnel in a pre-license exercise. That guidance is addressed in FEMA Guidance Memorandum EV-2 and is entitled Protective Actions for School Children.

Guidance Memorandum EV-2 provides in part:

l Purpose I This Guidance Memorandum (GM) is intended for Federal Officials to aid them in evaluating emergency plans and preparedness for school children during a radiological emergency. This guidance is also intended for State and local government officials and administrators of public and private schools, including licensed and government supported pre-schools and day-care centers, for developing ,

1 emergency response plans and preparedness for protecting the health and safety of students, a

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Echool Ey.acua_ tion Considerations Eyaquation to Re.lagation Guatern - The evacuation of school children under the continuous supervision of teachers and administrators from a school to a relocation center is a viable and reasonable approach when confronted with a radiological emergency. The decision to implement a protective action recommendation to evacuate to a relocation center should be tied to the nuclear power plant's emergency action level classification.

hCCe91RDDR CLitBLLB Requirements are set forth in FEMA (44 CFR 350.9) and NRC (10 CFR 50, Appendix E.IV.F.1-5.) rules for conducting periodic exercises and drills. Under these requirements, organizations with assigned responsibilities for protecting students are required to demonstrate through exercises their ability to implement emergency procedures contained in their emergency response plans. However, the public (e.g., school children) are not required to participate in exercises. Further, the actual use of school vehicles is optional. The demonstration of each organization's capability to implement these measures in exercises will be evaluated by FEMA and other Federal officials. The following functions should be demonstrated and evaluated in exercises in which the evacuation of students is necessitated by events in the exercise scenario:

1. Alerting and notification of appropriate school officials by local emergency officials with respect to status of radiological emergency and need to implement protective actions, including evacuation; With respect to simulating the evacuation of school children in an exercise, the following guidelines are provided.

2. An exercise evaluator will interview the relevant personnel at the EOC's, the School Superintendent's office, the School principals' office, and the Dispatcher's office, as well as the bus driver to determine their awareness of and preparedness for the evacuation of the school children...

l Sr.Jm01.Supn istendent's Office .j

1. When and.from whom'did the superintendent receive i protective action instructions or recommendations?.  !

What specific instructions or recommendations did the i superintendent receive? 4

2. What actions did'the superintendent take to-implement' these instructions or recommendations? Whom did the superintendent. contact and when?~  ;

School principal's Office

1. When and from whom did the principal receive protective _ action instructions? .W hat. specific instructions did-the principal receive?-

2. What means of communications (e.g.,' telephone, tone alert) were used to provide these instructions? Did this means of communication function adequately to 4 provide accurate and timely information?

3. What actions did the principal take to implement these 1 instructions? Whom did the principal contact and when? j In my opinion, GM EV-2 contemplates a level of J

participation by schools and school personnel in a pre-license Exercise greater than that demonstrated during'the June 28, 29, i

1988 Seabrook exercise. In view of the purposes of_an Exercise, I believe that level of participation is necessary.

Q.6. What is your understanding of the provisions in the NHRERP regarding the responsibilities of school personnel to respond and protect students in a radiological emergency?

l A.6. From my review of certain portions of the plan, it appears that the NHRERP provides an essentially generic emergency checklist for each public, private, day care, and nursery school in the New Hampshire EpZ. These checklists are entitled Emergency Response Plans. I will-refer to them as plans ~for the purpose of my testimony. A listing of the schools, with estimated student populations, is also contained l

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in Volume 4 of.the NHRERP. Attachment 4. The NHRERP indicates there are 35 public schools and 78 private, daycare, and nursery schools in the New Hampshire.EPZ. In the NHRERP, generally, each school is provided with the above cited emergency response plan. This plan provides a rudimentary checkls r; and roughly outlines responsibilities for school personnel.in the particular facility to follow in an emergency to protect students. See Attachment 5.

l Under the plans, for public schools, the status of emergency conditions and protective' action recommendations I

(PARS) are generally transmitted from government officials to each.of the 5 school Superintendents, who are responsible for the 5 school administrative units (SAUs) located in.the New Hampshire EPZ. According to the plan, each Superintendent is responsible for communicating with the principal of each school within the Superintendent's jurisdiction. According to the plan, the school principal will in turn direct teachers to implement protective actions and. supervise students throughout the emergency response. If evacuation is ordered, the plan indicates that teachers will assemble, board, and accompany students on buses for transport out of the EPZ to designated reception centers. These emergency plans appear to contemplate that, collectively, the school personnel at each facility are e intended to form an integrated and coordinated emergency response, and implement pars to protect their students.

Attachment 5.

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For private, day care, and nursery schools, the j Emergency Response Plan for each facility' generally follows the i

same process of protective action implementation as provided i for public schools, except there are no school Superintendents  !

for these private facilities. Communication and PAR coordination therefore appear to flow from government officials 'l directly to each private, day care, or nursery school.

Attachment 5.

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Q.7. Based on your understanding of the functions and responsibilities of ochool personnel to protect students, as i i

provided in the plans, what is your opinion concerning participation by these personnel in a pre-license Exercise? 1 A.7. Based on the level of participation required by ,

these plans for an actual emergency, the Exercise should include participation by a sufficient number of personnel from 1 ,

each school entity or organization to verify the capability of i each school to coordinate and integrate an adequate emergency -l response for students. This would include full participation by the relevant school superintendents to demonstrate i appropriate notification and cL'. nunication, as well as implementation of the protective action process. ,

9 In addition, principals or directors at each of the l 1

public, private, day care or nursery schools, located in the  !

New Hampshire EPZ, should participate in the Exercise not only  ;

I from the standpoint of demonstrating that they can be l 1

contacted, but also to show that they have a clear f l

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understanding of what is required of them at each emergency classification level, as well as how to properly coordinate the protective actions that are being recommended.

I also believe a representative sample of teac'ers who will be implementing protective actions should participate to verify their understanding of the plan, and demonstrate their ability to carry out pars for students. I do not believe, however, that it is necessary to have school children participate in the Exercise. It is rather the emergency response personnel charged with coordinating and implementing protective actions for students who should demonstrate their ability to properly implement their plan in an exercise.

Q.8. What is your understanding of the level of participation by school personnel from public schools, and from private, day care, and nursery schools, in the June 28, 29, 1988 Seabrook Exercise in New Hampshire?

A.8. (Sikich) On this issue, I have reviewed certain responses to discovery requests prepared by the Applicants, Attachment 6, and the State of New Hampshire, Attachment 7.

Although these responses do not appear fully consistent, the responses suggest that actual participation by EpZ school personnel was minimal for a few schools, and that most schools, and their personnel, did not participate at all in the exercise.

For example, both Applicants and the State of New l Hampshire indicate that "no teachers participated in demonstrating protective actions for school children during the Exercise as schools were not in session." Attachments 6, 7, at

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l response to Interrogatory #1. Yet the Exercise scenario depicted events as if the schools were in session. (e.g.)

Attachment 10.

In addition, according to Applicants, only 1 principal (Swazy School) out of 35 for the New Hampshire EPZ public schools, and only 1 staff member for a day care facility (Country Kids) out of 78 private, day care, or nursery schools was ever contacted during the Exercise. Attachment' 6, at-Response to Interrogatory #5, and at Applicants' letter dated March 20, 1989, p.2.

The State of New Hampshire concurs with Applicants' statements, except the State asserts that 1 additional public school (East Kingston Elementary) was actually contacted during the Exercise. Attachment 7 at March 16, 1989 letter from State l 1

of New Hampshire.

l In addition, these discovery responses suggest that even these limited contacts did not generate any test of the i

schools' plans or procedures, beyond a response of "no school". Id at Attachments 6, 7.

In short, virtually nane of the principals, i teachers, or other school personnel employed at 113 school facilities in the New Hampshire EpZ participated in the Exercise.

Q.9. To your knowledge, did any school personnel participate in the Exercise beyond that to which you have already testified? )

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I A.10 (Sikich) For the 78 private, day care, and nursery schools, and based upon the discovery responses in Attachments 6 and 7 to this testimony, it does not appear that any school personnel for these facilities participated further in the l I

Exercise, with the possible exception of phillips Exeter 1 Academy, discussed below.

For the 35 public schools, it appears there was additional, limited participation by certain school personnel.

(Paolillo) On March 3 and 6, 1989, I conducted '

interviews with certain EPZ school Superintendents. Tne l content of these interviews are contained in Attachment 9, and are true and accurate to the best of my knowledge and belief.

As appearing in Attachment 9, these interviews are adopted by me, and made a part of this testimony, as if fully set forth herein, t

(Sikich) My review of certain depositions and statements taken from each of the 5 school Superintendents in i

the New Hampshire EpZ, and from the Dean of the phillips Exeter l I

Academy, Attachments 8 and 9, and of Mr. Paolillo's testimony,

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l indicates that, with one exception, the extent of this further i limited participation by school personnel apparently consisted 1

of only a phone call to each Superintendent's office.

Apparently the State official calling each SAU office did not request that any action be taken regarding the Exercise, nor did the recipient take any action in response to the call.

Therefore there was no demonstration in the Exercise, nor even an attempt to demonstrate, that school personnel understand the

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4 plan or'are capabable of implementing protective actions.for  :

students, in the context of'a, full' participation exercise scenario. Inde'ed,-in the case of SAU #16, and SAU #17, which l l

comprise 2 of 5 School Administrative' Units in the New.

Hampshire EpZ, it appears that the;one phone call-made by the

-State to each SAU was received by a Secretary, who simply acknowledged the call and hung up. Attachment 9 at Statements of Superintendents Joyce and Clancy.

In the case of SAU #21 and SAU #50, the State apparently was able to reach'the-Superintendent or his assistant,.yet no follow up contact'to individual schools,.

coordination of response, or demonstrated capability to implement the relevant emergency plans was requested or-attempted. Attachment 8 at Katner Deposition; Attachment 9 at.

Durgin Statement. This was'so even though most SAUs have, historically, complied with requests to' cooperate or participate in planning or exercise; e.g. Id at Katner' Deposition p. 26; Monahan Deposition, p. 21; See also i Attachment 9 at Joyce stau . ant; and even though there were, or may have been, administrative personnel in certain EpZ schools I ,

during the exercise, Attachment 9, Statement of Mark V. Joyce,

p. 4; and Statement of George Tucker, p. 3, even though schools were closed.

For the portsmouth SAU, the Superintendent sent two-representatives, apparently to a local EOC, who, to the L knowledge of'the Superintendent, "didn't do anything other than observe." Attachment 8, Monahan Deposition, p. 14. In l

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addition, following notification that the Exercise had begun, Mr. Monahan later personally received a call from the State, but took no action in response. Id at 17.

For the Phillips Exeter Academy, with an enrollment of almost 1,000 students, Attachment 4, the statement of George Tucker, Dean of Students, indicates that his school did not participate at all in the Exercise, and that Mr. Tucker was not even notified that'an exercise had occurred until he was contacted by the Massachusetts Attorney General's Office in March 1989. Attachment 9, Statement of George Tucker pp. 1,

6. Mr. Tucker also spoke with people in his immediate office, and with fellow dean Susan Herney, but these individuals were b

not aware that the school had any involvement in the Exercise.

Id at p. 1.

This contrasts with statements made by Applicants in response to discovery requests. As stated by Applicants:

Identification of persons participating in the Exercise cannot be made in the form requested because information is not available to Applicants. Based on a review of existing player and controller materials generated during the graded exercise, at least one administrative representative of each of the five Supervisory Administrative Units and an administrative representative of the Phillips Exeter Acedemy participated in the exercise. Appli; ants are unaware of the identities of these personnel with the exception of George Tucker, Dean of Faculty, Phillips Exeter Academy. The administrative representatives received at least one telephone call from New Hampshire emergency response personnel during the exercise. Attachment 6 at Response to Interrogatory

1. 2(a).

The State of New Hampshire " incorporate (d) and adopt (ed) Applicants ' voluntary responses to TOH's Infort:.al Discovery Requests (hereinafter " Applicants's Response"),

Response 2(a), and concurs with the information provided therein."

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I Attachment 7 at Response 2(a). Even if Applicants and the State are correct that a call was made to the Academy, it is clear from Mr. Tucker s statement, and from those of the School Superintendents, that this phone call " participation" in the Exercise was perfunctory, often did not reach responsible personnel, and did not test, and did not attempt to test, the plans or personnel in the schools, or their capability to  ;

respond to an emergency.

Q.10. In order to meet the purposes and objectives for a  ;

l full participation Exercise, is it necessary to conduct the l Exercise when schools are in session?

A.10. (Sikich) No. As I stated, the purpose of the Exorcise is to verify the capability of the emergency response j l

organizations, and personnel responsible for implementing the plans, to respond to the exercise scenario. participation by the general public, including students, however, is not necessary to verify these capabilities. Whether or not school is in session, a sufficient number of school personnel responsible for emergency response should participate in the Exercise to demonstrate that these objectives can be met. In my view, this would include participation by all Superintendents, each principal or director, and a sample of teachers from aach school facility, in the case of public schools. For private schools, this would include all of the same personnel, except Superintendents.

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.4 Q.ll. Do youragree with FEMA'that the Exercise met Objective 19 which-provides:

Demonstrate the ability and resources necessary to .

1 implement appropriate protective actions for school- i children within the plume EpZ.

FEMA Report, p. 172.

A.11. No. An Exercise should. test emergency communications and coordination involving the schools. This requires a two-way. integrated. exchange of information.- The information flows from the government' officials through to the i schools, ano should be received;by the appropriate individual 1

who actually has responsibility to carry out the. response 1 functions stated in the plans. There must be sufficient interplay among school personnel at each school to demonstrate the capability to respond to the .tcenario, implement protective )

i action recommendations and take appropriate actions' as '

necessary to protect the health and safety of school children I

and school related personnel.- A full participat, ion exercise should test the capabilities of identified school resources (responsible school personnel) at each school. These school personnel must. verify their ability to respond in an integrated ,

and coordinated manner to an emergency. The June 28,'29 1988 l ' Exercise did not attempt to verify these capabilities. Prior to operation, these capabilities should be demonstrated and

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I evaluated in an Exercise. Until that time, there is not' f

reasonable assurance that adequate protective measures can and will be taken in a radiological emergency. 'l

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UNITED STATES OF AMERICA l

. NUCLEAR REGULATORY COMMISSION 89 APR 11 P5 :59 j ATOMIC SAFETY AND LICENSING BOARD. i budth s, , ,. ,a l Before the Administrative Judges: M!Md* I Ivan W. Smith, Chairman Dr. Richard F. Cole ,

Kenneth A. McCollom 1 l

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i In the Matter of ) Docket Nos. 50-443-OL i l ) 50-444-OL I l PUBLIC SERVICE COMPANY ) (Off-Site EP) {

l OF NEW HAMPSilIRE, EI AL. ) l I ) i (Seabrook Station, Units 1 and 2) ) April 10, 1989 l l

ATTACHMENTS TO TESTIMONY OF GEARY W. SIKICH AND JOllN PAOLILLO ON BE!!ALF OF ATTORNEY GENERAL  ;

JAMES M. S!!ANNON, TOWN OF HAMPTON, NEW ENGLAND l COALITION ON NUCLEAR POLLUTION AND SEACOAST ARTI-POLLUTION LEAGUE REGARDING TOH/NECNP EX 1(a) AND (b) l l

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l Department of the Attorney General Nuclear Safety Unit Public Protecton Bureau One Ashburton Place Boston, Massachusetts 02108 (617) 727-2200 i

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ATTACHMENT 1

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GEARY U. SIKICH l 1646 Cardinni Drivo  !

Munster, Indiana 46321 l Offices (312) 648-7415 i Homet (219) 924-4885 PROFESSIONAL EXPERIENCE i l

Laventhol & Horvath 1 Managing Director  !

Emergency and Environmental Advisory Services I March 1988 - Present 1

Recruited by Laventhol & Horvath to develop this functional '{

discipline. The practice consists of four integrated strategic I business units: f1 Regulatory Compliance Emergency Planning Training & Development Information Management 4

Developed federally mandated Hazardous Materials Response Plans for s

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clients in Indiana and Illinois..The plan is being evaluated for {

use as a model plan for hazardous materials response planning. 1 Providing litigction support to the Massachusetts Attorney General h on emergency planning, training, crisis communications and information management. I 1

1 Developed HAZVAL" an environmental assessment program. l Secured initial capitalization ($7,700,000) for Stericycle, Inc..

Stericycle treats infectious waste with gamma radiation. Projected market operation.

value of Stericycle is $53,200,000 after three years of l

Providing emergency preparedness, safety, environmental and risk j management services to the health care industry. Projected earnings total in excess of $35,000,000. l 1

1 Providing emergency preparedness support services to the public and i l

private sector. Projected earnings total in excess of $10,000,000.

1 Pannell Kerr Forster Supervisor Environmental and Energy Management Group April 1987 - March 1988 '

Assimilated my consulting practice into the firm. Created a new practice in environmental and energy consulting. Consulted to energy, chemical and transportation companies.

GEARY U. SIKICH Page 2 Logical Management Systems Entrepreneur October 1984 - April 1987 Initiated the start-up of Logical Management Systems. Logical Management Systems provides emergency planning, specialized management and human resource consulting services. Consulted to several start-up firms in the area of business development and strategic planning.

Designed COMTRAX'" an emergency preparedness commitment tracking system for Georgia Power Company. Consulted to EBASCO, a large nuclear engineering firm, in the areas of emergency planning, training, litigation support and plant licensing.

Facilitated the design and implementation of the emergency response management program for Carolina Power & Light Company.

Developed CRISIS MANAGER'" a crisis management program. Developed AUDITRAK'" an emergency preparedness compliance assessment program.

Developed a time management training program.

Our planning group established a record of "Best in the Region,"

for the initial Emergency Preparedness exercise for Carolina Power

& Light's SHEARON HARRIS Plant.

Impell Corporation Lead Senior Engineer May 1983 - October 1984 Consulted to Commonwealth Edison and Texas Utilities on emergency planning and plant licensing. Developed job descriptions and selection criteria for emergency planning personnel. Represented utility management as liaison to community and regulatory groups.

Established a record of "Best in the Region," for the initial Emergency Preparedness exercise for Texas Utilities COMANCHE PEAK Plant.

The Detroit Edison Company senior Training Specialist August 1981 - May 1983 Recruited by Detroit Edison to manage emergency preparedness training at the FERMI 2 nuclear power plant. Designed and implemented emergency preparedness training programs. Developed department strategy, schedules and budget. Supervised a staff of fifteen consultants and three utility personnel. i 1

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GEARY O. SIKICH Page 3 Performed evaluations of crisis management skills of corporate management, public ofH cials and response organizations. Conducted pre-licensing emergency preparedness exercise and audit / appraisal programs. Cited by the Institute for Nuclear Power Operations as having standard.

a training program several years ahead of the industry Established a record of "Best in thE: Region", for the initial Emergency Preparedness exercise for FERMI 2 Plant.

Science Applications, Inc.

Research Scientist March 1979 - August 1981 Responsible for the design and initial testing of Phase 1A of the U.S. Army National Training Center program. Supervised a staff of twenty project engineers, computer analysts and programmers.

Developed data analysis methods to determine the effectiveness of decision making in large organizations under crisis situations.

As part of a Nuclear Regulatory Commission taskforce, I performed job and task analyses of nuclear power plant security personnel and security systems.

} Designed a Supervised-On-The-Job-Training program for senior staff of the Royal Saudi Navy.

U.S. Army Officer July 1973 - March 1979 Served in various supervisory functions during my tour of duty.

Performed planning, analysis, information systems structuring and data acquisition functions involved with a high degree of national security sensitivity. This included classified strategic studies of lines of communications, telecommunications, transportation and political / economic infrastructure for the highest level executive decision-makers.

Selected to conduct concept testing of the Battlefield Information Coordination Center (BICC). The BICC is an information collection and processing center collocated with frontline combat units. The BICC provides near real-time access to essential information for executive decision-makers Assigned to investigate the feasibility of developing a National Training Center. Upon completion of the feasibility study, I designed the initial test for the National Training Center. The successful completion of the initial testing resulted in

$200,000,000+ being allocated for development of Phase 1A.

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GEARY Wo SIKICH Page 4 EDUCATION M.A., Management: Central Michigan University (graduate studies) l l

M.Ed., Educational Psychology: University of Texas; 1981 B.S., Criminology: Indiana State University; 1973 l

BELECTED PUBLICATIONS / PAPERS l National Training Center Live Fire Exercises; Military Intelligence j Magazine, 1978.

National Training Center Phase 1 Completion; Military Intelligence l Magazine, 1979.

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Royal Saudi Navy Supervised Training (SOJT) ; Vol. I-VIII, 1981. I I

Radiological Emergency Response Preparedness Training Instruction I Manual; 1982.

i Overview of Emergency Planning; Emergency Planning Workshop, 1 October 5, 6, 1987.

Emergency Planning and Preparedness: The Planning Function; Emergency Planning Workshop, October 5, 6, 1987.

Evaluating Compliance; Emergency Planning Workshop, October 5, 6, 1987; Presented at Financial Reporting of Environmental Exposures, Washington, D.C., December 5, 6, 1988.

l WHAT IF...., Corporate Responsibility and Shareholder Rights: The Impact of Environmental Legislation on Shareholders; March 1988; Presented at Financial Reporting of Environmental Exposures, Washington, D.C., December 5, 6, 1988.

Crisis Communications Planning; Emergency Planning and Chemistry for the Non-Chemist Workshop, August 11, 12, 1988.

Environmental Laws Hold Hospitals Liable for Wastes; Hospital Materials Management, October 1988.

Environmental Risks Can Be Made Acceptable Through Awareness and Careful Management; Midwest Real Estate News, January 1989.

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3 ] to Q. Please summarize your past professional experience and education A. Prior to joining Laventhol, I was employed by another firm by the name of Pannell Kerr Forster. I was Supervisor for the Environmental and Energy Management Group. I was assigned to begin a business consulting practice in the area of environmental and energy management, focusing on emergency planning, regulatory compliance, training and information services.

I was with Pannell Kerr Forster for approximately ll months _

before joining Laventhol & Horwath. I was recruited by Laventhol to build the emergency and environmental advisory service practice.

Prior to those two firms, I was self-employed from October of '84 until about April of '87. I consulted to the nuclear power industry. In general I was responsible for developing a training program for emergency preparedness i

on-site at the Shearon Harris Plant and at theH.B. Robinson j Plant. I also developed their emergency operatins facility  !

1 management procedures. I was contracted to Georgia Power for their Vogtle Plant, and was responsible for developing I off-site emergency planning. I also developed a commitment tracking system for their emergency planning with regard to l the Vogtle Nuclear Plant. I also outlined'a similar system for Georgia Power's Plant Hatch.

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6 7 /k prior to that I was a consultant with a Impell Corporation. I worked with them from May of '83 until October of '84 and was involved with consulting to Commonwealth Edison and Texas Utilities, in the areas of on-site and off-site emergency preparedness planning, training, developing job descriptions, and working.on licensing issues, prior to that, I was employed'by Detroit Edison as a senior training specialist and was responsible for developing the FERMI 2, Nuclear Power plant's initial emergency preparedness training program as well as subsequent training programs that were developed for the facility, i

prior to that I was-with Science Applications, Inc., as a research scientist. This was from March of 1979 to August of 1981, I was responsible for doing some work with the Nuclear Regulatory Commission on job and task analysis for plant security personnel and security systems. In conjunction with that contract, we were on the peripheral aspect of the Three Mile Island Nuclear Plant issue f om a standpoint of being involved from the initial contract we had on security personnel and plant security systems, prior to that I was a military officer with intelligence functions in the Army from July of 1973 to March, 1979.

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I Q, Have you in the course of your professional experience worked directly on planning issues as they relate to i radiological emergency plans?

A. Yes.  !

At Detroit Edison'I was responsible for developing j j

the nuclear emergency preparedness training program for the 1

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staff, both the on-site and off-site Detroit Edison personnel. We developed a program for staff personnel from I

the off-site group, who were people who did normal utility ]

functions from a non-nuclear standpoint and trained them on i how to do radiological emergency monitoring and the communication function of reporting that information. I developed that program and moved form there to Impell Corporation. I was involved briefly with the Byron Nuclear Plant for about one month doing some off-site. emergency preparedness work and then was shifted to the Texas a

Utilities Comanche Peak plan for a period of approximately seven months. In that period I was assisting our head l person on the site to develop an emergency preparedness program consisting of the site plan, the implementing {

procedures, the on-site training program, as well as conducting the drills, exercises and the graded Nuclear Regulatory Commission exercise. We did the first exercise 1

in December of '83 in which they came out best in their .

region as far as near term operating plants. I went back to Chicago from the exercise work in Texas, spent three and a half months in the Chicago office working on the LaSalle and Dresden plants for off-site emergency planning. I was

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ay involved in doing evacuation studies as well as revising some of the off-site emergency plans that had been developed by the State of Illinois and Commonwealth Edison. We upgraded those plans with regards to special populations and the overall off-site planning.

After approximately three and a half months of working on that project, I was assigned back to the Texas Utilities Comanche peak plant to do a complete upgrade on their emergency preparedness procedures and the emergency plan.

We literally rewrote the procedures for that plan. I was charged with writing most of the management procedures with regards to non-technical nuclear issues for the emergency I managers. I was charged.with writing and making them more task-oriented procedures focusing on the ability of the i-individual to operate on a checklist-type of basis so that he/she could become more focused on the task at hand in  !

contrast to the educational type procedures currently in  !

place. This is where the procedure is written in the third person to educate the individual as to his/her responsibility.

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We did a complete re-write and upgraded the procedures so l that emergency response personnel could accomplish these l 1

tasks, duties, and functions in a more efficient manner.

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'If/O After concluding that assignment I went back to the Chicago area and became self-employed. I was contracted to Carolina Power & Light and spent a year at.the Shearon Harris' Nuclear.

Power Plant. .I was responsible for developing their emergency preparedness training program for the facility.

When I got to the facility, I was. moved from the training i

group to a temporary assignment to work on their first I

exercise. I worked with consultants from several companies and basically marshalled the setup of drills, exercises,  !

and their overall' final exercise.into a program that the utility was able to implement fairly easily. I then returned.to the training role that I was originally _

assigned.

l In conjunction with that contract,-I was~ assigned on a o special basis'at the request of one of Carolina Power & 't Light's vice presidents to rewrite the H.B.' Robinson j i

Plant's emergency operations facility procedures for the  !

l people who would man that facility during an emergency.

This was part of CP&L's preparations for an annual graded exercise at H.B. Robinson.

Upon completion of the contract I had with Caroline Power &

Light. I went to Georgia Power under contract to work on the off-site emergency plans for plant Vogtle. At the. )

Vogtle Plant I was involved with some of the licensing i issues regarding the off-site emergency plans and their.

adequacy.

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ooy,a At'the Vogtle plant, we were successful in, one, putting y together the off-site emergency plans, two, identifying )

problems and having them taken care of internally and to the satisfaction of the outside observers. I was, also, l

responsible for implementing an off-site training program  !

in crisis communications.that dealt with transmitting information from the plant to off-site response personnel.

This training program pertained to how to transfer l 1

I technical information to people with non-technical l backgrounds.

My contract was extended'and I was asked to assemble an )

emergency preparedness commitment tracking system for'the i Vogtle plant. i The tracking system was based upon an i analysis of approximately nine essential elements. Those were administration, organization, facilities, equipment, trainin?, off-site coordination, communications, i organization, drills and exercise.

The purpose of the commitment tracking system was to identify all of the commitments that Georgia power had made with regards to the plant for emergency preparedness over a j course of approximately eight years of construction. We j ended up identifying over 4,000 commitments of which 458 were determined to be continuing commitments. The ongoing l commitments were subsequently put into a scheduling program.

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. I As a result of this, I developed COMTRAX which is a very simplified data base commitment tracking program. We use it to catalog commitment tracking issues for facilities that are affected under: 1) nuclear criteria; and 2).of environmental issues, under the Superfund Amendments Reauthorization Act (SARA) alto known as the Emergency Plannir J Community Right To Know Act. In addition there are several other environmental laws that impact on companies that reg,uire commitments to be tracked and t

properly documented.

I, also, was responsible-for developing a program called AUDITRAK, which is an emergency preparedness compliance assessment program based on NUREG 0654 and SARA Title III.

The focus of AUDITRAK is to take the requirements of the l original FEMA and NUREG-0654 guidance and SARA Title III and put it into a computerized work paper form. It i functions by looking at the essential elements of analysis I cited earlier. AUDITRAK provides a set criteria for plants similar to the grading used by the Nuclear '

Regulatory Commission with 10 CFR 50.54T criteria.

A prototype version of this system, was used at Texas Utilities' Comanche peak Plant. The result was a comment by NRC's inspection team that they could do their job in a i

1 more timely fashion because all the documentation was close at hand. The NRC staff actually said that it was the first

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l weekend break that they had had in this type of inspection, because the information was well-organized, .and in a form that was easily understandable, validated, and cross-referenced to the regulations and. site documentation.-

I have developed a program called CRISIS MANAGER-which is an automated emergency plan consisting of nine to ten-sections that deal with the key elements of analysis:

administration of the plan, the organizational structure f

l and concept of operations, communications, emergency classification, protective action recommendations, reentry and recovery, training, drills, exercises, evaluation and a cross-reference between the. emergency plan to specific regulatory guidance and commitments.

I went back to the Chicago area'in 1987 and merged my practice into Pannell Kerr Forster. I was recruited by ,

l Laventhol & Horwath to develop their emergency and environmental advisory services practice. Since coming to

• l Laventhol & Horwath I developed another program dealing  !

primarily with emergency preparedness.and environmental assessment issues called HAZVAL. HAZVAL is designed to assess general site information, identification, collection, storage and disbursement of hazardous materials, recordkeeping, training and other required documentation.

The program is currently being used to assess compliance with SARA Title III issues in terms of emergency planning.

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Currently, at Laventhol, I've been involved with setting up l their emergency and environmental advisory services practice. This practice is focused on four areas, regulatory compliance, emergency planning, training and development, and information management. Attached is a copy of my resume and capability brochure. l i

With regards to publications and papers, I wrote the Radiological Emergency Response Preparedness Training Instruction Manual for Detroit Edison in 1982. I have conducted a series of workshops on emergency planning which -

include topics such as an overview of emergency planning, emergency planning and preparedness, the planning function; q

and how to evaluate compliance. I am working with'the National Safety Council on a series of articles about  !

i emergency preparedness. I am also negotiating the publication of a book I wrote on emergency planning and preparedness. I recently had an article published in  !

Hoso'dt1 Materi als Manaamment about environmental laws and how to hold hospitals liable for wastes. I have written l and published articles on real estate issues and environmental risks. I am currently speaking in March of this year before the American Society of Mechanical Engineers on SARA Title III and its emergency planning requirements.

In April I will talk before the Chicago Bar Association on emergency planning and how their clients are affected by emergency planning issues. I will also be /

conducting a one-day workshop on emergency planning at

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l HAZWASTE Expo, Atlanta, '89, on emergency planning.- I also

)i will talk about crisis communications, crisis communications i i

planning, and working with the off-site community.

In addition to that one-day seminar, I will be presenting a one-hour discussion of regulatory compliance issues.

I have also developed federally-mandated hazardous l 1

materials response plans for clients in Indiana and Illinois. _The Indiana plan is currently being'used and l

recommended by state officials as a model plan for all {

l hazardous materials response planning for local emergency J planning committees.

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I have also developed emergency. preparedness training a

programs for industry. Specific programs dealt with the Illinois Chemical Safety Act which parallels the Emergency I

planning Community Right to Know Act and portions of 10 CFR  ;

50. I am currently negotiating contracts for emergency i planning, training, and information systems development, l with numerous clients in the utility industry, the refining and oil industry, steel industry, health care industry and the public sector.

l'i } 1% i ATTACHEENT 2 i l -

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! NUCLEAR REGULATORY COMMISSION l Before the 1

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ATOMIC SAFETY AND LICENSING BOARD

\ j In the Matter of ) October 21, 1988 \ ,

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PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, et al ) Docket Nos. 50-443-OL <

) 50-444-OL off-Site Emergency 1 Planning

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_(Seabrook Station, Units l'and 2)

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TOWN OF HAMPTON AND NEW ENGLAND COALITION REPLY TO ON NUCLEAR POLL THE RESPONSES OF THE STAFF-AND APPLICA TO INTERVENERS CONTENTIONS ON GRADED  !

I NOW COME the Town of Hampton (hereinafter "T f OH") and New England Coalition to the responsesonofNuclear the Pollution (hereinafter and hereby "NECNP reply Staff and dpplicants submitted by TOH/NECNp on the graded exercise c to certain con 29, 1988, as follows: onducted on June 28 and l-TOH/NECNP EX 1 \

The scope of the June 28-29, Radiological Emergency Response Plan 1988 Exercise of the New Hampshi NHRERP) could not and did not yield valid or m(eaningful rewas so limited that it

,' capability 5 50. 4 7 (a) (1 to implement and (a)(2), that plan, as required sults regarding the evaluations) of emergency in that it did not include by 10 C.F.R.

response capabilities of demonstrations or entities relied upon to implement th NHRERP. many persons and exclusion the of Exercise these entities from the Exercise p In addition, the

[ capabilities, asevaluated required by 10 major portions recludes a finding that of emergency Part 50, Appendix E(F) (1) . C.F.R. response 550. 4 7 (b) (14) and 10 C.F.R.

Other than limited participation by State l

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i of New Hampshire personnel, the najority of the organizations,

! entities, and individuals relied upon in the NHRERP for implementation of that plan did not participate in the Exercise. Thus, theequipment, Exercise did not address the willingness, availability, training, capability, or adequacy of performance of the entities and individuals each of which is necessary to I.

I identified in Bases a to g below, implement the portions of the NHRERP referenced therein. Accordingly, i the NHRERP is fundamentally flawed. [f BASES:

(a) None of the teachers relied upon under the NHRERP to '

implement protective actions for school children, 211, e.g., NHRERP vol. 18A, Appendix F, participated in the Exercise. Necessarily, the Exercise failed to meet a primary objective to demonstrate the ability and resources necessafy to adequately protect students in an  !

emergency. Exercise Report, p. 172. Since hundreds of teachers through their representatives, and by petition, have already provided evidence in this proceeding of their intent nga to implement the NHRERP, failure to test for the availability and participation of New l Hampshire teachers represents a fundamental flaw in the NHRERP.

(b) Since none of the New Hampshire teachers participated in the Exercise, FEMA could not observe any adequate demonstration of the organizational ability or resources necessary to effect an early i dismissal, sheltering, or evacuation, of the school children, even j though this demonstration was one of the Exercise objectives. j Exercise Report, p. 172. Under the NHRERP, early dismissal, i sheltering and evacuation are the 9 2 protective actions for school I children. Sig (e.g.) NHRERP Vol. 18A, App. F. 1-3, F. 1-4. All of these protective actions assume, and rely upon, teachers for implementation. Id. Failure to observe or test necessary personnel ,

or procedures to protect studsnts represents a fundamental flaw in the I NHRERP.

(c) During the summer months, Hampton Beach is the most highly and densely populated area in the Seabrook EPZ, and poses unique and j

extreme obstacles to emergency planning. Under the NHRERP, State Police are required to provide all 17 traffic guides to staff every traffic control post located within Hampton Beach, and to assume responsibility for regulating the bumper to bumper traffic out of the Beach aren. SAs NMRERP, Vol. 6, App. I: Exhibit 1 to Applicants' i

Direct Testimony No. 3 (Personnel Resources), Table 3.1-2. The Exercise did not provide for, test or require even a single State Police officer to staff any of the five traffic control posts located in Hampton Beach, and the Beach, as an area for exercising the Plan, was essentially ignored. Failure to adequately demonstrate the ability and resources deemed necessary under the NHRERP to evacuate ithe EPZ's most populated beach area represents a fundamental flaw in

'the NMRERP.

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ATTACHMENT 3

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T 3# Federal EInergency Management Agency vashington, D.C. 20+72 NOV i 2 :.

GUIDANCE MEMORANDUM EV-2 PROTECTIVE ACTIONS FOR SCHOOL CHILDREN Purtese This Guidance Memorandum (GM) is' intended for rederal officials to aid them in evaluating emergency plans and preparedness for school children during a radiological emergency. This guidance is also intended for State and local government officials and administrators of public and private schools, including licensed and government supported pre-schools and day-care centers, for developing emergency response plans and preparedness for protecting the heal:h and safety of students.

Backereund The joint Federal Emergency Management Agency (FEMA) and Nuclear Regulatory Commission (XRC) guidance document, NUREG-  ;

0654/TEttA-REP-1, provides criteria for protective actions for persons, including school children, within the plume exposure pathway emergency planning :ene (EPZ) in the event such protective actions are needed in response to a radiological emergency at a commercial nuclear power plant. The need to ,

address the issue of protective actions for school children i stems from both the lack of detailed guidance on this issue i and the expressed interest for such guidance from public

. interest groups, State and local government officials and Federal Regional of ficials.

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Guidance contexts:

is provided in this GM on schoci evacuation in two  !

for developing emergency response plans and f or conducting and evaluating exercises. ' The primary method f or protecting school children examined is evacuation to relocation centers. This GM is a companion of the guidance on evacuation contained in Gli 21, Acceptance Criteria for Evacuation Plans. This specific guidance related to school children is appropriate because of the interest and concern expressed about protecting the health and safety of school children during a radiological emergency at a commercial nuclea r power plant.

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scheel Evacuatien Cersiderstiens Iyneuatien 12 peleentien Centers. The evacuation of scheci en11dren under :he continuous supervision of teachers and administrators from a' school to a relocation cencer is a viaole and reasonacle approach when conf ronted wi:n a radiological emergency. The decision to implement a protective action recommendation to evacua:e to a reloca ica center should be :ied :o the nuclear powe:~ plant's emergency action level classification.

Some emergency, response plans include the protective action stracegies of early evacuation and early dismissal. If Sta:e and local governments select one of these strategies, : hen they ought to address it in their emergency response plan.

If a State or local government elec:s to employ early l evacuation or early dismissal, this guidance is sufficiently flexible to cover both strategies. All of the general guidance for evacuation would apply with the addition of the special considerations for early protective actions at the end of this GM.

The recommendation to school officials to evacuate the school

hildren to relocatien centers should specify the area (s) :o be included in the evacuation. For example, the evacuation could include scacols within the two-mile radius of the plant and within three downwind sectors beyond the two-mile radius.

Prompt evacuation is not advisable during exceptional' '

situations such as having to drive through a radioactive plume or into a severe blizzard. Under these circumstances, the special population including school children, handicapped and/or immobile persons should be temporarily sheltered and subsequently evacuated, if need be, as soon as conditions permit.

School children and other special population evacuees (see also GM 25, REP for Handicapped Persons.) should be relocated outside the ten-mile E?% in predesignated facilities to ensure that the accountability, safety and security of the evacuees can be maintained and to minimize vehicular traf fic and telephone use within the EPZ.

General considerations- For whatever protective action options are contained in emergency plans, the plans shocid include provision f or notifying parents and guardians (e . g. ,

through the Emergency Steadcast System (EES)) of the status and location of their children during a radiological emergency. Also, the plans should document the decision making process and criteria used for developing emergency procedures for implementing protective action measures f or school children. Acceptance cri:eria for developing anc evaluating emergency planning and preparedness f or schoci enildren are provided below.

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Plannine Standard and K21IcaricN Cr!teria J.  ??ctective Esscense Plannine Standard l

A range of protective actions have been develop.ed for the (

plume exposure pathway EPZ for eme::gency workers and the l public. Guidelines for the choice of protective actions '

during .an emergency, consistent with Federal guidance, i are developed and in place, and pretective actions for l the ingestion exposure pathway E?% appropriate to the l locale have been developed. (NUREG-06 5 4/TE MA-RE?-1, j

p. 59) -

Evaluation criteria 2.34 Each State and local organization shall establish a capability for implementing protective actions based upon protective action guides and other criteria. This shall be consistent with the recommendations of E?A l regarding exposure resulting from passage of i radioactive airborne plames (EPA-520/1-75-001), and i

. with those of DHEW (DHHS)/FDA regarding radioactive ]

contamination of human food and animal feeds as  !

published in'the rederal Reeister of Seeemsee tir t95Gr i f49 PR 5899&t deteber 22,1982 112 I3 47073).*

2211. The organization's plans to implement protective  !

me "tres for the plume exposure pathway shall include:

J.10.a. Maps showing evacuation routes, evacuation areas, pre selected radiological sampling and monitoring points, relocation centers in host areas and shelter areas (identification of radiological sampling and monitoring points shall include the designators in Table J-1 or an equivalent uniform system described in the plan);

J 10.b. Maps showing population distribution around the nuclear facility. This shall be by evacuation areas (licensees shall also present the information in a sector format);

J 10.e. Means for notifying all segments of the transient and resident population; J.10.d. Means for protecting those persons whose mobility may be impaired due to such facters as institutional or other confinement;

• For your information and reference, tne 12/15/73, OHMS guidance has been superseded oy the 10/22/82, guidance.

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UDg/0 J.10.:. .Means of relocation; 3.10.M.

Relocation centers in host areas which are at least five miles, and pref erably ten miles, devend the ocundaries of the plu=e exposure IP: (See K.5);

J.10.1. Time estimates for evacuation of various sectors and distances based on a dynamic analysis (time-motion study under various conditions) for the plu=e exposure pathway EPZ (See Appendix 4);

Areendix j. Evacuation 2133 Estimates Within ata Plume Excesure Pathway Emer:encv Plannine lana Accend!x 4.!!.C. Seecial Facility Poculation An estimate for this special population group shall usually be done on an institution-by-institution basis. The means of transportation are also highly individualized and shall be described. Schools shall be includ'ed in this segment (p. 4-3).

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These evaluation criteria address the key planning requirements concerning the evacuation of students f rom schools. The review unds e these criteria is intended to ensur's that adequate planning and preparedness capabilities '

exist to, enable school officials to evacuate students in the event such a protective action is necessary during a radiological emergency. This guidance covers those actions from the initial notification to school officials of the need to evacuate the students to their arrival at relocation centers or other protective actions. In 4dition to these a cti' ens , the guidance also addresses time f rames for accomplishing the protective actions.

For purposes of definition and re'ference to NURIG-0654/ FEMA-RE P-1, we are including " schools" among the types of institutions, the mobility of whose population may be impaired during a radiological emergency, because most students are dependent on school officials for transportation to and from their residences. (See evaluation criterion J .10.d. ) Also, " schools" are explicitly ref erenced in Appendix 4 on pagas 4-2 and 4-3 as a type of "Special Facility Populatitn" for which evacuation time f rames are needed on an institution-by-institution basis. The term,

" schools," as used in this GM refers to puolic and private schools, and licensed or government supported pre-schools and day-care centers.

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2)J/W Accertance criterin An emergency plan will typically be acceptable under :hese evaluation criteria if it fully addresses the following emergency functions for :he evacuati:n of, or cener appropriate protective measures for, school children.

Local governments should take the iniziative to identify and contact all eublic and erivate school systems within the  ;

designated plume exposure pathway EPZ to assure that both public and private school officials address appropriate planning for protecting the health and safety of their students f rom a commercial nuclear power plant accident. The planning of both the public and private school officials should be. closely coordinated with that of the local government.

Local governments should ensure that appropriate organizational officials assume responsibility for the emergency planning and. preparedness for all of the identified schools. Local governments should also ensure that the emergency planning undertaken by these organizations is integrated within the larger offsite emergency management framework for the particular nuclear power plant site.

In accordance with the guidance contained in GM 21, the evacuation planning undertaken may be developed in three ,

contexts:

(1) Part of the existing radiological emergency preparedness plans, 3

(2) A separate annex of an existing integrated emergency plan for many types of disasters and i emergencies or (3) A separate evacuation plan for all of the schools in i

each' school system.

School officials should document in the plan.the basis for determining the proper protective action (e. g. , evacuation, early preparatory measures, early evacuation, sheltering, early dismissal or combination) including: ,

a Identification of the organization and officials l

responsible for both planning and effecting the protective action.

Institution-specific information:

- Name and iocation of school; ,

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- Type .cf school and age grouping (e.g., public j elementary school, grades kindergarten through sixth)- '

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1 1 1 Total population (students, faculty and 0:her l empicyees); I Means for effecting protective actions; Specific resources allocated for transportation and supporting letters of agreement if resources are provided from external sources and

- Name and location of relocation center (s), and 1 transport route (s ) , if applicable.

If parts of the institution-specific information apply to many or all schools, then the information may be presented generically.

l Time frames'for-effecting the protective acti:ns.

l Means for alerting and notifying appropriate persons and groups associated with the schools and the students including:

- Identification of the organization responsible for providing emergency inf ormation to the schools; -

- The method (e . g. , siren and telephone calls) for contacting and providing emergency information on  ;

recommended protective a~ctions to school officials; j

- The method (e. g. , siren, tone alert radios and telephone calls) for contacting and activating designated dispatchers and sen:o1 bus drivers; and ,

1 '

~ The method ( e . g. , E3s messagea, for notifying parents '

and guardians of the status and location of their children.

Plannine Standard W Evaluation Criteria N. Exercise ugl Drills Plannine standard Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities. Periodic drills are (will be) conducted to develop and maintain key skills.

Inadequacies identified as a result of exercises or drills i are (will be) corrected. (NU REG -06 3 4 /TEMA-REP-1, p. 71) I i

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Evalustien crie,ria 9.1.a. An exercise is an event that tests :he integra:ed capacili:y and a major portion of :he basic elemen:s existing within emergency preparedness plans 'and organizations. The emergency preparedness exercise shall simulate an emergency that results in offsize l radiological releases which would require prompt  !

response by offsite authorities. Exercises shall be l conducted as set f orth in NRC and TEMA rules.

Halta An exercise shall include mobilization of State and I local persennel resources adequate to. verify the capability to respond to an accident scenario requiring response. The organization shall provide for a critique of the biennial exercise by Federal )

and State observers / evaluators. The scenario should be varied from exercise to exercise such that all major elements of the plans and preparedness organizations are tested within a six-year period.

Each organization should make provisions to start an exercise between 6:00 p.m. and 4:00 a.m. once every six years. Exercises should be conducted during different seasons of the year within.a six-year l period in order to provide fpc exercising under various weather conditions.. Some exercises should be unannounced 3 14 official observers from Federal, State or local 3 governments will observe, critique and evaluate the {

required ex.ercises. A critique shall be scheduled at the conclusion of the exercise to evaluate the ability ]

l of. organizations to respond as called for in the plan. I The critique shall be conducted as soon as practicable I after the exercise, and a formal evaluation should '

result from the critique.

AIAAA 21 Review 1

These evaluation criteria address exercise-related i requirements and their evaluation by Regional Assistance  !

Committee CRAC) staff. In addition to identifying capabilities for evacuating students or effecting early l dismissal as a " major element" of an organization's emergency response plan, suggestions are provided for conducting  ;

interviews with officials f rom schools during an exercise. I

• These provisions conform to the revision of evaluation crit erion N.1.b. of NUREG-0654/TEMA-REP-1 promulgated in GM'PR-1, Policy on NUREG-0654/TEMA-REP-1 and 44 CTR 350 Periodic Requirements, l

___--_--___--___--_O

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OY } lld y Acceetanet_ criteria -

Requirements-are set f orth in TEMA (44 L CFR 350.9) and NRC (*: .

072 50, Appendix E.IV.E.1-5.) rules for conducting periodi:

exe;cises and drills. "Jeder these.requiremen:s, organizations with assigned responsibilities for protect ng students are re ';

' ability to implquired ementtoemergency demonstra:e chroughcontained procedures exercises in,their  : heir -

emergency response ' plans. However, the public (e.g., . school children) are not required to participate in exercises.

Further, the actual use of ~ school vehicles 'is optional. The i demonstration of .each ceganization's capability to implemen:

these . measures in exercises will be evaluated by TEMA and other ' rederal of ficials.

The following functions should be demonstrated and evaluated in' exercises in which the evacuation of students is necessitated by events in the exercise scenario:

1. Alerting'and notification of appropriate school officials by. local emergency officials'with. respect to status of radiological emergency and need to implement protective '

actions, including evacuation;

2. The contacting and notification of dispatchers and school bus drivers, as appropriate, to inform them of any potential or actual .need Joe them to transport students i and '

3. The provision of information to the parents and guardians, as appropriate, concerning the status and intended' location or destination of the students.

With respect to simulating the evacuation of school children in an exercise, the following guidelines are provided.  ;

)

1. At the discretion of school officials, the bus driver may i proceed to drive a school bus to a relocation center, as necessitated by the simulated ~ exercise events.

2. An exercise evaluator will interview the relevan't personnel at the IOC's, the School superintendent's .

)

office, the School Principal's office, .and the - l Dispatcher's office, as well as the bus driver to determine their awareness of and preparedness for the

' evacuation of the school children. Pertinent questions

~

for the exercise evaluator pertaining to the dispatcher and bus driver include:.

Nereenev ceeratiens center m - m one or more IOC's may be involved in decisionmaking to effect the evacuation of schools. For example,-in some States, local school evacuation must be coordinated wi:n

- ~-

.. ja y jg State officials. In such cases, observers may need to concurrently evaluate evacuation or other protective action decisionmaking in both state and local ECC's.

1.

Nho made the decision for evacuation or Ocher protective action of schools and when?

2. What specific actions (evacuation, early dismissal Or shelter) are incorporated in the decision and what specific sectors / schools are impacted by this decision?

3. When and f rom whom did the ECC receive infor a:1:n about this decision?

4. When and whom did the ECC staff contact to implement this decision?

\

5. Did ECC staff undertake actions to assist school evacuation or other protective action such as securing guides, buses and assistance in traffic control?

School Superintendent's Office '

1. When and from whom did the superintendent receive protective action instructions or recommendations?  ;

What specific instructions or recommendations did the superintendent receive? .

2. What actions did the superintendent take to implement these instructions or recommendations? Nhom did the superintendent contact and when?

School Princieal's office ,

1. When and from whom did the principal receive protective action instructions? Uhat specific instructions did the principal receive?

2. What means of communications (e.g., telephone, tone alert) were used to provide these instructions? Did this means of communication function adequately to provide accurate and timely information?

3. What actions did the principal take to imple=ent these instructions? Whom did the principal contact and when?

Discatcher

1. When and from whom did the dispatcher receive the instructions? What specific instructions were received?

1

=

l .

2. (*ha: teans of coccunications were used? ' Tere :ne communications between :ne dispat:ner and his/her supervisce and :he dispctener and the cus  ;

driver adequate to convey appropriate and :imely '

information?

4. When did the dispatcher initiate notification to bus drivers and guides :o i=plecent the evacuation or other protective action plan? What specific instructions were provided by the dispatcher?' How long did it :ake to con:ac the bus driver :o give the order :o evacuate?

ggg Drivers /cuides f 1. When and from whom did the ' bus drivers and guides receive instructions? Nhat instructions were received? .

. 2. *.' hen did the driver arrive at the school?

3. Did :he driver have an adequate map or knowledge of

, the route?

i

4. Uas the driver aware of any agreement between the drivers and local authori:ies for them'to provide their services in the event of a'radiologi. cal emergency ?

5. What means of communications were used? Uere communications with the dispatcher adequate :o convey appropriate.and timely infor=ation?

6. Did the exercise play necessitate a change in instructions to bus drivers and guides? If so, wha:

were. these new instructions? What means of communications were used to contactLthe bus drivers and guides? Mas this means of communication adequate?

Sadiation f*enitorine g Protection M ggg Drivers and Guidas ils desienared emereene'r-werkers)

1. Nere bus drivers and guides provided with specific means for radiation =enitoring (e.g., dosimeters and film badges) and exposure control (e.g., potassium iodide, respiratory protection)?.

2. Mere bus drivers and guides : rained in "he proper use

. of these instruments and materials?

i

3. Mere instructions provided to the bus dr' vers and guides for :ne autneri:acion and use of p.'eassium iodide? l s'

~

?? ] /U .

4. Curing the exercise, were instructicas given to al:er evacuation /early dismissal routes in order to aver:

radiation exposure by bus drivers and guides?-

1 Releestien caneers/Maichberheeds .(f2: M dis- i mi i-

1. When did the buses arrive at the relocation-cent er (s.) /neighbo rhood (s ) ? >

2.- According to the. exercise scenario events, did the '

bus drivers go.to the appropriate relocation centers / neighborhoods? . Did they arrive in a :imely 3 manner to avert radiation exposure?-  !

Previmien 21 Emereenev Instructions 12 Parents and cuardiggg 1.. Was information provided to parents and guardians on j the location of students, e . g. ,. relocation centers, i early dismissal to residences or sheltering? When i was this information provided?  !

+

2. What means (e.g., Ess messages and telephones) were '

used to provide this infor=ation?

3. Was this information provided in a timely and i accurate manner according co the exercise scenario events?

In some cases, answers to the above questions will' be secured f rom direct observation of the simulated evacuation, thus

' obviating the interviews.

sencial considerations jag imelementine Protective Actions In addition to the guidance above on school evacuation,.the following special considerations are provided for use when implementing other protective actions.

. gagig preenraterv Measures. In order,to facilitateLehe implementation of protective actions, . the fellowing measures should be considered:

1

a. Inventory resources' f or mobilization; e.g.,- school "

buses and drivers.

b. Curtail extramural or extra curricular activities so that school. children are available for. prompt evacuation, if it becomes necessary.

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c. Select the method (e.g., E35) and the draft message to notify parents and guardians of the status or destination of their childrenLif it becomes necessary to take protectiv.e actions.

d. Assure that the relocation center is availa'ble in the event evacuation is necessary.

IAIl2 IZieuation. Early evacuation is accelerating the implementation of protective actions for school children prior to the activation of protective actions for the general public. For example, if a plan calls for an evacuation of the public at the " General Emergency" level, then protectree actions for school children would be. initiated at the "si: $

Area Emergency" level. In the event of a rapidly )

l deteriorating situation,. school children would be evacuate i simultaneously.with the general public. '

, Iay12 Dismissal. While early dismissal of school children :s not addressed as an evacuation option per se in NUREG-0654/TE :A-REP-1, it is incorporated in. this GM as a method f or ac:omplishing the intent of evaluttien criteria under planning standard J because of its use for other types of emergencies such as imminent natural hazards (e.g.,

snowstorms). Hazards such as a school fire or boiler failure l have a limited hazardous area, unlike an extended l

radiological plume; therefore, the early dismissal of  ;

students to their parents and guardians may be prudent. The greater area affected by severe weather, such as a blizzard, usually does not jeopardize the health and Jafety of the school children if they are dismissed early before the storm or remain sheltered in the school. In contrast, the radiological plume may make.both the school an: home undesirable -shelters if both are in the plume < :posure pathway, or if a fast moving event could escalate to while the children were in transit. 'rurther, in the presence of vnstabla meteorological conditions it is difficult to project the mC7ement of radiological releasas.. Therefore, the uni:ue characteristics of a radiological. emergency place limits on the use of early dismissal as a viable protective action, particularly in heavily populated areas.

I2 ASEA h combined M Ia;'2, Disminnal. Early dismissal used.in conjunction with evacuation as described above provides another option. The school children who reside 'in a-sector of the ten-mile EPZ not effected by the potential danger or outside the ten-mile EPZ could be dismissed early to their parents, guardians or other supervision while those students whose homes are potentially in the path of a i radioactive plume would be evacuated to designated relocati:n  !

centers. I i

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shel eri.9e. Under certain circumstances shel:ering may be

he pre"f erred protective actica (e.g., when there are hazardous read condi:10ns or the possibili:y exists that evacuation may result in ::ansporting students :hrough :ne pla=e). Sheltering may be used as a primary 0: :empors:y protective action depending upon the characteristics of the ,

radiological release and the status of weather and : cad conditions.

GM EV-2 is issued subsequen: to review and concurrence by NRC staff who have determined that it provides clarification and interpretation of existing NUREG-0654/ FEMA-REP-1 criteria applicable : p:::ective actions fe: *special populations."

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SAU e16 PUBLIC SCHOOL TRANSPORTATION REQUIREMENTS i

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4 Vol, 4 - 188-6 Rev. 2 2/88 w_________- __ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ __ ._ _.

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i

ATTACHMENT 5 SPECIAL FACILITIES -

EMERGENCY RESPONSE PLAN PORTSMCUTH SENIOR HIGH SCHOOL (Grades 9-12)

Alumni Drive Pcrtsmouth, NH 03801 Telephone No: '

l David Matthews, Principal 2 I. PURPOSE This plan describes the preparation and protective response required by Pcrtsmouth Senior High School to react to an emergency condition at Seabrock Station Nuclear Power Plant. This plan is contained in Appendix F to the City of Pcrtsmouth Radiological Emergency Response Plan, which may be referred ta for additional information.

II. EMERGENCY PREPAREDNESS RESPONSIBILITIES A. The Superintendent of Schools has the following responsibilities:

t

1. The Superintendent is responsible for reviesing the bus needs prier to the start of each school year. The Superintendent will meet with the Principal and Public Works Directer to review bus needs.

2. The Superintendent is responsible for perfanning an ennual

~

review of this plan. Any needed corrections should be given to the Portsmouth Civil Oefense Director.

Vol. 21 F.2-1 Rev. 2 S/86

$y (j,;

O B.

The Principal of Pcrtfacuth Senior High School has the following responsibilities:

1. The Principal is responsible for maintaining a tone-activated radio in a location which will be continuously monitored l whiletheschoolisinsessIon. A preferred location would be the secretary's office.

2. The Principal is responsible for reviewing the bus needs l

prior to the start of each school year and reporting the I, results to the Superintendent. The Principal will attend a )

meeting with ths Superintendent and Public Works Director to discuss current needs.

h

3. The Principal is responsible for ensuring staff metters have copies of public inferrnation brochures and are familiar with emergency procedures to be used during sheltering and I evacuation.

q r ,

4. The Principal is responsible for attending energency response training classes, drills and exercises as requested by the t Superintendent.

5. The Principal is responsible fcr performing en annual review of this Plan. Any corrections should be given to the Superintendent. -

I i C. The Faculty and Support Staff of Portsmouth Senice High School nave I

l the following responsibility:

1. The Faculty and Staff are respcnsiole for attending energency response training classes, drills and exercises as requested l by the Principal.

Vol. 21 F.2-2 Rev. 2 8/8b

.g l

III. EMERGENCY RESPGNSE PROCEDUREd Note Time' -

A. Receive notification from thel Superintendent of 1 I

Schools via telephone of an'mergency declaration' and any pertinent infortnation. Provide the. student I attendance for the day. -

8. If the tone-activated radio is the first notifi-1 l

j cation of an sTiergency condition,'centact the I I

' Superintendent at- for further inferrnation.

The tone-activated radio norinally serves as back up 2 ]

1 notification and is automatically activated as part

.1 of'the public alerting systam.

]

C. Depending on the Emergency Classification Level, _

-]

take action as follows: .

l

1. UNUSUAL EVENT - No notification. No acticn h

required.

[-

2. ALERT - School will be notified. No action required unless directed. Stand Sy. 2

. Superintendent may recommend school cancellation via norTnal procedures as a precautionary f

measure.

Vol. 21 F.2-3 Rev. 2 8/86 .

i l

.. _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ - _ - _ _ - - _ - - J

Sb lI4

, Note Time

3. SITE AREA EMERGENCY cr GEf1ERAL EMERGENCY

a. School in Session. Sencol will be noti-fied and may be directed to undertake a protective response such.,as early dis-missal, sheltering or evacuation.

b. School Not in Session. .The Principal j l will be notified. The Superintendent of l l

. Schools will detennine if school should  !

be cancelled as a precautionary measure and notify.the Principal.

2 D. Turn on AM/FM radio' to WOKO (97.5 FM) . (If reception l is poor, tune to one.of the additional stations listed in Appendix A.) Additional infonnation may. then b's obtained through messages over tha Emergency Broadcast System (if activated). ,

E. Sheltering . If Portsmouth, the Superintendent or the Emergency Broadcast System recor@ ends sheltering,,

then:

i

1. Close all windows and decrs.- l i

)

2. Turn off all ventilation systans using outside air (i.e., fans, air conditioning, etc.).

3. Remain indoors. The sheltering area has been designated in the classrooms. (The gyrnnasium could be used if the situation ' warrants.)

l 2 i Vol; 21 F.2-4 Rev.'2 S/86 1

- ~

g g,g O

Note Time 4

Await further instructions from Portsmouth, the Superintendent or the Emergency Broadcast Systan.

F. Evacuation. If Portsmouth, the Superintendent or the Emergency Broadcast Systen reconynends evacuation, then: -

The Superintendent shall:

1. Ensure transportation services have been obtained by Portsmouth for the school and will be sufficient for school evacuation. Obtain the number and capacity of transportation and expected time of arrival.

The Principal shall:

1. Verify with the School Superintendent that i

transportation services have been contacted by Portsmouth. Determine the time of arrival and ensure the capacity is adequate.

2. Instruct students and faculty via the public address systen to apsenble in the gynnasium.

3. Ensure that all students are transported to the Reception Center at the Spaulding High School in the host co d nity of Rochester, New Hanpshire, where they may be picked up by their parents / legal guardians. Assign one faculty msnber to accompany each bus.

Students may be released to parents / legal guardians if they arrive prior to bus boarding.

Vol. 21 F.2-5 Rev. 2 9/86

5fjlK

' \

Note Time

'4 Assign faculty members to supervise the students until they are picked up at the Reception Center by their parents / legal guardians or until relieved by other personnel.

2 Tno Faculty shall: .

1. Account for all students prior to boarding buses.

2. Accompany students to the buses and ensure that students beard them in an orderly fashicn.

3. Supervise students in the Reception Center until they are picked up by their parents / legal gu Tjians or until relieved by other personnel.

l The Support Staff shall:

1. Ensure that the building is secured before i1 leaving.

G. Prior to sheltering or evacuation the schools may 1 1

be closed by the Superintendent in anticipation of  !

the escalating emergency condition. In this case i k

students may be transported home via the normal

~

method.

l Vol. 21 F.2-6 Rev. 2 8/86

se g In}

e IV. CONTACTS

_ Telephone Title / Agency Name Office Hone -

Superintendent-of Timothy'Monahan

^

Schools -

-l Portsmouth Civil Defei - Paul Famulari.

Director i

l Portsmouth Public Works- Dan Ayer j Director Portsmouth. Emergency Operations CenterJ i (Central Fire Station) -

l I

tl l

Vol. 21 F.2-7 Rev.'2 8/B5 l

i

______.___.._.._.m.._..

b[ b Portsmouth Senior High School to Spaulding High School (Raception Center)

% ,8 it fw

\/s 1 f SPAULDING Mica sc>oot

= m.4

• A

• • = = ?$ ^/'

h9 .

7+ %,

4 <a

% t&4 8 j 91 Exit school grounds on Alu::Ini Dr. Right 's onto Rt. I North (Lafayette Rd.) . Follow ,,,

across Memorial Bridge. Exit onto Rt. 236 ] )

North. Exit onto Rt. 9 South. Follow to 4 ,

)

Rt. 16A North (merges with Rt. 16 Norch). 54 !

High School is on left after Chestnut Hill  % n,, ,

Rd split.

/ --

, i'

% t/ev,

% ,a, j

i 1  ! i 1 \

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vol. 21 F.2-8 Rev. 2 e/86

_+

6/ f /0 SPECIAL FACIL'ITIES EMERGENCY RESPONSE PLAN HAMPTON FALLS CHILO CARE CENTER 98 Lafayette Road, Hampton Falls, NH .03844 Telephone-Not a Larry Ford, Director-Hours 6:30 - 5:30 m l2 -

l I. PURPOSE l

l This plan describes the preparation and protective response required by J

l HaTpton Falls Child Care Center to react to an energency condition at Seabrook

)

Station Nuclear Power Plant. ' This plan is contained in Appendix F to the Town of Hampton Falls Radiological Emergency Response Plan, which may be referred.

to for additional infonnatiori.

II. EMERGENCY PREPARE 0 NESS RESPONSIBILITIES j

(,

k A. The Director has the following responsibilities:

i

1. The Director is responsible for maintaining a tone-activated radio in a location which will be continuously monitored while school is in session.

2. The Director is responsible for reviewing transportation needs prior to the start of each school year. The Director l

will meet with the Hampton Falls Transportation Coordinator to review transportation needs. .

l

3. The Director is responsible for ensuring staff members have copies of public information materials and are faniliar with l2 emergency procedures to be used during sheltering and evacuation. .

Vol. 17 F.4-1 Rev. 2 8/86 i

-_--__-_- _ ___ l

60 rg it,d

4. The Director is responsible for, attending ernergency respense training classes, drills and exercises as requested by the i

Civil Cefense Director.

1

5. The Dimetor is responsible for conducting an annual review of this plan. Any corrections should be given to the Civil Defense Director.

B. The Staff has the following responsibility:

1. The Staff is responsible for attending snergency respcnse training classes, drills and exercises as requested by the Director. ,

III. EMERGENCY RESPONSE PROCEDURES l

Note Time l A. Receive notification frcrn the Hampton Falls  ;

Transportation Coordinator via telephone of an emer-gency declaration and any pertinent information.

Provide the student attendance for the day. A call dll also be made by the NH Civision of Public Health Services. l2

8. If the tone-activated radio is the first notifi- l cation of en emer-~,cy condition, contact the l Transportation Coce finator at for further information. The tche-activated radio ncrmally serves as back-up notification and is autcrnatically ,ctivated as part of the public alerting system.

C. Cepending en the Emergency Classification Level, take action as follows:

1 Vol. 17 F.4-2 Rev. 2 8/86

"; ~

,7 ,

f3 /

, , ."j Note Time 1

1.. l UNUSUAL' EVENT' - No notification. No action.- j requi' red.

2. ALERT - School may bel. notified. No' action }

. required unless directed. - Stand By.

3. SITE AREA EMERGENCY or CENERAL' EMERGENCY . School'.

dll be notified and may be directed to-undettake

' a protective response such as early' dismissal,  :;

i < sheltering er evacuation. l l .-l

.I L D. Turn on AM/FM radio to WOKO (97.5 FM) . (If reception '

=

is poor, tune to one cf the additional stations listed;  ;

in Appendix A.) Additional inforTnation may'then , : ei be obtained through messages-over the Emergency j Broadcast System -(if activated) . fj

=q E. Sheltering.- ~ If the Emergency * 'cadcast System announces '{.-

I that sheltering has been reconinended, then: .-!

t

.]

1

1. Close all Mndows and doors.

)

2. Turn off all ventilation systems using outside air (i.e., fans, air conditioning, etc.) .

3. Rernain indoors.

I i i

1 i

Vol. 17 F.4-3 Rev. 2 8/86

-;gg -g Not'e Time-

.4 Await further instructions 'over the Emergency-Broadcast' System. .I

-x .i --

.]

F. LEvacuation. If' the Emergency. Broadcast ' Systern announces that evacuation has been rectrrmended, then the Director shall: ,

. . j

1. Account for all' children .present and ensure that' -

all. students are transported to the Reception '

Center at.the Cover.High School in'the host-

]

t cormunity of Dover, New Hampshire, sere they may be piched up -by their parents / legal guardians.'

Assign a staff member .for each. vehicle used. 1 Children may be released. to parents / legal guar .

diais if they, arrive -icr to' vehicle boarding. I

2. If a transportation service .is to be used, 1 verify that they' have been contacted by the 1 Hampton Falls' Transportation Cecrdinator .). *I l

Cbtain the expected time cf arrival and ~ ensure the capacity is adequate.

3. Ensure that the building 'is secured before leaving.

l Vol. 17 F.4-4 Rev. 2 8/8E l

M y ][

IV. CONTACTS .

Telephone Title / Agency Name Office Hcrne Hanpton Falls Civil Cefense Kenneth A11eri  ;

Director Harnpton Falls ,

Transportation Cecrdinator i H ten Falls Fire Station  !

l ergency Operations enter) j l

i i l i

l l

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1 i

l l t l l

l i

Vol. 17 F.4-5 Rev. 2 8/86 1

\

l

__________________w

b6 l( i.

~

.p Hampton Falls Child Care Center

• to At{08 Dover High School (Reception Center) soeuens 7

{

art Dover High School l i

A' 58 M Right out of Child Care Center onto

'+ Rt. 1 South. Right onto Rt. 88 Nest (Exeter Rd. becomes Hampton Falls Rd.).

% Left onto Rt. 101-C West (Hampton Rd.).

Right onto Rt. 108 North. Exit onto

. / Alumni Rd. High School is on the right l

teT l

l Rt 108 l

f Rt. , 2

, i, ,,

1. 4 \

k "ke U"nker Hin st 1 -

1 /

Rte 10 th mh Rte)IS *'*^Hampton h@

n_ m m Expressway Rte 111 A f

Rtg111 g

Rt 08 4 Hampton Fahs I Child Care C nter ,3 Ate 88 \

1 15 e k

- 't' Rte so- . (eg k k i 1

Vol. 17 '

Rev. 2

- 8/86 {

i

v 69 t)9 lON SPECIAL FACILITIES EMERCENCY RESPONSE PLAN SACRED HEART SCHOOL (Private, Grades 1-8)

Lafayette Road, Hampton, NH 03642 1 Telephone No: l Margaret O'Donoghue, Principal

{2 g i

I. PURPOSE h

This plan describes the preparation and protective response required by I Sacred Heart School to react to an emergency condition at Seabrook Station l Nuclear Power Plant. This plan is contained in Appendix F to the Town of  !

Hamaton Radiological Emergency Response Plan, which may be referred to for j l additional information. 1 II. _ EMERGENCY PREPAREDNESS RESPONSIBILITIES <

I l A. The Principal has the following responsibilities: 1 l

J

1. The Principal is responsible for maintaining a tone-activated l i

radio in a location which will be continuously monitored while j l school is in session. 1

2. The Principal is responsible for reviewing transportation needs prior to the start of each school year. The Principal will meet with the Hampton Public Works Director to review t transportation needs.

3. The Principal is responsible for ensuring staff members have copies of public infonnation materials and are fatiiliar with

(

f anergency procedures to be used during sheltering and ,

i evacuation. t i

I i

1 Vol. 18 F.5-1 Rev. 2 S/86  ;

i j

l l

, g

4. The Principal is_ responsible for attending emergency response l t

training classes, drills and exercises as requested by tne Hampton Civil Defense Director.

)

5. The Principal is responsible for perforTning an annual review of this plan. Any corrections should be given to the Civil' l Defense Director.

B. The Staff has the following responsibilities:

1. The Staff is responsible for attending emergency response training classes., drills and_ exercises as requested by the Principal. 1 III. EMERGENCY RESPONSE PROCEDURES _

Note' Time A. Receive notification from the Hampton Public Works Director via telephone of an emergency declaration and any pertinent infortnation. Provide the student attendance for the day.

j B. If the tone-activated radio is the first notification of an emergency condition, contact the Hampton Public Works Director for further information. The tone-activated radio normally 1 serves as back-up notification is automatically activated as part of the public and alerting systen. -)

A call will also be made by the Superintendent.

l2 I

C. Depending on the Emergency Classification Level, -l 1

take action as follows:

1. UNUSUAL EVENT - No notification. No action required.

Vol. 18 F.5-2 Rev. 2 8/86 i

1 1

)

(,qi/bcI o

Note Time

2. ALERT - School will be notified. No action - l 2'.

required unless directed. Stand 9y. The I

Superintendent of Schools will not 'j the-school if he orders public school canci.llation or early dismissal as a precautionary measure.

-3. SITE AREA EMERGENCY or GENERAL EMERGENCY - School will be notified and may be directed to undertake a protective response such as early dismissal, .

Sheltering or evacuation. The Superintendent will notify the' school if he orders public school cancellation or early dismissal as a precautionary measure.

O. Turn on AM/FM radio to WOKQ (97.5 FM). (If reception is poor, tune to one of the additional stations listed in Appendix A.)- Additional information may then be obtained through messages over the Emergency Broadcast System (if activated).

i E. Sheltering. If the Emergency Broadcast System announces l that sheltering has been recanTnended, then: 1

1. Close all windows and doors.

2. Turn off all ventilation systers using outside air (i.e., Fans, air conditioning, etc.).

3. Wemain indoors. The auditoritsn is the designated sheltering area for Sacred Heart School. 2 Vol. 18 F.5-3 Rev. 2 8/86

9 Note Time

4. ]

Await further instructions over the Emergency.  !

Sroadcast System.

F. Evacuation. ~ If the Energency Broadcast System announces. l that evacuation has been reccmnended, thens.

The Principal shells l'

1. .If a transportation servire is to be used, ensure-that it has been contacted by the Hampton Public Works Director. Obtain the expected time df arrival and ensure capacity will be adequate. I

2. Ensure that all students are transported to the i Reception Center at the Dover High School l1 in the host ecmnunity of Dover, New Hampshire, where they may be picked up by their parents /

legal guardians. Assign one staff menter to accompany each bus. Students may be released l2 to parents / legal guardiens if they arrive prior to bus boarding.

3. Assign a staff member (s) . to remain with students until they are picked up at the Reception Center by parents / legal guardians or until relieved.

by other personnel. 2 4

4 Ensure that the building is secured before leaving.

I-l 5

Vol. 18 F.5-4 Rev. 2 8/85 l

?)] IO TJote Time The Faculty shall:

1. Account for all students prior to boarding buses.

2. Acccmpany students to the buses and ensure that students board them in an orderly fashion.

3. Supervise students in the Reception Centeg j

until they are picked up by their parents /

l legal guardians or until relieved by other personnel.

2 l l

1 i

1 l

l l i

l 1

Vol. 18 F.5-5 Rev. 2 8/66

93 jQq IV. C0fjTACTS Telephone Title / Agency flame Office Home Superintendent of florman C. Katner School Administrative Union 21 Hampton Civil Defense Philip Richartis j Director l 1 l l Hampton Public Works John Hangen '

l2 l Oirector l

Hanpton Fire Department Station #2 (Emery,ency j Operations Center) 4

. l l

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1 l

l l

l l

l l

1 Vol. 18 F.5-6 Rev. 2 8/86

}3 /A Sacred Heart School (Hampton) l to l Dover High School (Reception Center) p9 1

~

Dover

,, H' School 2

2

%4 pe 108 '4

/

l95 F te 1 I

i Right onto Rt, 1 North (Lafayette Rd,)i Left  !

onto Rt. 101 C-West (Exeter Rd.). Follow to }

Rt. 51 West. Enter I-95 North. Exit onto I Spaulding Tpk. North. Exit onto Rt. 108 South  !

(Durham Rd.). School is on right.

i 4 l l

101C Sg i

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~

Sacred

\ h*

og

\ Schoo Heart ,

W

e1 -

l l O l Vol. 18 F.5-7 Rev. 2 08/86 l

l

m

//d ATTACHMENT 6 l

January 9, 1989 i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the

]

ATOMIC SAFETY AND LICENSING BOARD 1

) l In the Matter of ) l l

)

PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL

) (off-Site Emergency (Seabrook Station, Units 1 and 2) ) Planning Issues)

)

) l APPLICANTS' VOLUNTARY RESPONSES TO TCH'S INFORMAL DISCOVERY REQUESTS on December 23, 1988, the Town of Hampton ("TOH") served i l

its First Set of Interrogatories and Request for the J

Production of Documents to the Appl %>.7ts on the June 2'8-29, 1988 Exercise. Applicants volunteAr he following responses.

As To Instructions For Usa l l

All exercise-related documents that Applicants retained after the exercise are already available and have been since I September 29, 1988, and many of then since July, 1988.

Appb.r. ants identify herein the documents produced by a cummary description. The burden and expen.:e of " identifying"

m

?f//GO 1

by TCH's definition each document produced would be excessive and or justified in the circumstances. l l

As To Soecific Reauests Interrocatorv No. 1 Identify all teachers who performed or participated in protective actions for school children during the Exercise.

For each, state:

(a) The nature and extent of the participation or function performed:  !

(b) ThA purpose of the performance or l participation:

l (c) The school (s) for which each teacher performed  !

or participated:  ;

, (d) The section(s) of the NHRERP tested or j exercised (e) Whether in Applicants' opinion the performance

, or participation was adequate, and the basis for that opinion:

1 (f) Whether a log, record, or other documentation concerning the Exercise participation was prepared by or on behalf of each teacher; (g) Identify and produce all documents upon which you rely to answer this interrogatory.

Aeolicants' Resoonse To Applicants' knowledge, no teachers participated in demonstrating protective actions for school children during the Exercise as schools were not in session.

Interrgorv No. 2 Identify all administrators and school personnel other than teachers who performed or participated in protective actions for school children during the Exercise. For each, state:

1 .

W_________-__-_-___. __ _ - - - - -- -

v --

. 4

}6 l l&

i (a) The nature and extent of the participation or function performed;

)

(b) The purpose of the performance or participatish; (c) The school (s) for which each administrator and j school personnel performed or participated)

(d) The.section(s) of the NHRIRP tested or exercisedt (e) Whether in Applicants' opinion the performance or participation was adequate, and the basis for that opinion; (f) Whether a log, record, or other documentation i concerning the Exercise participation was prepared by or on I behalf of each administrator and school personnelt (g) Identify and produce all documents upon which you rely to answer this interrogatory.

Aeolicants' Resoonse (a) Identification of persons participating in the Exercise cannot be made in the form requested because the i,nformation is not available to the Applicante. Based on a review of existing player and controller materials generated during the graded exercies, at least one administrative representative of each of the five Supervisory Administrative IJnits and an administrative repr-esentative of the Phillips Exeter Academy participated in the exercise. Applicants are unaware of the identities of these personnel with the exception of George Tucker, Dean of raculty, Phillips Exeter Academy. The administrative representatives received at l

L____________________. _ _ _ _ _ _ _

~

I'0 llfb] l i I l least one telechone call from New Hampshire emergency _ respo,nse personnel during the exercise. (b) The purpose of this participation was to demonstrate the capability to notify school administrative personnel of emergency conditions; to demonstrate the ) l capability to convey precautionary or protective action

                                                                                                                           ]

decisions to schools; and to demonstrate the capability to determine transpo~tation resource requirements of the - schools. j l (c) (1) SAU 16 i

                                                                            - Exeter High School
                                                                            - Exeter Junior High School
                                                                            - Lincoln St. Schcol                           j
                                                                            - Main St. Middle School
                                                                            - Region 18 Vocational School
                                                                            - Swasey Central School
                                                                            - Newfields Elementary School
                                                                            - Stracham Memorial School (2)  SAU 21
                                                                            - Winnacunnet High School
                                                                            - Academy Junior High School
                                                                            - Centre School
                                                                            - Marsten School
                                                                            - Seabrook Elementary School

U' l (3) Portsmouth Superintendent of Schools

                                                  - Portsmouth Senior High School
                                                  - Pertsmouth Elementary School
                                                  - Brackett Elementary School                ]
                                                  - Sherburne Elementary School                !
                                                  - Dondero Elementary School
                                                 - Little Harbor Elementary School
                                                 - New Franklin Elementary School
                                               .                                               I
                                                 - Wentworth Elementary School                 l (4)    SAU 17                                        l
                                                 - Sanborn Regional Middle School
                                                 - Newton Memorial Schtol
                                                 - Sanborn Regional High School                !
                                                 - Bakie School l

(5) SAU 50

                                                 - Greenland Central School i
                                                 - Rye Elementary l
                                                 - Rye Junior High School (6)     Phillips Exeter Academy, George Tucker, Dean of Faculty (No further identification available).

l (d) Volume 4.B. State Agency Procedures

                                         - Department of Education - Emergency Response Procedures

Pi g /L-

                                                             - Director of Pupil Transportation Safety -

Emergency Response Procedures NHRERP Town Specific Volumes

                                                            - Section II, Emergency Response Functions s
                                                            - Section III, Emergency Preparedness Responsibilities
                                                           - Section IV, Emergency Procedures
                                                           - Transportation Coordinator's Procedure
                                                           - Appendix F, Special Facilities Plans (e)

As the Exercise Report for the June 1988 FEMA graded Exercise states, "The State of New Hampshire demonstrated the ability and resottrees necessary to implement Protective Actions for school children." (p. 172) (f) As far as can be determined, no log was kept by or on behalf of administrator and school personnsl. (g) Occumentation is contained in the following documents which have been made available to the parties: (1) New Hampshire Radiological Response Plan (2) FEMA Exercise Report - Seabrook Station 1988 Graded Exercise (3) Participating local Emergency Operations center Logs (4) Controller Reports for the participating towns

   ~

T2) lbb' (5) Controller Reports and participant logs for the State Emergency operations Center and Incident Field oggie, 1 l i l I t l i l i 4 l f 1 1

                                                                               \

__j

p~ w-g l l l k i

                                                                                       \

i l i Interrogatory No. 5 For each school in the New Hampshire EPZ, identify all communications during the Exercise between teachers or other school personnel and the State of New Hampshire, its agents or contractors, concerning protective actions for school children. With respect to each communication: (a)

                                                                                        )

Identify thc person making the communications I (b) The method of communication; (c) Time: (3) Purpose; l l l l 1 l ______-_ _ ____ - --_ O

gn ' ' ' ' ' ' (e) Recipient;

                                                       ~

(f) Response; (g) Any actions taken as a result of the communication; and (h) Identify and produce all documents upon which you rely to answer this interrogatory. Acclicants' Reneense Identification of persons in the context of this interrogatory gannot be made in the form rsquested because the information is not available to the Applicants. A list of communications by New Hampshire emergency response personnel pertaining to protective actions for school children is attached as Attachment 1. Documents relied upon to answer this interrogatory have been made available. 4... .ii

I I w % Ce a 3 F E D T S t e c . . I e e T m n c o e A l I B s h e S r l B e U i P ce S . E e d C m e e B W a'I f s d d . . s r a e B E I e E e M e I r f f I

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M 3 /M i t%R 20 '89 17:04 POPE 5 & GPAY ropes - & G R AY ONE INTERNATIONAL PLACE BOSTON. MASSACH USETTS O211o-2624 30 erwice s.4:4 omovicgNCE, m, , cig3 3 .:6m sci 7oce 0 0' '8"s emwin av s s,s. * * (dCJ 62. 6400 wasm NotON.O. 0 20004 9 51- W O

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                                                                                                                                      *ELEcos'E4. flot; 626 394.

t March 20, 1985 Mr. Matthew Brock, Esq. Office of the Massachusetts Attorney General Nuclear safety Unit McCormack State office Bldg. One Ashburton Place, Boston 02108-1698 l Re: warification of Applicants' Voluntary Responses to T0H's Informal Discovery Requests (January 9, 1989)

Dear Matt,

I am sending thi6 lwlL=r Lu campond to your letter dated today, in which you ask for clarif.Leation of Applicants Voluntary Responses To TOM's Informal Discovery Requests (dated Januar Responses"). y 9, 1989)[ hereinafter " Applicants' voluntary Applicants address your inquiries concerning Interrogatories have provided as 8 and 9 by responding to the paragraphs you follows: A. Applicants confirm that prior to the date of the Exercise, Applicants or their agents contracted with 3 bus companies to provide all of the buses and drivers that would participate in the Exercise. The bus companies that agreed to provide these transportation resources, and the number of buses each company agreed to provide for the Exercise, are identified in Applicants' Response to Interrogatory 8(d). . } B. Applicants confirm that prior to the date of the } Exercise, Applicants or their agents also contracted with two ambulance companies to provide all of the ambulances and artulance drivers who would participate in the Exercise.  ! These ambulance companies and drivers are identified in Applicants' Supplemental 27, 1989. Response to Interrogatory 8(f), dated January

c. Applicants confirm that during the Exercise each of these l

bus and ambulance companies provided vehicles and drivers in compliance with the contracts described above. i _________.--L----------

t%P 20 '99 17:05 P0FE3 5 'IEN \ Ropro & GaAy Mr. Matthew Brock, Esq. March 20, 1989 You have also asked for clarification on whether the phone calls numbered 10 through 14 and listed on page 2 of Attachment 1 of Applicants' Voluntary Responses were actually made. Applicants to numbers 10, 11, state that the telephone calls listed next 12, and 14 were simulated. Within the EOC, individuals assigned to notify the listed schools r,ade phone calls, and data supplied by controllers was received. To the best of Applicants' knowledge, and based on an inspection of Exercise Records, the calls listed next to-number 13 were actually made to school personnel. believe the reci',_snt of the call to the Swazy school wasApplicants Kids school was Joyce Gal,lant. principal Margaret Griffen, and c'he recip . I believe from speaking with you both today and last Monday questions. that the above information should take care of your

                                                                                                                   =

sincerely, { Geoffre C. Cook w J

3

                                                                      ?> g[t& & '

ATTACHMENT 7

            .                                          January 30, ;339 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Nuclear Regulatory Commission
                                      )

In tne Matter of ) Docket'Nos. 50-443-OL i

                                      )                      and PUBL:C SERVICE COMPANY OF        )

50-444-OL j NEW HAMPSHIRE ) (Off-Site Emergency  ; (Seaorook Station, Units 1 ) Planning Issues) a ?.d 2 ) l

                                     )

THE SJATE OF NEN HAMPSHIRE'S VOLUNTARY RESPONSES TO j THE TOWN OF HAMPTON'S INFORMAL DISCOVERY REQUESTS CONCERNING THE JUdE, 1988 JOINT EXERCISE t i H

                                                                                     \

l AS TO PRODUCTION OF DOCUMENTS 1 L All exercise-related documents retained by the State.of New l Hampsnire nave been availacle to all parties since July, 1988. Secause exercise-related documents also have been made availacle r,. tne Applicant at a single location, the New Hampshire Office of-Emergency Management transferred control logs and all other sia:e-documents relating to the Jane 1988 Exercise to tne same locatto. I:r convenience of the parties. This transfer occurred shortly after  : ..e Exercise. ( \ s

ANSWERS TO SPECIFIC OUES:::NS

interrogatory No. 1 Identify all teacners who performed or participated ;n S eacn, 3: ate:actions for scnool enildren during tne Exercise, protective For (a) The nature and extent of perf0rmed; ne participation or f;nct:3.-

(b) (c) The scnool(s) The purpose of the performance or participation; participated; for whien eacn teacher performed or (f) (e) The section(s) of the NHRERP tested or exercisec Whetner part;cipation was adequate, in the State's opinion the performance or; (f) and the basis for tnat opinion; Whether a log, record, or other documentation concerning eacn teacner;tne Exercise participation was prepared by or on behalf of (g) to answer tnis Identify and produce all documents upon which you rely interrogatory.

Response

To tne oest <now. edge of :ne State of New Hampsnice, no teacners participated in demonstrating protective actions for school cnildre.- during tne Exercise of the New Hampsnire Radiological Imergency Response Plan (" hereinafter "NHRERP Exercise" , as schools were .st in dession.

                                                                                  @1g //[

Interrogatory No. 2 ' Identify allLadministrators and secool personnel.etner tnan i' teacners who performed or participated in protective acti:ns for senoot children-during the Exercise. For eacn, state: (a) The nature and extent of the participation or fanctior! performed; (c). The purpose of the performance or participation; to) 1 personnel performed  :!he schoolls) for whicn each administrator anc'senool l or participated;. (d) The section(s) of ene_NHRERP tested or exercised: le) "hetner in tne State's og,nion.tne performance or participation was adequate, and the oasis for that opinion; (f) Whether a log, record, or other documentation- i concerning tne Exercise' participation eacn administrator and school personnel; was prepared by or on'oeh'alfLofj (g) :dentify and produce all documents upon which you rely l to answer ents inteerdgatory. Resconse a) The NHRERP 'ici;me 43, Department of Education (" DOE") 1 procedures, outline ene notification pathway for schools within the j EPt. i A listing of Oepartment of Education personnel is contained in } l Volume 4B, Attachment i of the NHRER'P. DOE personnel who 1 participated in ene exercise are listed in the exercise logs. Calls were made to each setool Supervisory Union. Superintendent. A listin7 i of SAU contacts is contained in Attachment 1 offthe DOE procedures wh;ca are located in Vol. 4B. All listed SAUs were contacted. The ' i State also incorporates and aoopts the Aeolicants' Voluntary Response- to TOH's Internal Discovery Request (hereinafter

       " Applicant's Response"),-Response 2(a), and concurs with information proviced therein.                                                                     i o)    The ' purpose of ene participation" was to demonstrate, for             -i

_ i purposes _of the NHRERP Exercise, the State's capability to notify l school ?ppervisory cersonnel. The State also incorporates and adopts j Applicants' Response ho. 2(b). c) (1) SAU 16 Exeter High School ' Exeter Junior Mich. School

1

                                                                                                                                                                                                   ,l
                                                                                                                                                                                                  )

Lincoln St. Scncol 1

                                '                                                                                                                                                                s l

Main St. Middle Scnool i Region la Vocational School

                                                                                                                     - Swasey Central Scncol Newfields Elementary Schoo!                                              "

Stratnam "emorial' School (2).SAU 21 Winn acu nt.e t Hi.gh Senool

                                                                                                                   - Academy Junior-High School Centre Scncol                                                            i Marsten School
                                                                                                                  - Seacroo< Elementary.Schoo'                                                     1 i

(3) Portsmoutn Superintendent of Schools Por: 5noutn Senior High School = Portsmouth I.'ementary School

                                                                                                                 - 3 racket: Elementary Scnool
                                                                                                                 - Shercurne_ Elementary School i
                                                                                                                 - Dondero Elementary Senool
                                                                                                               - Little Harbor Elementary School i
                                                                                                               - New Franklin Elementary School
                                                                                                              - Wentworth Elementary School (4)           SAU 17
                                                                                                              - Sanborn Regional Middle School q
                                                                                                              - Newton Memorial School                                                             '
                                                                                                              - Sancorr Regional High School
                                                                                                              - Bakie senool (5)          SAU 50                                                                      '

1 I l i i l _ _ _ . _ . _ _ _ .__._________j

9/ J / kG l u

                                                                                                                                                                                ]

Green; ant Central Senco. Rye Elementary Rye Junior Hign Scnool \ (6) Phi;1ips Exeter Academy, George Tucker, j { Dean of Faculty (No far:ner identification avai;ac;eJ.

                                                                                       ?rocedures d)     See:       Response to 2a) sucra.                                           i

n addition to ne er:ce:;resi

                                                                                       .'isted in Response No. 2a), NHRERP Section 2.6 was demonstrated, e)    As tne Exercise Report for         ne Jane lyd8 NHRERP Exerc;se             i i

states, "The State of New Hampsnire demonstrated :ne aoility and  ! resources necesaary :o ;mpienen: Protec:ive Actions for school enildren." See: F E M. A Exer::se Report, Septemoer 1, 1988, p. 172.

) The State of Mew Hampshire is aware of no logs otner than

nose completed cy :ne , Department of Education represen:ative a: me State IOC. Tnese_ 10gs are available to all parties at tne sa..e

_location as materials made available for discovery oy tne Appi; car .  ! g)

                                                                                                                                                                     ~

l Documentat;on is contained in :ne following documents sn.:r o. l mave oeen made availaole to tne parties at tne same .oca: ion as : s- > t documents voluntarily produced by the Applicant:  ! (1) New Hampshire Radiological Response Plan I i (2) FEMA Exercise Report - Seabrook Station 1988 Graded l Exercise i 4 (3) Participating local Emergency Operations Center ' .: : _ > (4) Controller Reporys for tne participating towns l l i l

 ~
                                                                           /Gu
                                                                     %3 Interrogator'/ No. 5 Fot each schooi in the New Hampsnire EP:, ident.fy a;;

communications personnel and the durino State the-Exercise o' cet'aeeen teacners or s-aer se.- New Hameshir?, its agents or cont:ac 3:3,' concerning protective actions for school chi'dren. With rescect.to eacn communication: - (a)- Identity the person making the communication; (c) The metnod of communication; (c) Time . (c) Purpose;' (e) Recipient; i (f) Response; j (g) (n) Any actions taken as a rescit of tne communicator.s'and! to answer enis :dentify and produce all documents.apon which yo; :e;;" interrogatory. i Reseonse - i Communication and exercise logs of ne local liaisons at the :FCi l l and of the transportation coordinators at local ECC's,. as well as i \ these for tne :FO and State EOC, contain this information. These

                                                                               \

cocuments are currently available to the parties at ene same locat;;.- { as tnose documents voluntarily produced uy tne Applicant. The State also adopts and incorporates Attachment 1 of One Applicant's Response. 6

                                                                              -I I

l 1

                                                                              'l 1
                                                                                 )

I l i l 1 1

FROM StafE OF NM ( T H U )0 3.16. ' 9 9 08806 NO.1

               .f- v.y aso4:.

John P. Arnold THE STATE OF NEW HAMPSHIRE a "^ eh irsw c'W"m4x u"a an re?ramnuv rxnn

r m ern wtnnn a nAx m stw.)>>m.c s . . .,. a.uE : uvu.

s JD'EMY t k. 'n V3 4 sc:o. e e n, ,o r n.u ., m4s ? nt u.e & &

                                                                -.                                   .omx c.,, ,uya uy nm.u rc.sca

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                                                                                 .9y                 e wa. ,. m.. ux 1
                                                                       % i      j xtu st.y ANs r E RF.s :t M

w. r.anso,a KFVIN J M/ARTW THE ATTORNEYGENERAL [iM[j"; 7y.snrs.a  :

ENVIRONMENTAL PROTECTION BUREAU j STATE HOWE ANNEX l

                                                              & CAP;TOL STREET                                                  l CONCORD. NEW HA.s!PSHIF.E v3M1.M                                          f l
                                                                     .m . i n.
                                                                                                                                )

I i March 16, 1989  ! l Mr. Matthew Brock Assistant Attorney General Nuclear Safety Unit ) i Department of the Attorney General Commonwealth of Massachusetts John W. McCormick State office Building 1 Ashburton Place Boston, Massachusetts 02108-1698 Re: Clarification of June 1988 Exercise Matter i Dear Matti In further clarification of our. conversations, I offer the following with respect to the State's answer to Interrogatory #2 concerning the identity of administrators and school personnel who performed or participated in protective actions for school children during the June 1988 exercise of the NHRERP. ) In our response to Interrogatory #2,a., the State incorporated Attachment Discovery Request. 1 of the Applicants voluntary Response to TOH's Informal Attachment I contains a chart with the left hand column entitled " School" with 15 entries made below. You have asked whether the State of New Hampshire contacted and dealt with more individuals than are listed in our response to Interrogatory #2 which incorporates Attachment 1. no. The calls recorded by entry numbers 10, 11 and The answer is 12 of Attachment I were simulated. Telephone calls were placed to the school's listed by entry numbers 13 and 14, and contact was made to the individuals noted by the attachment. Understand that exercise controllers inserted data giving the number of students for a particular facility as is noted in Attachment 1 in the last j column as you read from left to right. l l

reon s'arr or 88 f4 f /bD l,

                                                           <tsu>es.ts.'s9 esi:7       80.1 Mr. Matthew Brock     '
                                                                                                        .l Ma rch 15, -1989                         4                                       ]

Page 2 l I have been assured that Attachment 1 is a' result of a thorough I examination of controller logs, and indicates all simulated and attempted contacts made to schools 'as part of the June 1988 exercise. Based on the foregoing, I am confident that the State's response to Interrogatory #2 is a comprehensive listing of all contacts made to school personnel as part of the June 1988 exercise. I trust this clarifies this issue for your purposes. Sincerely j [

                                                    .                           e~                        l Geoffrey M. Huntington Assistant Attorney General          i Attachments GMH/aml ec:    Geoffrey Smith, Esquire, Ropes & Grey                                     I t

ATTACHMENT 8 9f f /(,f 6

                                                                               )

l Re In the Matter of Public Service Company of N. H., et al (Seabrook Station. Units 1.& 2) DEPOSITION OF NORMAN KATNER 1 i I N D E X Interrogatories by Mr.' Brock 3 Signature page I 27 l i l I i I v

90 2 /&c 9 H

                                                                               'l UNITED STATES OF AMERICA                                ,

Nuclear Regulatory Commission Before the Atomic Safety & Licensing Board 1 Insthe Matter of Public Service Company.  : . of New Hampshire, et.al  : i (Seabrook Station Units 1'& 2)  : i DEPOSITION'OF NORMAN KATNER 1 Deposition taken by-subpoena and. 1 1 1 agreement of the parties at the law offices of Shaines & q l McEachern, 25 Maplewood' Avenue, Portsmouth, New Hampshire,'on j l Monday, March 13, 1989, commencing at 9:15.o' clock in the' fore-- - ) noon. 4

  --                                                                               l APPEARANCES:                           'q For the Commonwealth of Massa-chusetts Attorney General's Offico :     i
                                                                                .l Matthew Brock, Esq., Assistant
                                       -Attorney General Nuclear Safety Unit                        l One Ashburton Place Boston, Massachusetts 02108 i

For Public Service Company of l New Hampshire: Ropes & Gray 1 International Place Boston, Massachusetts 02110-by Geoffrey Cook, Esq.

                                                                                -t For the State of New Hampshire            i Attorney General's Office:               I v

l Geoffrey M. Huntington, Esq. I L Assistant Attorney General i

                                                                                        %9 /L. 6, o

Stenographer: Donald E. Lamont', CSR 25 Maplewood Avenue Portsmouth,'New Hampshire

                                     'It is-stipulated and agreed that:

the. deposition may'be taken in the first. instance'by-Stenograph and-later-when. transcribed may be'used as and for the deposition of the deponent for all' purposes insofar as competent. The reading and signing of the deposition by the deponent is expressly waived. v [ Deponent duly sworn by Mr. Lamont) INTERROGATORIES PROPOUNDED BY MR. BROCK: I, Norman Katner, on' oath, depose.and say.as follows: Q1 Would you state your name and address. A Norman Katner, 10 Blueberry Lane, Rye, New Hampshire, i I Q2 How are you employed? ' l A I'm employed by the School Administrative Unit ~ Number j 21 in Hampton. Q3 And how long have you had that' position? A July 1st, 1984. i Q4 And your job title is? A' Superintendent of Schools. Q5 Would you summarize the-responsibilities you have as

                                                 -,_.-..---___------.-----,---aa.--      a,--------

h or 1 /G & 1 ll superintendent for SAU 21. A Well, by law I'm the chief executive officer of the j six school districts that compose the School Admini-strative Unit. 1

06. Well, could you be a little more specific as to on a day by. day basis as superintendent what your j 4

responsibilities are via-a-vis these six schools that comprise the District?- $ 1 A well, it varies. If you've got'three thousand three I l hundred and fifty-nine children and five hundred and 1 twenty-nine employees and a twenty-one million budget it's going to vary on a day to day basis. l Some days it deals with personnel . Other day it deals with roof leaks, other days it deals with snow days. Today, for example, it deals i 1 with a luncheon at eleven-thirty to discuss what we're . going to do in the school district that lost a bond- i issue in South Hampton, do for the kids for next.. year, ' l l So it varies on a day to day basis. , 07 Who hired you as superintendent?' A The joint board of the School Administrative Unit Number 21. Q8 And you were hired in 19847 _ A '84, right.

491 /60 U ' 09- What are the responsibilities of the School Board, 1 as distinct from your own responsibilities, with respect to the schools within SAU 217 A .They hire.the superintendent, the assistant superin-u tendents. They establish.the,SAU budget. That's 1 about it.. 010 Who sets. policy for SAU 217 , l A The joint board.. I Q11 And you administer that policy?- ' A That policy plus the policies of the six other school districts. Q12 , So there's a joint school district board. A .Right. 013 And each~ school in' addition has their own boards? A Right. 014 The school boards are elected? l A Yes. Q15 Would you identify the schools in SAU 217 A South Hampton, Seabrook, Hampton Falls, Hampton, North Hampton and Winnacunnet. 016 And the principals'for each one of those schools are 1 under your supervision and direction, is that correct ? J A Generally speaking, but because it's.a dual type of _ situation, they certainly can't disagree with their

(

l i _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ - -O

                                                                                                     /cn'? /t4G U

i local boards, so they take direction from1them as l l well as from the superintendent. I Ol7 And the faculty would in turn'at each of these school a j take direction from the principals in the. respective i schools?

                                                                                                                .. j A    Yes.

018 -Are you familiar with the prccedures for schools set i forth in the New Hampshire Radiological Emergency I i Response Plan for Seabrook Station? A Vaguely. 1 Ol9 What is your understanding of those procedures? A My understanding of those procedures are that given a particular type of warning, that the students would be evacuated from sites, some going south toward Nashua, others going north toward Manchester. Q20 Do you have an understanding of your responsibilities as superintendent specifically under that plan? A Well, yes. l Q21 Okay. Was the question not clear? o 1 i A Oh, no. The question is one that involves profes-sionalism and three thousand three hundred and fifty-i nine students. There is no question in my mind as to what the role of superintendent.is in any emer-ge*ey, and that is that it's his primary function to

m a Ibi O 'h/s y .

                                                              ..           l see that those ch'ildren, whether it be a hurricane           'l 1

or whatever it be, are taken. care.of up until such i i 1 time as his position is assumed by-the National Guard l1 or other agencies such as the police department gives orders to. leave the area.

    -Q22 And--

i A Tornadoes, for example, that's what I'm speaking of, that's what I am familiar'with. The responsibility JJ of-the superintendent has always-been, as far as I know, the element of respons'ibility is the well-being j I! of the children that have been placed"in his trust j by state law. 023 And is that your general understanding with' regard. i to the responsibilities of yourself as superintendent under the New Hampshire Radiological plan. A I, yes, I wouldn't see any difference. -Now I'm talking professionally. If.it's an emergency, it's an emergency. Q24 You're not aware of any more specific-procedures than  ; what you just described? Well, other than that we're notified in'11ght of A a-- certainly, there are different levels of warnings. and we do certain things during those, we e.ither 6 cover up or evacuate. As far as--there may be scre- l

                                                                           +

                                                            /A 3 9 lble in between that I'm not familiar with.

025 Are you aware of any specific responsibilities under that plan? And when I'm referring to the plan it's the New Hampshire Radiological plan. Are you aware l of any specific responsibilities under that plan for principals of.the SAU 21 schools? A The principals have certain duties to report periodi-cally. We notify them right in the building. They in turn notify their staff and their students. I , think it varies on what they do depending on the severity of the warning. 026 Is it your understanding that you would be part of formulating whatever the appropriate action would be for these students in the event of-- A Yes. Q27 --an emergency at Seabrook? A Uh-huh. Q28 Yes? A Yes. With the exception of the Hampton School Dis-trict, which as you well know, Matt, because you  ! worked with the town, has refused to let the super-l intendent of schools participate. On whose legal advice that was, I don't know, but that did occur.

 -     So I do not participate in the Hampton school simply

jp g ](p(p 8 1

v. b I

because the Hampton board, I believe through legal counsel, was advised, advised me not to participate in the emergency plan. Q29 With respect to any of the other schools in SAU 21 have you received a similar direction? A No. Q30 So you were Superintendent of Schools in February i of 1986, for SAU 21, correct? A Yes. ~

                                         ,                  031               Do you recall that there was an emergency exercise of l

) the plan at that time? 4 1 A Most of the, most of the responsibility for'the plan l has been delegated to Fred Engelbach who is the 1 assistant superintendent for buildings, transportation:1, ' et cetera. I vaguely recall a February 26th l l but I don't recall what year. I know there was one in the winter. Beyond that there's not very much I can tell you. MR. BROCK: Could we go off the a record for a second. l [A short recess ensued at this  ; i point]

                                                                                                                                                                       .l 032                   So if I understand your answsr, your best memory is i

w _ . _ . _ - _ _ - _ _ . _ a -__. _ _ _ - _ - - - . _ - - _ - . _ . _ _ - - _ - - _ . _ - _ _ _ . - - . - - _ . _

IM ui /leb l 1 there was an exercise sometime in the winter a couple j yet:s ago, correct?

                                                                              )

A Yes. Q33 But you don't recall details about that exercise? A Not really. Q34 Do you recall whether you or your office participated l l in that exercise?

                                                                              )

i A Well, if you define participation, if a pho'ne call ) from someone is a participation, then yes we parti-cipated.- 035 And do you recall receiving such a phone call?. A Yes.

    ~

036 Do you recall who made the phone call to you? l A No. Q37 Did it come to you personally? 1 l A I took it, I don't think it was personally directed to me. Q38 Do you rechll the content of the phone call? A Just that there was a--there's a term that's used, mark or whatever, and we knew what was coming. I believe we knew what was coming. You're asking me questions, we keep no records of these, so you're asking me to l m rely on my mind which was battered about in a recend

                                                           ' /oC 9 /6b accident so I am unable to remember a lot of the details I once was able to.

039 That's fine, I'm just looking for your best memory. 1 Just to pursue that February or pursue that exercise which occurred sometime in'the winter a couple years o 1 ago, other than that phone call do you recall any involvement or participation by your office in that exercise? i l A There are two things we've been involved in. One we'vi 1 d been involved in the reviev of the plans. That's been on-going over a period of time, with various l consultants from TSNH.

                                                                           ]

4 In fact I believe that our' involve- i i ment led to a change in the plan. It seems to me if I s memory serves me correctly that we were heading all 1 of our students south toward Nashua and I requested j that they be sent north because sending some of them south would send them by the plant and there was no l need to do that. So I think we were then-changed to go to Rochester or Dover or up that way. I ' If you mean that kind of involve-twent and participation that's been on-going. If you l mean that particular day when that phone call came , in, our involvement at that time, I believe, was i . . , f

                                                                                                                           /tb 1 Ilds G. 1 I

simply either as a recipient of the call or we alerte ll our building principals. Q40 Do yon recall whether you took action after receiving , the phone call, such as alerting your principals, or do you remember?- A No, I don't. But if that was part of the plan that l we agreed to, then that was done. However, some of 9 these drills have taken place when school has not been in session. And I can't tell you on what given date that happened two years ago. February--I can't cell you whether we were in school that day or.not. 041 You are aware there was an exercise of the' plan last i June 28th and 29th, 19887

                                                   'A                     Yes.

0' 42 Whsn did you first become aware that there was to be an exercise on that date? A I believe it was before but I can't tell you when before. l 043 Do you remembei 7w you were notified that there was to be such an (, 2.rcise? A I believe I had a personal visit from Helen Wilson. Q44 Who? A Helen Wilson. But again I can't, I don't make notes m of these so-- 1 l_______---_--------.--------------- - _ - - - - - - - - - - - - - - - - - --

w __-_-_ __-__ -

                                                                               /D) o) lh(s 045  Who is Helen Wilson?

A Helen Wilson is a contact person, I believe a con-sultant for PSNH who dealt with local schools. Wait a minute, no, she may have been, she may have been with the State emergency defense or a state agency. I can't tell. I think she is or was. Q46 Do you recall approximately when Helen Wilson advised you there was to be an exercise? A No. 047 And do you remember anything specifically about what she said about the exercise other than it was to occur? A What I said when I was advised that there would be one? 048 That is correct. Did you have any reply? A I think I indicated that we would be out of school. 049 And what was her response to that? A That, I don't recall. Q50 Do you recall yourself saying anything further to her about the exercise or the date it was to be scheduled 7 A No. 051 And your best memory is that contact occurred before the exercise but you don't recall when it occurred? s- A That's my best memory. I wouldn't attest to the

                                                               /MP 9 //$//    I O

accuracy of that statement because I really don't

                                                                             ]

know. 052 Do you recall other than--well,-strike that..Wasithat I communication from Helen Wilson by. phone or how dide j you receive that? I

                                                                             .q A     I can't tell you. Helen Wilson has been a contact
            ' person, she has stopped into my office by. appointment on several different, on many different occasions.

I don't believe I talked to her at all on the tele-phone. I think I talked with her primarily in my l office so I would have to think.it was in my office j prior to. But perhaps by going back to my date l calendar, I could give you some idea of when that j occurred.

                                                                               ]

1 053 Do you recall receiving any written materials,.docu-ments, from her or c.nyone else regarding the exercise prior to its being held? A That specific exercise?

                                                                             -i 054- That is correct.                                                    l A    No. But we did receive constant updates to the plan.-              '

055 Let me just clarify. .You'did not receive written-materials regarding this June, '88, exercise.to the best of your recollection? (

    ,_ A    To the best of my knowledge, no.          I got all the

__ - - w

u materials'from whoever was representing theLagency.. We discussed.that. I think.that occurred a.long time ago. We got all of those plus we did not get--anythiag. I believe that we got from PSNH was when the plan-was revised. 056 Now this exercise occurred on-June 28 and 29, 1988, that's your understanding? A Yes. Q57 School was not in session at that time?- A No. Q58 Where were you at that time? A At the Red Jacket Inn here in Conway. 059 New Hampshire. A Yes. 060 And what were you doing there? l l A That's the Commissioner's annual conference, the Commissioner of Education. 061 And you as a school superintendent would attend'that? A Yes. < Q62 Were-other SAU superintendents attending that as l well? l " l A There's only'one SAU superintendent. Q63 I'm sorry. There are superintendents for other l SAU's, correct? l

l

                                                                                                                                     //b 9 /b/r    '

b A Yes. Thay would be attending. 064 And ic your best memory that--strike that. Did any-11 one else from your office or SAU 21 attend that conference? A No. Wait a minute. Last year? There may have been  !

one assistant superintendent Mr. Wilson. I think he 1 l did attend.

l Q65 And what was his name? l A Leon Wilson. I l 1 Q66 And he is an assistant to you? l A Yes. 067 And you testified that schools were not in' session on June 28-29, 1989,. correct? A yes. 068 Would there have been still administrative staff, principals or.other school personnel, at any of the SAU 21 schools on those dates even though school was not in session? A Yes. j 069 You would expect that that would be true with respect i to-- a A All except South Hampton. The principal of South Hampton is a teaching principal and pretty much

    ,,                                               follows the contract with teachers, but he may have

m li l' 4 lb(r i O I 1 l been or he may not have been. I can't say. I don't know what closing date he finished last year. j 070 But with the exception of South Hampton, you would.  ! expect there would have been school personnel at the i other SAU 21 schools? i A

                                                        ~

Well, that's hard to sey in a blanket type of state-ment, because some of the principals may have asked-for and been granted vacations. So I can't tell you.

                      .       In the high school there would have been an admini-trator there. There would have been an administrator         !

l at the Hampton Academy junior high school. There would have been an administrator at the Seabrook i l elementry school. There would have been an'admini- I strator at Hampton Falls. i The Hampton schouls other l l than North Hampton I really can't tell you. I could tell you, Matt, by looking at the vacation schedule whether or not they were there, or whether or not they were supposed to be there. 071 Do you recall being asked by the State of New Hamp-shire or New Hampshire Yankee or anyone else involved with Seabrook Station to be present on either the l l 28th or 29th? ' A No. 072 To your knowledge were any of the school-personnel l l L_____________________ _ _ _ _ _ .

                                                    /13 1 / 6 61 0

at the various schools in.SAU 21 requested to be present on those dates? A Not to my knowledge. I had left it with Helen Wilson that she had free access to contact the principals. in the various districts because I didn't think it wan l

                                                                    \

expedient for her to go through my office each time ) i she wanted to talk to them. And so she may have i contacted those principals in those buildings. If she did I do not know of that. 073 And subsequent to the exercise you never had it reported back to you by anyone that those contacts had been n.ade? A Well, with my not being there, Mr. Engelbach handled the drill and I talked with him just before I came up. He accepted the phone calls, he could not remem- i ber whether or not he then fanned out those phone ' calls to the buildings. He doesn't know, because l 1 we do not write things down as these tests come in. 1 I think there was a test that i preceded that one in which they sent buses in from Manchester, over that way, into Hampton Falls. I think that was the first test that we entered into. was the bunes. The second was in the winter, the l

m. third one was in June as I recall. l i

i 1 i

n.

                                                                                                                               'l l e 4 W/s k1    i 1

Q74- Let's.just focus on11ast summer's June 28-29' exercise k

                                                                                                                                            . 1 o
                                                                                                                  +
                                                                                        .       .                                                E So if I' understand it, you personally.were in Conway               !

attending a conference on those dates, correct? i A Yes.< l f

                                                                                                                                               - il Q75    And your assistant a Mr. Engelbach was at your office on those. dates?

1

                                                                   ,  A      Yes.                                                                  '

Q76 And you spoke.with him'before coming to theLdeposi ' tion this morning? l i A Yes. 1 i 077- And he-- i A No, I spoke to him, Friday. When I got the. summons , d at four-thirty in the' afternoon;-I.spok'e to him.  !

                                                                                                                                                 }

And what did Mr. Engelbach--well, Mr.-Engelbach. told Q78

                                                                                                                                               -]

you that he recalled rec ~iving a. tele}' hone call? A Right. 079 He received one telephone call? A It was a very fleeting, he was on his way out the door when I asked:him if he:had participated in the drill and he said yes, he had received a call. Now whetner that was one or more yna'd have to ask'him.-

                                                                     .080    Did he tell you whoJhe received that call from?.                     i i

A No. .

                              . sa                                   'Q81    Did he tell you what the content of that call was?:

1 I i' i

W _ _ - _ _ _ _ - - _ _ - _ - - - - - - lol? 164 b A Just that it was a--well, we all knew in advance that we were having a test on tSo two days. So in the conversation I had with him I just asked him if he received a phone call from PSNL regarding a test on those days and the answer was yes. 082 And he couldn't recall whether he took any action subsequent to receiving that phone call? A do. Again, we were on our way out the door when the subpoena was delivered. He was on his way home Friday, I was on my way home. So there really wasn't a long time to talk to him about it. It was just, maybe, Fred, you ought to go up in my place because you know more about this than I do, and I told him what it is. He suggested that I knew more about it than he did. 093 At least Mr. Engelbach did not tell you anything that he did further than receiving the phone call? A He didn't tell me that he did anything or didn't do anything. 094 Are you aware of any involvement, including phone contacts, concerning this exercise last June with regard to the principals at any of the SAU 21 scho01s? A That would be not within my purview of knowledge because that again would have to be asked of Mr.-- _ __ l

                                                                                                                                                   'll< f /b/-          ,

D.  !

                                                                                                                                                                      .i I'm not aware he'did, I'm not' aware he didn't.

Q95 And you're-not aware that the principals were con-tacted directly, for example, by the State of New Hampshire during'that exercise? A No.  ! l 096 And you're not aware of-any contact or any involve-ment of any of the teachers.in SAU 21 during this exercise? l i A Teachers are not normally.in school when school--when f j l the kids leave, the teachers leave, almost concurrent Ly] . So on the 27th, 28th and.29th ths teachers would not-have-been in school. , i

                 --                                                                                                                                                   H 097                                                    And would not have participated in this exercise I

as far as you know? A They have indicated via the union that they will not- 1 participate in the drills, although.I have been led to believe that I will have staff in the case of ' emergency. Q98 And what staff would that be?.  ! A Those are staff members who are saying an. indication; they will net, but they indicated to'me that if the-kids are in danger they would participate. Q99 And were any of--when you say staff do you mean sr faculty?- 1 w.-_--_-_______._.__._-_. - - - _ _ - - _ - _ _ _ _ - _ - - _ - - _ _ . - . _ . _ - - - - . _ _ _ . - -_ - __ _ - -_.

                                                                                               /#, 7 OD D

A Faculty. 0100 And to your knowledge, were any of those faculty involved in the exercise last summer? A No, because their year had ended. They were out of school around the 15th or 16th, sometime in that June era. Q101 Would you expect it to be brought to your attention if any of the teachers or principals of SAU 21 schools had been contacted or involved in the exer-cise? Well, I imagine I would if the teachers par-ticipated because we would all be wondering what they would be doing there. But as far as the principals that would not be brought to my attention. Q102 Following the exercise on June 28-29, were you con-tacted by any Federal officials regarding the exercise? A By that time, if there had been any contact it would have been with Fred. 0103 And you did not personally receive such contact to the best of your knowledge? A June of 1988, that's a long time ago. Q104 Anytime from the conclusion of the exercise. A I don't recall any. That does not mean it could not have occurred but I do not recall.

                                                         /)? 1 //de  1 0      j Q105  And you're not aware that Mr. Engelbach or anyone       l else on your staff received such contacts following     )

the exercise? i A Well, he has not indicated that to me but that's not  ! I uncommon. 0106 So he may have, he may not have. l t A That's right. j Q107 And that would also be true for_ contacts by state  ! I officials or anyone else, you personally haven't j J l received such contacts since the exercise but Mr. Engelbach may have received such' contacts. A I again would have to check my calendar to find out ~

  .                                                                  I to make sure that I had not. Most of those would have gone to him had there been any.

Q108 You today sitting here, you don't recall any contact you personally received?  ! l A No, because I don't have my date book with me and-therefore I can't confirm whether I did or didn't. ) Q109 And your hast memory is that you have not received I

    '                                                                l any questionnaires or documents since the conclusion     I i

of the exercise, again sitting here, to the best of l l your knowledge? A It seems to me that a questionnaire came in and it wa s  ; 1 I s sent on to Mr. Engelbach. i l 1 l l i

                                                                      //t 1 /b6 u

Q110 Do you recall who sent that questionnaire? l A No. Q111 Do you recall anything of the contents? l A No. . 0112 Do you know whether Mr. Engelbach did anything with that questionnaire?  ! A No. Q113 Aside from the exercise of last June 28th and 29th, l since that date have you had any contact er involve-ment regarding any emergency plans or exercises for Seabrook Station? l l l A I can't answer that. I'd have to check at the i office. 1 1 0114 You don't recall any sitting here though? A It seems to me that there were two or three attempts, or maybe four attempts, to set up a meeting, but we could not, it just didn't work out according to schedule. But there were Helen Wilson once or twice and a consultant from the Pittsburgh area, I can't remember her name. Q115 We're just asking for your best memory. A I think there were attempts to establish meetings, I think meetings were scheduled, but I think the meetings were cancelled. 1

IIA 4 Il>G, v-0116 Can you tell'me what training you or your office or SAU school personnel have received with regard to , l emergency plans or procedures for Seabrook' Station? I A Training? Q117 Correct. l j A Actual training. None to my knowledge. . Offered but

                                                                                 .I refused.
           '0118     Now the District school board is the one who hired         1 you, is that correct?

j A .The joint' board. i

                                                                                .j Q119     And the joint board as the policy maker for SAU 21          ;

did they ever tell you not to participate in the-

                                                                               i exercise last summer?

1 A No. Q120 Did they ever tell you that your office or the school personnel in SAU 21 should'not participate? j A No. Only the.Hampton board by resolution said we should not participate in any of the activities related to the Seabrook evacuation plan.. Q121 And aside from that there would be.five other local-1 district school boards under SAU 21? A Right.

         - Q12 2'   And could you just refresh my memory and identify thos e (s              five?

I

l 13m l llJb ' D A South'Hampton, Seabrook, Hampton Falls, North Hampton , j Winnacunnet and Hampton. Q123 -And with the exception of the Hampton local board, to your knowledge have~any of the district. boards l directed the schools in their respective jurisdic- i I tions not to participate in the exercise.last summer?

                                                                                                                                            ]

A No. Not by board resolution. 0124 And again with the exception of Hampton, you and your t l office have not refused requests by the state to { i cooperate or participate in planning or exercise? j A No. Q125 l You are here inr subpoena, is that correct? j

        ~

A Yes. 0126 And that subpoena included a request for certain documents, did it not? A Yes. . 0127 Were you able to locate any documents within the request? A Not--the staff leaves at four, well it was after the office closed, but we couldn't find any. relative to what we thought you would want to talk about today , any and all documents relating to the involvement of myself and 21 in the June 28 and 29 emergency s, exercise for Seabrook Station. We could not think

                                                                          's11 lb(p 1
                                                                                        .\

1 of any that we would have. Q128 And was Mr. Engelbach involved in trying to decide-- j l A No, well, for about three minutes. ' I Q129 okay. Let me just finish the question. A- Okay. l Q130 So last Friday you and Mr. Engelbach were trying to~ f determine whether.there were documents within the l scope of that request and concluded there were none?- A Right, that we could find in the three minutes.that 1 l 4 we had available to us. .You asked-about a survey, j we weren't sure that there was a copy kept of;that. Normally, we do not ke.ep copies of. surveys. 1 MR. BROCK: That's all I have. MR. COOK: I have none. l MR. HUNTINGTON - I don't have any questionsefor the state offNew Hampshire. [Whereupon.at 9:55 o' clock in the forenoon, the within deposition was then concluded] -

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l l THE STATE OF NEW EAMPSHIRE ROCKINGHAM, SS. I, Donald E. Lamont, a certified. shorthand reporter, in and for the State of.New- , i Hampshire, do hereby certify that the foregoing _ ' twenty-seven pages'contain a full, true and correct' d 1 transcript of all'of the testimony of the' witness NORMAN KATNER, to the best of my knowledge and belief. IN WITNESS WHEREOF, I have here- I unto set my hand and seal this' ' f day of 1989. N/  : Donald'E. Lamont, CSR l l t

__ l} A 4 ' //r(> b Re In.the Matter of Public Service Companyfof N. H.,'et al , (Seabrook Sthtdon Units 1 li 2) I DEPOSITION OF', TIMOTHY F. MONAHAN I N D E X i

                                                                               .I i

Interrogatories by Mr. Brock' i 3' _ Monahan Depo I Exh for Iden. .. Introduced at g

                            ' Description                    page:                 j 1

Letter from Helen Wilson 7 I

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                                                                              )1T 9 /b$

U  ! l l l UNITED STATES OF AMERICA j i Nuclear Regulatory Commission J Before the Atomic Safety'& Licensing Board ( l l

                                                                     ..                      a In the Matter of Public Service Company            :

l { of New Hampshire, et al  : (Seabrook Station Units l & 2) - 4 DEPOSITION OF TIMOTHY F. MONAHAN  !

                                                                                            '1
       /                                               Deposition taken by subpoena and      l l

agreement of the parties at.the law offices of Shaines & ' McEachern, 25 Maplewood Avenue, Portsmouth, New Hampshire, on l 1 Monday, March 13, 1989, commencing at 10:15 o' clock in the fore-- I I noon. APPEARANCES: For the Commonwealth of Massa-chusetts Attorney General's Office: l l l Matthew Brock, Esq., Assistant ) Attorney General Nuclear Safety Unit' One Ashburton Place Boston, Massachusetts 02108 For Public Service Company of New Hampshire: Roper S. Gray 1 International Place Boston, Massachusetts 02110 by Geoffrey Cook, Esq. For the State of New Hampshire Attorney General's Office: i v Geoffrey M. Huntington, Esq. l Assistant Attorney' General l

lJ< 1 lide O Stenographer: Donald'E. Lamont, CSR 25 Maplewood Avenue Portsmouth, New Hampshire.  ; __.-___~ ___ It'is stipulated and agreed that the deposition may be taken in the first instance by Stenograph and later:when transcribed may be used as and for.the deposition of the deponent for-all

                                    . purposes insofar as competent.

n

                                                          . The reading and signing.of the deposition by the deponent-is expressly waived.                        i (Deponent duly sworn by Mr. Lamont}                                                 s 1

INTERROGATORIES PROPOUNDED BY MR. BROCK: I, Timothy Monahan, on oath, depose and say as follows: Q1 Would you state your name'and address for the record please. A Timothy Monahan, 604.Elwyn Road, Portsmouth. Q2 How are you employed? A Superintendent of Schools in Portsmouth.  ! Q3 How long have you held that position? A Fifteen, sixteen; years. , Q4 Would you summarize your. responsibilities as Super- f

                                                                                                          -1 intendent of Portsmouth schools?                                        '

v i ___________i_____. __w

_-m_ 13tr 1 /leb U ,

                                                                  ^   l A                                                             i' In charge of all the schools from an educational point of view, from a financial point of view, and whatever other fires come down the line.

05 Who hired you? j A The Board of Education. Q6 The Portsmouth Board of Education.

    'A    Uh-huh.

Q7 And;that is an elected body? A Yes. Q8 Who sets policy for the Portsmouth Schools? A The Board of Education. Q9 And you implement that policy? A Yes. Q10 Would you identify the schools in the Portsmouth School system for which you are responsible? A The high school, the junior high school, the following elementary schools: Little Harbour, New Franklin, 1 Wentworth, Brackett, Jones, Sherburne, Dondero. Q11 Each of the principals of those schools that you've j identified answer to you, is that correct? A Yes. 1 Q12 Are you familiar with the plans and procedures in the New Hampshire Radiological Emergency Response Plan for Portsmouth Schools? , 1

l17 u1 lle(: A Yes. Q13 And for shorthand purposes in this depositions I'll just be referring to that as the plan. A Okay. Q14 What is your understanding with respect to your responsibilities as superintendent under that plan in an event of an emergency at Seabrook? A If I am notified that there is an emergency, to the point where I have to consider evacuating the schools or sheltering the students, then I make that decision. The decision, the information is given to me I assume from the City Manager who gets it from somewhere else, 015 And it's your decision as to what protective actions the students should be taking? A Yes, but they advise me. Q16 And when you say they, that's your staff? A No. That's the, I don't have the right word, the headquarters that are set up here in the city which contains the mayor, me--but I don't go--the police chief and so forth, that group. They're the ones that advise me and I would assume that advice is coming from the state. Q17 But you make the final call, that's your understand- 1 ing?

ins 9 I&G 0 A Yes. 018 Were you involved in an emergency exercise for Seabrook in February of '86, if you recall? A I would guess yes. Q19 Do you have a memory of doing that or-- A I have a memory, and I can't pin them down, but approximately that long ago I was down at the head-quarters here. Would I be right in saying that's the EEO, does anybody know? Q20 Whatever your best memory is. A But anyway, the central area here in the city, I have a memory of going down there to a drill. 021 And what was your involvement or participation at tha t time? A At that time I sat there, listened to the information that was coming, and sometime around one or one-thirty I was told that it had been upgraded. What comes back into my her) as when we were told, when it was sug-gested to ne 4' ,t we evacuate, we were already evac-uating because it was so late in the day that the buses were rolling. No students had left the building but the buses were moving to pick up the students to take them home. And so, therefore, we just let nature I 1 s take its course.

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i l Q22 And what you've just described is your involvement with the 1986 exercise? A I believe, yes. ' Q23 Now you are aware there was an emergency exercise for Seabrook last summer June 28th and 29th? A Right. Q24 And when did you first become aware there was to be an exercise at that time? A May 14th. Q25 You're looking at-- A I'm looking at a letter. Wait a minute now--as we discussed I will be in my office on the June 28th date. I wrote on May 14th, so it was prior to May 14th. I Q26 May I see that letter please. l A It's from me to Helen Wilson. l MR. BROCK: Okay. I'd like to mark this as an exhibit. Let's go off the record. (An off-the-record discussion ensued at this point, whereupon the cited document was then received by the reporter and marked as Monahan Deposition Exhibit 1 for identification) 027 Okay, Mr. Monahan, I'm referring to what's been marked as Deposition Exhibit 1 and that is the L_---------------_-------------- -

i

                                                                                               /40 / lieb D          i letter dated May 19, 1988, from you to Helen Wilson, is that correct?

l A Yes. l 1 I Q28 Who is Helen Wilson? 1 A She's out of the office of Emergency Management--oh, { what's her title? She's the director of, I guess-- } l I don't know. I mean I don't know here exact title. She's the person that I always deal with concerning any of these matters.  ; 029 And that would include the exercise? A Uh-huh. No, once the exercise is under way--on that a particular day? 030 Let me withdraw the question to be clear. In terms 1 of getting information that the exercise was going l l to occur, Helen Wilson was your contact? A Yes. 031 Okay. And that would also be true as to planning issues as well? l A Oh yes. Many meetings with her. Q32 All right. Now in the letter, exhibit 1, you indicate , 1 I three dates when you would be available to participate , correct?  ! A Yes. l l Q33 Those are May 24, June 10 and June 28th? i 1 l

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l la) 7 h'el! j o

                                                              ^

1 A I would assume that she gave me those dates. I don't j I have--probably Helen arrived in my office and gave l me some dates and I wrote back and said, yes, any 4 l of them. 1 034 So your best memory is those dates were potential dates for the exercise? l A Yes. 035 And you indicate in that letter that you would be i available for all three of them. j A Yes. j l 036 Do you recall the discussions with Helen Wilson that . led up to your writing the letter of May 19th? l

-'                                                              l A   I can't recall them. I would only be guessing.

Q37 Do you recall any discussions with anyone from the state of New Hampshire, or New Hampshire Yankee, concerning the exercise before it occurred? A No. I, my, I would be sure, quite sure, that Helen Wilson was always my contact. 038 And other than this letter, do you have a memory of any, either yourself or anyone from your office, being involved or planning for this exercise? A Well, I think that depends on how deep you want to go into that because two years prior to that there was ,, constant interaction or my people and the city, the

m-

                                                    /t3 o /A/,

o police and Helen Wilson and many people in putting together the evacuation plan, or whatever it is, that we have on file right now, which.would include Helen and others meeting with my principals gathering  ! information and so forth, i 039 And so you and the Portsmouth school system have had  ! input into those emergency plans for Portsmouth j i schools? A Yes, no question on that. Q40 Did you or school personnel from the Portsmouth schoo l i system.have input into when the emergency exercise { would be scheduled or what would occur during the  ; i exercise? l l A We did not have input as to the date of the exercise.

                                                                 'l What would occur would be that which was in the plan.

041 And the exercise we're referring to is the one last  ! l summer, , t A i Correct. Q42 Do you recall specifically any suggestions or recom-mondations which either you or your staff or anyone l from the Portsmouth schools may have made to the state , I or to anyone about the conduct or content of the j exercise?  ! f I u A Well, no, and I doubt very much that we did because l

l l I l \

l 3

   ~
                                                   !8 A 9 /66 U                  I school was closed. The year was over, the students were gone. And as I recall--first of all you should know I do not go to the headquarters down here. I was originally scheduled to do that and I petitioned Helen, I'm sure, to remove me from that and I said I would send a couple of other people down. I felt that was not the proper place for me.

I have lor.g looked at this entire q exercise and plan as having something obviously to l 1 do with Seabrook, but several years ago we had a hur-ricane coming and we were not prepared for that. And I looked at this as a plan that would fit any emergency 7 not just Seabrook. And I wanted to be in my office, l not down there. i Down there I found, because I did participate in the one, all I did was sit around all day and then they told me things. And when I decided to do something or I wanted to inform my people, I picked up a telephone and called my office and had somebody disseminate that information. And I made the point to them--this is a long story, I don't know if you're interested in it--but I made the point I don't want to be down

 ,   there anymore, I can stay in my office.      I can just l

( _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ -

                                                                                                                           /Av 1 /66 0-as well be told to recommend evacuation in my office, I

I I have the ability.to use an-intercom to call any ~ principal from my office, I have the ability to call them on private numbers that wouldn't be tied up. And so I thought I should be there and so I said give me a sort of conference call. And so they agreed. l And so on that June 28th exercise I was in my office, which gave me nothing to do because3 we di'dn't have any students. So my people went down there, they sat around all day, and I don't remember whether they recommended evacuation, or sheltering or what that day. Whatever it was I took the phone call and I said thank you and we didn't have any 4

                                                                                                                                         )

students and that was the end of it. I i Q43 Let me just back up a minute. Prior to the exercise then, your best memory is that you were aware there was to be an exercise but you didn't have input into the date and it was your understanding that the exercise was to basically test what the plan provided for in terms of procedures, is that correct? A Yes. Q44 Now you said schools were not in session on June 28 and 29 of last year, correct? sj A Yes.

m-l%'4 }/'o fe 1 u i l i l l' Q45 When did they get out for the summer? A About a week before. 046 So that if I'm looking ut Exhibit 1, deposition Exhibit 1, where you say you would be available May 24, June 10 or June 28, at least with respect to those first two dates, school would have been in I session? A Yes. Q47 on the day of the exercise, the first day of the I exercise June 28, you were in your office, is that i 1 l correct? A Yes. 048 And you had sent some of your subordinates somewhere else in town to be part of this exercise? l A Yes. Q49 And who was that? l 1 A William Hartwell and Richard Pecunies  ; 050 And what are their titles or functions? l l A Dick Pecunies is my personnel director. William i Hartwell is my director of adult education. MR. HUNTINGTON: Could you spell  ; his name please. , A P-e-c-u-n-i-e-s. (By Mr. Brock]  !

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051 Were there any other school officials in the_ Ports-i mouth school system who you directed to be involved in this exercise in some way?  ! A No. Q52 Okay. Are you aware of any other Portsmouth school officials who were involved in this exercise? A ' No. l 053 Where did the two individuals you just identified go , i to and what did they do? A The upper level of the Fire Department. And, to'the best of my knowledge, which is my hsking them to-l remind me what they did, they simply did what I did the ' first time. They listened and they relayed any infor.aation to me that they were told. 054 So periodically during the day you would have a con-versation with these two individuals by phone? A No, I was wondering what happened to them, I didn't from them. They could have took the day off on me. 055 Do you know of anything that they did in the fire l l station in terms of the exercise other than observe? l 1 A I believe they didn't do anything other than observe, listen. It was not their role, that's why I'm saying that. I 056 Now you were in your office. Did you have some '

v.

                                                                  ')U O lid-6 involvement, contact, in terms of the exercise?

A only through them. 057 All right. So you personally did not receive a phone call? A From them I did. I received a call from one of them sometime during the day, and I don't remember when, advising me either to shelter or to evacuate. And as I said, no students,.so we stopped right then. 058 You didn't take any further action because there were no students? A That's right. 059- Other than that one phone call from one of your subordinates from the fire station, did you receive phone calls or otherwise have a role to play in this exercise? A No. I believe the way it's set up, I would receive l phone calls only from them.' And I might have received more than one, you know, as they upgraded the thing, but I just don't remember. 060 But you know you received one call, you could have received more? A Yes, yes. 061 To your knowledge would any of the principals who j s_ were school officials in the-Portsmouth schools l

                                                   .______________._m_..       - M

IAT 4 Ho b

                                                                                   ~

U that are part of your system, did they receive calls or would they-- A No, no they would not. 062 Let me just finish the question. A Okay. 063 Did they receive calls or did they otherwise parti-1 cipate in this exercise? l A No, they didn't. When the date was set'and I knew that school was closed, I knew that it would end I with me because some of them would even be on ' vacation. 064 And you never heard back that any of them had received calls? A No, i 065 When you received this telephone call from the subordinate at the fire station, if I am correct. l he was relaying some recommendation about the protec-tive action which should be made for students, is that correct? A Yes. 066 Either to shelter or evacuate?

                          -A    Yes.

067 Do you recall which one was the recommendation?

 -                         A    No.

i

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l 068 Other than receiving that call and acknowledging j the information relayed, did you take any action I i after receiving that call?- ' A No. 069 Was there anything that was going on that made you aware that there was an emergency exercise for Seabrook that day other than the phone call which you've already described? l A Nothing that I remember. 070 After the exercise was completed June 28'and 29, well let me just back up a second, strike that. The answers you've given with respect to June 28, that is the same as for the 29th, we've been talking about l l those two days.  ! l A Right. 071 You received one phone call in that two-day period. A I don't know that. When my peonle were down there

I received at least one phone call. If I received another one, that could be but--

Q72 Following the exercise-- A l Excuse me. I had to receive another phone call telling l l me that the emergency was on and I had.to dispatch i l those two people down there. So there's two phone s, calls. 1 i i

                                                           /vb /- /h /-

V. 073- So you recall a phone. call at the beginning of the exercise which said, we're now-in the exercise.

        'A     Yes.

Q74 How did you know the exercise was' concluded? l A I don't think I knew that and Ifdon't think I was l concerned because I didn't have students, and when they got to the point of either shelter or evacuation j l that ended it for me and in fact I would guess my I people even left there then. i 075 If the schools had been open that day wculd you have taken further action or do you know? 1 t A I would have participated in.the' plan in whatever that would be. $ J 076 And do you know as you sit here what the plan would have called for you to do? A No. If they had, if we moved to evacuation I'm l guessing they may have wanted to run some buses to the schools. And if that was the case, that would l have been the extent of it. We would not have moved students. 077 After this exercise was concluded, June 29, were you ' l contacted or interviewed by any federal, state offi-cials, New Hampshire Yankee officials or anyone else

 ,            for your opinions about what occurred or to obtain l

W _ _ _ _ _ - _ _ _ _ - _ _ - - __ _ lVI I /!:& O information from you? A I'm sure that Helen Wilson visited with me because Helen Wilson visits with me often, and I'm sure we discussed it. Q78 Do you have a specific memory or-- A Well, I do have a memory because I think there were representatives there evaluating everything, and my memory tells me I said to Helen, how did it all go. I don't remember her answer. But I would have been curious. 079 And do you recall when this meeting might have occurred? A No. I could dig that out of my appointment book if I had to. 080 And your best memory is that this involved Helen Wilson and some other officials? A It could have. My contact has constantly been with Helen. Yes, sometimes she brought other people with her, but that would be unimportant. It would be Helen ti ut would make the appointment with me, it would be Helen I would talk to. 081 And do you recall any more specifically than you've already described what you may have discussed with s, Helen or any officials following the exercise?

1

                                                        /t/2 7 //rf,     j O

I i A No, I don't. And the reason being is that what '+;uld ' have to tell me, because I didn't move students, I didn't shelter students. I 082 Do you recall whether you received any written materials or questionnaires or other documents, since the exercise, relating to the exercise? A No, I honest.ly don't remember. That's very possible if & hey dj ;tributed some questionnaires, then I l probably filled it out and sent it back to them.

                                                                         ]

083 So if a questionnaire or that kind of material was provided to you, you weald have completed it? l A Yes, yes. 084 Sitting here though you're not sure whether or not in fact you received such material? A That's right. 085 Since conclusion of the exercise of June 29, have i you had any contact or involvement regarding planning or the exercise for Seabrook beyond what you've i already described? I A Yes. 086 What was that? l A Last week my princ_ pals met concerning that. I was in Washington, I can't even tell you what they did. .

 ,,         Helen came down, she said, I'd like to meet with               I l

l I

I48 1 /ho u them and discuss some things. I think it was more updating the plan and the names of people and so forth. And I said okay, and I set a date of last j Wednesday at one o' clock at which time they all met with Helen. And it hasn't been the biggest thing on my mind so I haven't asked as to exactly i what went on. Q87 Am I correct that you as superintendent of Portsmouth l schools, and the Portsmouth school system, have cooperated with the state of New Hampshire when asked regarding plans and exercises for Seabrook? A Yes. 088 Do you know any reason why the exercise was scheduled i on June 28 as opposed to an earlier date? A No. MR. BROCK: Thank you.  : nave nothing further. MR. HUNTINGTON: No questions. MR. COOK: No questions. [Whereupon at eleven o' clock in the forenoon, the within deposition was then concluded) v

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r THE STA"E OF NEW HAMPSHIRE l l ROCKINGHAM, SS. I, Donald E. Lamont, a certified shorthand reporter, in and for the State of New Hampshire, do hereby certify that the foregoing twenty-one pages contain a full, true and correct  ! l transcript of all of the testimony of the witness l" TIMOTHY F. MONAHAN, to the best of my knowledge and l belief. l IN WITNESS WHEREOF, I have here-unto set my hand and seal this /l f day of l O 1989, i

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Donald E. Lamont, CSR  ! i i I

Nif /6& j PORTSMOUTH SCHOOL DEPARTMENT CLOUGH DrWE PORTSMOUni NEW WMPSHRE 03801 o,a a n. j i uman unanoo - smaNENOGMNN:H00Ls 40H3H000 l May 19, 1988 Hrs. Helen Wilson j Office of Emergency Management State Office Park South 107 Pleasant Street ' Concord. NH 03301 Dear Helen

                     .                                                                          i As we discussed, I will be in my office and available to participate in a drill on May 24, June 10. and June 28.                                         i 1 hope that by my agreement I am not devoting three days in the next month to drills. However, I will do the best I can.and will be participating.

i Yours truly I l

                                              #                        r,                       I i .Ag          e - --                        I Timothy F. Honahan                          i 1

Superintendent of Schools ' i paw I i l' i

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l 6 C)RDREN ARE BORN k1AINEaB

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ATTACHMENT 9- [./6l To: Seabrook From: John S. Paolillo Date: ' March 24, 1989 1 1 I on 3/3/89 I interviewed Mr. Durgin in his office-located in Rye, N.H. Mr. Durgin is a school ~ superintendent within the-state of N.H. responsible for School Administrative Unit (SAU)-

          #50. At my: request, Mr. Durgin advised me:of his involvement in the Seabrook evacuation plan and. emergency exercise H

conducted last June.28 and 29, 1988. )

                                                                                                         .I There are four towns which M:.       Durg'in is responsible.for.as a school superintendent:

1. Rye

2. Greenland

3. New Castle

4. Newington According to Mr. Durgin, as of now, the' town.of Rye is not participating in anything to do with the plan. The-town of Greenland will not participate until commuting and transportation problems are resolved. The town of New Castle has agreed to participate fully in plan activities. The town of Newington is not located within the evacuation zone.

Mr. Durgin stated that on 6/28/88, Mr. Durgin received a l phone call (at his office) from the State Department and was advised that an active exercise was presently taking place for the Seabrook Nuclear Power Plant. Mr. Durgin was not L__i________-----_--------- -- _ - - - - - - - - - ------- - U

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1 I l instructed to do anything. He did not do anything in response l l to the call'. I After the phone call was completed, Mr. Durgin.left his I office to attend a meeting held at the New Castle school. The meeting weas not related to the' exercise. As he' entered the parking lot at the.New Castle school-he: noticed a school bus parked in the lot. He'd'id not inquire as to why the bus was tnere. Mr. Durgin does not' recall if any principals were l present in the schools at the time of this exercise.. However, q he' stated that there could have possibly been some school t administrators present within the building at the time of the .) I exercise. On~6/29/88, Mr. Durgin did not receive any l notification of an exercise being demonstrated that day, and had no involvement in the exercise. Mr. Durgin also discussed his role-in the evacuation plan. After Mr. Durgin receives a phone call notifying him of an alert, his-first respnse is to contact all the principals of f the schools within his region. The principals in turn spread the word throughout their schools and take proper steps in evacuating. In the event that Mr. Durgin is unable to be contacted, a designated contact person takes his place'and acts as a substitute. This contact suh2titute would most likely be Mr. Durgin's secretary Mary Lou Stevens. According to Mr. Durgin he was aware of 3.to 5 prior exercises. Further pertinent comments made by Mr. Durgin are listed below. i

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i I If principals of these schools are not available, 1 their assistant principals would then assume their role during the time of an actual emergency,

                       -                                                                       i Mr. Durgin has received letters in the past from                   1 Seabrook, but does not recall the date of these letters or the content.                          ,

(' Mr. Durgin has in his possession a copy of the Seabrook Station Response Manual. Mr. Durgin periodically receives written updates on procedual changes in the plan.

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To: Seabrook From: John S. Paolillo . Date: March 24, 1989 l On 3/6/89 I interviewed Mr. William Clancy over the phone. l l 1 Mr. Clancy is a school superintendent of School Administrative i Unit (SAU) # 16 within the state of New Hampshire. The interview regarded the emergency exercise conducted last June l 28 and 29, 1988 and Mr. Clancy's participation in the Seabrook-evacuation plan. The following towns fall under Mr. Clancy's jurisdiction: {

1. Exeter

2. Stratham j

3. Newfield

4. Brentwood i

5. Kingston '

l

6. Kensington 1

At the time of the 6/28/88 exercise, Mr. Clancy was away on vacation. However, Mr. Clancy's secretary did receive a phone call notifying the office of an exercise. According to Mr. Clancy, no action was taken by his secretary except for receiving the phone cail. This phone call was the only involvement of Mr. Clancy's office in the. June 28-29 Exercise. If something further had occurred, Mr Clancy expects that he would have been informed. Mr. Clancy's understanding of the evacuation plan is as follows: 1

 - v
                                                                                                     /6b l(gf; He receives a phone call notifying him of an emergency.

Mr. Clancy contacts the principal in each individual school within his district. Tile schools handle the dispersement of students to buses for evacuation. Students are taken to designated areas. Mr. Clancy suggested that the exercise be conducted during a time when school was in session. Helen Wilson agreed with Mr. Clancy's idea of conducting the exercise when school is in session. 1 or 2 prior exercises have taken place; one of them included a telephone exercise. Mr. Clancy has in his possession a copy of the Seabrook Station Response Manual. i

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lSI } AA i TNTERVIEW i JOHN PAOLILLO, INVESTIGATOR i MARK V. JOYCE, SUPERINTENDENT OF THE i SANBORNE' REGIONAL SCHOOL DISTRICT, N.H.

                                ' MARCH.6, 1989 I

ATT: ' State your full name. JOYCE: Mark V. Joyce. ATT: Okay, and your position?'

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JOYCE: Superintendent of Sanborne Regional. School District. I ATT: Okay, now what schools or what town are you primarily designated to as a superintendent? JOYCE: It's a cooperative school district formed of the towns of Newton and Kingston, N.H. ATT: Okay, now I'm going to proceed to last summer, particularly June 28th and June 29th. Do you recall that there was a mock evacuation performed? JOYCE: Yes, although that was prior to my assumption of my i I duties as superintendent. At that point'I was j assistant superintendent. ' ATT: You were? Okay,'now you say you were aware of this mock evacuation. Tell me, how were you made aware of it? JOYCE: I believe it was scheduled for sometime in May or June and there was a preliminary date that had been delayed and the final dates were in late June. ATT: Okay, now is this notification a phone call or was it... JOYCE: I was not familiar with that; it was shared with me by ' my predecessor. ATT: Okay. Now at the time, particularly June 28th the first day,'can you recall any events that transpired that you were involved in? JOYCE: No. I was not here at that time. I was at a state meeting, but as I spoke to Matt Brock the other day, in checking with the office staff here, what happened on that day was that we received a call through the network that activated our process locally for verifying the number of students in school and so forth. At that time, late June, all schools were closed. So the call was received here but no action was taken beyond that.

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        'ATT:     Okay, do you recall who particularly made that phone call to your office?

JOYCE: I-don't. Nor does my office staff. ATT: You don't. Okay, to your understanding what is your office's procedure on a phone call like this? ' JOYCE: On the first level it's to consult with the schools to get the attendance that day to verify the number of buses that will be used for evacuation purposes. ATT: Okay, now you contact the schools directly yourself? JOYCE: One of my office staff would. ATT: So you wouldn't be handling that part of it? JOYCE: You would probably.do it simultaneously to get that information as soon as possible. ATT: Okay, now the contact people at the school; who would they be? Anybody particular? JOYCE: The principals. ATT: Okay, now say they're not available at the time? JOYCE: The secretaries. ATT: Okay, now if the call came to your office and you weren't available; who would then take over for you at that time? JOYCE: Did you hear my response? ATT: No, I didn't. 1 JOYCE: Did you hear what I said? My assistant would take I over. ATT: Oh, your assistant would. JOYCE: Yes. l ATT: Okay, and he would act along the same lines you would if you were there? JOYCE: Yes, she would. ATT: Oh, she would. Now, getting back to the second day of l l that evacuation, the 29th. Here you made aware of any l 1 proceedings then involving your office? JOYCE: The extent of the recollection was that there was a call, one call.

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                                                                                   /6}    /f ATT:       On the 29th?                                                                I I

l JOYCE: It was late June and that because schools were closed. Our fo? low-up network was not used, as I previously stated. They don't recall who called other i i than it was part of the plan testing that they were aware of. {' ATT: Okay, so it was only the one call. What do you I particularly expect as far as your office's involvement goes in something like this? Do you understand fully what your role is to be? 1 JOYCE: Well, in terms of the test, it was my perception that we understood what our role was. Once we know we got the final procedure all established and we know that Seabrook is going to be a working entity, then we would review those and make sure that we were crystal clear on it. But it's been six, seven, eight months since the test date and we haven't really had any follow-up discussions following that. ATT: You haven't. Have you received any documentation since then? JOYCE: I have not, no. I have had a meeting with a couple of individuals from Seabrook. I think it was in October. At that point they were awaiting the final disposition of, I believe, both the elections and the future of Seabrook. Since that time, I've had no future meetings with anyone from Seabrook, nor from the evacuation nor from the State. ATT: Okay, so there's been no written documentation that's been sent to you directly. JOYCE: Not since my tenure here in this position here, no. That was effective July 1, '88. ATT: Okay, to your knowledge is anyoody in the schools that fall in your district been involved directly? j JOYCE: Since that time? ATT: At that time and since that time. JOYCE: Not since my involvement in my roll as superintendent. We have received, let me think here, over the summer we've received the radios, dispatch radios that would be used in each school. But I don't l believe any communication has gone directly to principals to my knowledge. ATT: Okay, so the first initial step would be contacting your office and... l l l

JOYCE: In terms of the notification procedures? ATT: Exactly, exactly. Then you're expected to filter the word down. JOYCE: Yes, sir. ATT: Okay. Back on June 28th, I'm just going to back up for just a second; to your knowledge, were any of the principals in the schools at the time of the demonstrations? JOYCE: I can't be precise about that. I know that several of us were at meetings because during that period of time that was ti.e state's superintendent meeting, so the state's principals came. ATT: Okay, do you know wha the. principals were at those schools, at those two schools at the time? Are they the same people now or... JOYCE: Yes, they're all the same individuals. I can check as to whether or not they were in school that day. The school was closed; there were no students in the district at that time. ATT: Okay, so there could have been people but to your knowledge you're not sure right now. JOYCE: There were no students. ATT: Okay, I didn't mean students, I meant faculty or administration... JOYCE: There was no faculty. There may have been administrative or maintenance personnel. ATT: Okay. Now that particular day, the day of the 28th, you were at, as you say, a state superintendents' meeting? JOYCE: Yes, sir. ATT: And where was that held? JOYCE: North Conway. ATT: Okay. Now how far is North Conway from the district that you work in? JOYCE: An hour and a half ride. l

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Mq /c< ATT: Okay. At any time during that day that you were at the meeting, did you notice anything that was I transpiring as regards to this evacuation, any buses or anything that you might have noticed? JOYCE: In North Conway? l ATT: Anywhere in particular that you were that day. No? JOYCE: No. ATT: Okay. Prior to last June, to your knowledge, has your office been involved in any other contact regarding a mock evacuation? l JOYCE: Yes. There's been extensive involvement over the last couple of years in terms of receiving training from the Seabrook personnel. I participated in a community test done Saturday in Kingston as a representative of the office. I participated in the Newton test on another Saturday and regulations in terms of our ' responsibilities were reviewed in meetings with, I believe, Helen Wilson and another lady named Becky...I forget her last name....throughout that kind of development phase. We also have a training program for administrators and then we have a subsequent training program that was volunteer for staff members who were interested. ATT: Okay. Do you recall how many of these training programs or exercises were offered... JOYCE: I don't. ATT: . . . prior to the June 28th date of last year. JOYCE: There were several but I don't recall how many. ATT: Okay, I just have to back up on one of the questions again. To you knowledge again, the schools wer: not contacted directly as far as an evacuation goes? JOYCE: On the June date of 1988? ATT: The June date or any other date. JOYCE: Prior to that time we oracticed calling, yes, but not on the June date. ATT: Not on the June date. Now on the prior dates would they have been possibly contacted directly? JOYCE: No, they would have been contacted though our office.

N6 lbl ATT: Okay, so the procedure would've beenLthe.same. Contacting your office, then you contact them. JOYCE: Correct. ATT: Okay. To your knowledge, were any principals at the schools or the. faculty or anybody who works at the school directly'been involved in any one on_one contact with the Seabrook people? JOYCE: Yes, they were all part of a training. program. ATT: Okay, now particularly on the 28th, to your knowledge. j JOYCE: 28th,'to my knowledge, no. { ATT: Okay. Now you say you just took the post of superintendent over recently, correct? JOYCE: Yes. ATT: How recent? JOYCE: July 1, '88. ATT: July 1, '88. Now any documentation that your. office received before then regarding this evacuation, was that facilitated to you? JOYCE: Yes. A whole file of changes were being sought.

                                                                                           . v.        i ATT:       Okay, did you talk to your predecessor regarding diis                                  '

evacuation plan? 6 t) ( JOYCE: He was here. prior to that date so I wasn't aware of the other training programs that we've had and we had that prior to the transition with my predecessor and the representatives of Seabrook last spring. ATT: Did you talk to him about the June 28th exercise in particular? 1 JOYCE: At the time I can recall meeting there, it was...the date wasn't yet established; it was sometime in May or June and as I've previously identified, those dates were changed. ATT: Okay. Do you feel comfortable about speaking with your predecessor and your. entire staff as far as identifying the participation on June 28th? JOYCE: I feel comfortable. Well, I spoke to them about it and to their recollection that's what occurred and to I .3that degree I feel comfortable. v

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l ATT: Did you speak to your predecessor after this excercise? JOYCE: No. I spoke to the office staff who were here. ATT: Okay, then before this exercise or following them afterward, his involvement was eliminated totally? JOYCE: Yes. Yes, he was gone from the district. ATT: Okay. Do you remember who got that phone call that day? k JOYCE: Yes. , ATT: Can you tell me who that was? JOYCE: Karen White.  ! ATT: I'm sorry. Can you repeat that? Karen White? JOYCE: Yes. ATT: Okay, and she is... JOYCE: She is the secretary in my office. ATT: Okay, and you've talked with her about this, about that particular phone call and about the June 28th proceedings? hello? , JOYCE: Yes. ATT: Have you spoken to Karen White since then about that particular phone call? JOYCE: Yes. 1 ATT: Okay. Since the June 28th exercise, has there been l i any other phone contact made to your office regarding i any upcoming drills or .trupcomingtrain)ngprograms or anything involving... j l JOYCE: Then the meeting in October which I previously talked about and that's the extent of my contact with anybody from... 4 I i ATT: Okay, so that s the latest that you've received anything. JOYCE: Yes, sir. i ATT: Have there been any briefings regarding the June 28th exercise?

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JOYCE: Not to my knowledge; not that I've been invited to or a part of. ATT: Okay, I'd like to ask you right now, Dr. Joyce, to advise me that you had knowledge that this conversation was taped. JOYCE: Yes. ATT: Okay, would you just state that? JOYCE: I had knowledge that this conversation was taped. 1 ATT:- Okay, that's fine. I just want for taking'the time to.... to thank you very much  ! I JOYCE: Okay, l i ATT: ...to speak to us.... l JOYCE: You bet. ATT: ...and everything like that. I'm going to turn the conversation over to Matt Brock. JOYCE: Now Matt can speak loudly rather than-just whisper. j l 1 l i

M 1&l < TNTERVIEW JOHN PAOLILLO, INVESTIGATOR j GEORGE TUCKER,' DEAN OF STUDENTS ~  ! PHILLIPS EXETER ACADEMY, EXETER N.H. MARCH 6, 1989 ATTY ': Okay, can you please-state your' full name please? TUCKER: Yes. George Tucker ATTY: Okay, and your position? l 4 TUCKER:' I'm a Associate Dean of Students at Phillips Exeter Academy. ATTY: Okay. Now, as Associate Dean, what schools fall in

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r the district that you are in charge'of? i TUCKER: It's just a single private school in New Hampshire of I about 1,000. students. ATTY:  ! Okay, so.it's just one school that falls under your jurisdiction, correct? TUCKER: Yes. ATTY: Okay, Mr. Tucker, are you aware that.last June, specifically June 28th and June 29th, there was a mock exercise? TUCKER: I'm not, I was away for summer vacation at the time. I thet left the academy about June 15th, so I wasn't aware that drill took place. ' ATTY: Okay, you were not aware of that drill previous to the date itself? 4 TUCKER: No. 1 ATTY: Okay, that day? to your knowledge was your office contacted on d ' TUCKER: No, not to my knowledge. I've asked people in the immediate office and they don't recall that.any call was made about June 28th or 29th. ATTY: ( Would you expect to know about it or informed about it if communication had taken place at that time? TUCKER: Well the contact person here is Mrs. Susan Herney who is Dean of Students and second on that list would be my name and neither one of us received a note about that call. t L-_____---_- -- - - ^

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ATTY: What specifically is your. school's involvement in this plan or you yourself? What is your specific involvement? TUCKER: I'm not sure on how to answer that...could you rephrase that? i ATTY: -Well, in'the evacuation plan itself, do you understand the evacuation plan I'm talking about? l 1 TUCKER: Yes. 4 l ATTY: Gkay. What is your responsibility in this plan? Your's specifically? TUCKER: We are, responsible for following whatever recommendation the N.H. Civil Defense makes; it could be to shelter our students in the dormitories or 3 l perhaps move them to the gymnasium for evacuation. In the plan there are'several responsibilities that the ' l Dean of Students office has. Generally, it's attendance taking and notifying dormitory faculty about the steps that have to be taken. ATTY: Okay. What are the specific lines of communications if such an evacuation were to take place? TUCKER: Through the Dean of Students and the principal's office to dormitories and other facilities on campus ! and our safety department. ATTY: Okay, who would contact the Dean'of Students? TUCKER: I understand that representatives from the N.H. Civil  ! l Defense Students. would initiate the calls to the Dean of ( l ATTY: Okay, so they would either contact you directly or the dean itself. TUCKER: That's correct. ATTY: Okay, and from there you would contact the principals and that would filter down the line? TUCKER: That's right. ATTY: Okay. Now, specifically on the June 28th exercise, you've advised me that you had no recollection that this was taking place. Was there any follow-up in this evacuation, any documentation that made you aware that...

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l6/ g ) I 1 TUCKER: No, not that I recall. at least. Not that came directly to me, f ATTY: How did you find out that there was one? TUCKER: The call f rom your colleague a couple weeks ago. l 4 ATTY: Okay, so no one else 'in your office or anyone else l from N.H. school board or anything else made you aware > of such an evacuation? TUCKER: No. ATTY: Now at the time on June 28th the schools, I sssume were not in session. TUCKER: That's right; I think the public schools ended in June, about the 22nd, last year. ATTY: Okay, the answer's the 22nd. Was there anybody in your specific school at the time? TUCKER: Were there any students? I'm sorry, I didn't hear that. ATTY: Was there anybody present in the school on June 28th or 29th whether it be students or faculty... TUCKER: There would have beeri a maintenance staff and a small group of administrators working but no teachers or students in session. ATTY: Okay, time, this staff that could've been working at that to your knowledge were they contacted in any way? TUCKER: Not to my knowledge. ATTY: Were there any administrative officials in the school at that time, to your knowledge? TUCKER: Yes, there would have been administrators working at I that week of the year. ATTY: But as far as you know, they were not? TUCKER: They were not contacted? ATTY: They were not there. TUCKER: No, I would expect that between ten and a dozen school administration people were working that week. ATTY: Okay, but they were not contacted to your knowledge?

TUCKER: I have been able to learn from conversation with them. ATTY: Okay, now if they were contacted, would'you expect to be advised of that? TUCKER: Yes, I would expect at least a' note that the call's been made. ATTY: That the call's been made. Okay, say supposedly that a call did come through and you and...who was the , other contact person you mentioned? j TUCKER: Susan Herney. l ATTY: Okay, if the two of you weren't available at the time, is there anyone within your office, anyone else who j would take over as a...in your role or-in your place? TUCKER: Well, the other that might be contacted are the Vice-principal or principal or the Director of Safety. 1 ATTY: Okay, they would be the people after you cannot be-contacted, correct? Do you understand what I just asked? l TUCKER: Yes. ATTY: Okay, so if you weren't able to be contacted, then whoever is be'ow you in the line of administration would be contacted. TUCKER: That's right. ATTY: Okay, so everyone is made aware of your school's role in this plan...the actual role that you'd teke...the procedures. Okay, nox.do you have specific documentation from Seabrook outlining the procedures of this plan? L TUCKER: Yes, we do. ATTY: Okay, does the booklet have a name or does it... TUCKER: Well, I don't have it here right in front of me but we're a special facility within the town of Exeter.

                                                                    . ATTY:    Okay, this outlines your role, you kth3w,'that specific       ~

part of the plan, outlines your role in this evacuation, correct? TUCKER: Yes. ATTY: Okay. Have there been any updates, documentation you might have received since then...since the June 28th mock drill?

                                                                                                                                                                              /63 g /W TUCKER:                       No, I haven't received any current information since                                                       '

June. ATTY: Yori aven't received any written documentation or i information,_ correct? Is'that correct? TUCKER: That's correct.

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ATTY: Okay. What.about any phone contact of any kind to update any proceedings in any way? TUCKER: No,-I haven't received any communications from N.H. or ) Seabrook about'this. l ATTY: Okay, prior to the June 28th, Jun'e 29th mock dr'll, i do you recall any other previous or any-training-programs or anything'regarding this case? TUCKER: There was a drill, I.think it was.aboutl January 20th or 23rd'and I just remember that date, but it may have been '87 and not '88. So it was a phcne drill in which center. we did receive a call from the Exeter emergency ATTY: Okay, were you present at the time of t'l; call? TUCKERT: Yes, I was. ATTY: Okay. What exactly transpired, do you recall after-the c all came through? TUCKE'A: It's just a call indicating that they were testing the phone tree and that we just acknowledged receipt of the call. That's really all it wes. ATTY: This was not the 28th? TUCKER: No. This was not the 28th of June. This was in January...it may even have been not January of '88 but January '87. AfTY: So, previous of the June 28th mock exercises only been one other exercise to your knowledge that's been conducted? TUCKER: That's right. ATTY: And that was a phone exercise, correct? TUCKER: Yes. ATTY: Okay, prior to that particular phone exercise, did you receive any information pertaining to that exercise? I mean, were you made aware that this was going to take place? ___________________m_ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . ___-____1._.____________m_ -

l Q NAj i TUCKER: Yes, we were. I remember' notification that this l drill, the one in January, was going to take place. ATTY: Were you made aware of this by phone or by written contract? > 1 TUCKER: By phone. ATTY: Who exactly called you, can you tell me? TUCKER: I don't recall. It may have been...we've had a series 1 of meetings over the past several years that1may have  ! been-a' woman who was working for the New-Hampshire l

                                                          -Civil Defense.                                          I can't. recall her name at'this point but it may have been that person.                                                                      )
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ATTY: Okay, so'the phone call is made to your office and they made you aware that a mock exercise was taking Place, correct? l TUCKER: Correct. ATTY: But you did not get a.similar notification for the June exercise that took place last year? TUCKER: No, I didn't. I l ATTY: Okay. Let me just go back to the June exercise for a second. .I know you were away at.the time, but did anyone from your office or'anybody from your faculty staff observe any activity relating to this exercise? TUCKER: I don't have any record on that, but I really can't l speak for other people who might've seen activity in i It's a very big school with 300 employees so town. they may have seen something but I couldn't tell { 1 because I was away. I ATTY: Okay, now this exercise that was conducted last June...your understanding was that school was not in session at this time. Did you in any way point this out to any of the Seabrook contact people, that possibly they should conduct an exercise when school was in session? TUCKER: The first notification that I had about this drill on the 28th was the call from your colleague a week or so ago scheduling this conversation. Otherwise, I hadn't heard about it at all. ATTY: Okay, I think that's about all I have to ask you. I just want to ask you one more thing. To your knowledge this conversation has been taped; can you just state that you do understand that this conversation has been taped? a

TUCKER': Yes, I am aware that this conversation has been taped. i l l ATTY: Okay. Well, I thank you very much for your time. I'm j going to turn the tape off now and I'm going to turn  ! t.he conversation over to Matt Brock. But thank you  ! very much for your time, Mr. Tucker. I TUCKER: Your welcome. 1 i J 4 1

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ATTACHMENT 10 '0 [ /dd OEREtCY OPERAT1CNS W_SSACE F0FW Originator Msg. Ntsnber: [- 1 p== 2 Date: [ b t' 8 f

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         # Internal:                                                  C Urgent:                                            -

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