ML20005B398

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First Set of Interrogatories Directed to NRC Re Emergency Planning.Certificate of Svc Encl.Related Correspondence
ML20005B398
Person / Time
Site: 05000471
Issue date: 07/01/1981
From: Shotwell J
MASSACHUSETTS, COMMONWEALTH OF
To:
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8107080174
Download: ML20005B398 (36)
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' REIATED CORRESPONDENd n///t /

. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g S N W

BEFORE THE ATOMIC SAFETY s 0 -9,

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) 'Q 73 In the Matter of: )

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BOSTON EDISON COMPANY, et al. ) Docket No. 50-471 (Pilgrim Nuclear Generating )

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6,M,pI1N>q3 L 9 COMMONWEALTH OF MASSACHUSETTS '

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INTERROGATORIES TO THE NUCLEAR REGULATORY COMMISSION STAFF w &

RELATIVE TO EMERGENCY PLANNING cn Pursuant to 10 C.F.R. 52. 720 (h) (2) (ii) , the Intervenor Commonwealth of Massachusetts requests that the attached Interrogatories be answered fully, in writing, and under oath by NRC personnel [ hereinafter, " Staff"] with knowledge of the f acts and designated by the Executive Director for Operations.

Each question is to be answered in six parts as follows:

A. Provide the direct answer to the question.

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B. Identify each document, and the particular parts

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thereof, which in any way serves as a basis for the answer.

C. Identify all documents known to the Staff which pertain to the subject matter questioned but which do not serve as bases for the Staff's answer, including documents which provide or support an answer different from that provided by the Staff.

D. Set forth the name, affiliation and title of each individual who participated in any way in the preparation of the Staff's answer, whether or not said individual is an official or employee of the NRC.

E. Set forth the name and title of any Staff member who did not participate in the preparation of the Staff's answer and who has, or may have, more direct personal knowledge of the subject matter of the question than the individual (s) identified in Section D.

F. Identify the person (s) , if any, whom the Staff intends to have testify on the subject matter questioned and state their qualifications.

For purposcs of these instructions, the term " document (s)"

refers to the original and copy (but not both if identical in every respect) of any printed, written, recorded, transcribed, punched, taped, filmed, photographed or graphic matter, whether sent or received or neither, whether a draft or otherwise, however produced or reproduced, and both sides thereof, including but not limited to, any memorandum, correspondence, letter, affidavit, court paper, transcript, diary, report, study, telegram, table, telex message, record, chart, paper, work paper, graph, index, book, notebook, pamphlet, periodical, tape, data sheet, data processing card, note, notation, minute desk calendar, appointment book, sound recording, computer I print-out or microfilm.

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INTERROGATORIES

1. In the opinion of the Staf f , is the 9.5 to 12 mile (radius) plume exposure pathway EPZ set f orth in Boston Edison Co. 's [her einaf ter , "BE Co."] PSAR appropriate for Pilgrim II? Describe in detail all theories , assumptions ,

procedures and data used in reaching this conclusion and the censideration given each of the f actors listed in the f ootnote below as it relates specifically to the emergency response needs and capabilities at Pilgrim II. If your answer is anything other than an unconditional af firmative , provide the dimensions of the plume exposure pathway EPZ which the Staf f ,

concludes is appropriate for Pilgrim II.

  • In i6entif ying every document or study which forms a basis f or your answer to question 1 or which pertains to the subject matter of that question, as required by the instructions above ,

include any site-specific c- ceneric study which addresses any one or more of the f ollowf - fectors:

(1) demography, inne:m permanent and seasonal

  • residents and tructi its (2) meteorology (3) topogr aphy (4) land use characteristics

( 5) access routes (6) local jurisdictional boundaries (7) release time and energy characteristics (8) release height

( 9) radionuclide content of release, including release f ractions (10) plume dispersion, including plume rise (11) deposition velocity (12) dose-effects (13) sheltering and shielding (14) radiation treatment (15) breathing rates

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- 2. In the opinion of the Staf f , is a 50-mile (radius )

ingestica pathway EPZ appropriate for Pilgrim II?* Describe in detail all theories , assumptions , procedures and data used in reaching this conclusion and the consideration given each of the f actors listed in the f ootnote below as it relates specifically to the emer gency response needs and capabilities at Pilgrim II. If your answer is anything other than an unconditional af firmative , provide the dimensions of the ingestion pathway EPZ which the Staff concludes is appropriate f or Pilgrim II.

  • In identif ying every document or study which f orms a basis f or your answer to question 2 or which pertains to the subject matter of that question, as required by the instructions above, include any site-specific or generic study which addresses any one or more of the followi.ig factors:

(1) demography , including permanent and seasonal residents and transients (2) meteorology (3) topography (4) land use characteristics

( 5) access routes (6) local j urisdictional boundaries (7) release time and ener gy char acteristics (8) release height

( 9) radionuclide content of release, including release f ractions (10) plume dispersion, including plume risa (11) deposition velocity (12) dose-effects (13) sheltering and shielding

'14) radiation treatment (15) breathing rates (16) time of year of release

3. Describe in detail the nature of any existing Commission guidance as to the manner in which any of the local conditions listed in the footnote on the previous page can or should influence the size and/or configuration of plume exposure pathway or ingestion pathway EPZs. Describe any i future Commission guidance which you expect to be issued I

regarding this subject, indicating the expected date of issuance.

l . 4. Describe in detail the methods and standards by which the evacuation time estimates contained in the Pilgrim II

( PSAR were evaluated and the range of estimates which would have been acceptable to the Staff. What consequences (including j early f atalities , delayed f atalities , early injuries, delayed l

injuriec,' developmental and genetic birth defects, and land and water contamination) did the Staff determine would be associated with each of the evacuation time estimates contained l in the PSAR? State specifically the highest evacuation time j estimate which would have been acceptable to the Staff for each evacuation sector drawn in the PSAR, citing any relevant Commission guidance, and describe the consequences (as categorized above) which would be associated with each such evacuation time.

I 5. Have the Commission and/or Staf f fo ind excessive any evacuation time estimate submitted to or calculated by or for the NRC with respect .to any proposed or existing plant? If so, indicate the plant (c) and estimate (s) which were the subject of I

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9 said finindg (s) and describe in detail the reasons for the finding (s) and the nature of any action ordered or taken as a consequence thereof.

6. Has the Staff (or anyone on its behalf or to its knowledge) conducted any generic or site-specific accident consequence analysis for (or having relevance to) releases from Pilgrim II equivalent to the PWR-1 to PWR-7 releases defined in WASH-1400 or releases from Pilgrim I equivalent to the BWR-1 to BWR-4 releases defined in WASH-1400? If so, set forth in detail the methodology, assumptions , and results of any such analysis, including calculations of early fatalities, del.yed f atalities, early injuries, delayed injuries, developmental or genetic birth def ects, and land and water contamination. If not, by whom was the decision made that such a study was unnecessary and what were the reasons for that decision? What process was followed in reaching that decision?
7. Has the Staff (or anyone on its behalf or to its i knowledge) conducted any generic or site-specific accident consequence analysis for accidents with containment f ailure modes such that the radioactive releaces exceed those_ set forth in the design basis accident assessment described in Chapter 15

! of the Pilgrim II PSAR? If so, set forth in detail the results l

of any such analysis, including calculations of early l fatalities, delayed fataliti s, early injuries, delayed l

! injuries , developmental or genetic birth def ects , and land and i

water contamination.

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8. In the opinion of the Staff, is it possible to evacuate saf ely the total permanent, seasonal and transient populations within each of the following areas during the day on a summer weekend? If any of your answers vary depending on ,

assumpilons made, provide a list of each assumption made and a +

description of how your response would differ if that assumption were changed. Disclose any assumptions made with

respect to an acceptable level of risk to the evacuating population.
a. The area which the Staf f believes should constitute the plume exposure pathway EPZ for Pilgrim II;
b. Each of the evacuation sectors drawn in the Pilgrim II PSAR:
c. The circular zone surrounding the Pilgrim site having a 20 . nile radius;
d. All of Cape Cod;
e. The entire Town of Plymouth and all of Cape Cod;
f. The entire Town of Plymouth and those portions of Cape Cod lying within 25 miles of the Pilgrim site;
g. The entire Town of Plymouth and those portions of Cape Cod lying within 20 miles of the Pilgrim site; and
h. The west 10-mile 90 sector drawn by BE Co. in its PSAR, extended to 20 miles from the Pilgrim site.

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9. In the opinion of the Staff, could thera ever be a need to order protective action (s) on any portion of Cape Cod or in any other area outside the plitme exposure pathway EPZ proposed by BE Co.? If so, in what areas and under what circumetances might protective action (s) be required, what particular protective action (s) might be needed, and how much time would be available f rom the initiation of the event (s) necessitating the protective action (s) before the particular protective action (s) would have to (1-) commence and (2) be fully implemented? Whether your answer is in the af firmative or negative, explair in detail the bases for your response, including any assumptions which you make with respect to an acceptable level of risk to the public.
10. In the opinion of the Stef f , could there ever be , in the event of an accident at Pilgrim and in the absense of traffic control mechanisms preventing such, spontaneous or vcluntary evacuation of some or all of the permanent, seasonal, and transient population on Cape Cod or of any other persons outside the plume exposure pathway EPZ proposed by BE Co.? If so, identify the various populations which you view as potential voluntary evacuees, and estimate the numbers of potential voluntary evacuees and the likelihood of such spontaneous evacuation (again, assuming no traffic control mechanisms preventing evacuation) .
11. The Staff has not objected in Supplement No. 5 to NUREG-75/054 to that portion of the PSAR, as amended, (at pp.

13A-3 5 to 13A-3 6) which reads as follows:

The evacuation time estimates include no vehicle volumes associated with ' spontaneous evacuation' of Cape Cod. This assumption is based on the relative ease with which spontaneous evacuation can be prevented. State Police can control the flow of traf fic exiting the Cape by posting details at the two bridges. These details can allow orderly flows off the Cape at those times when they will not interf ere with the evacuation of the EPZ. When the spontaneous evacuation begins to impede the flow of vehicles leaving the EPZ, off-Cape traffic can be halted, and if necessary, reverse routed away from the bridges. Similarly, evacuating traffic at the Sagamore Bridge traffic circle (nodes 800 and 801) would be directed down Route 6A by State Police.

a. Does the Staf f consider this an adequate response to its request of March 3, 1981, that BE Co. consider J

i the effects of spontaneous evacuation of people from Cape Cod in calculating evacuation times?

b. If the response to (a) is in the affirmative, how does the Staff anticipate that the State Police will make the determinations as to whether -pontaneous evacuation off the Cape is interf ering with or impeding the flow of vehicles leaving the EPZ and whether traffic should be reverse-routed away from

.ne bridges? To what extent will an impediment to traffic flow out of the EPZ be allowed before traffic off Cape Cod is halted? Do the evacuation time estimates calculated by means of the CLEAR model take account of this impediment? If so, how?

If not, explain in detail the effect which this ,

impediment to flow would have on those estimates ,

disclosing any assumptions made.

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c. For what period of time is the Cape population likely to be prevented f rom leaving the Cape? What behavior can be expected f rom individuals aware of the accident which has occurred and wanting to leave the Cape during that period of time, including individuals who are using the only f amily vehicle and whose family members are located within a 10-mile radius of the Pilgrim site?
d. Under what circumstances, if any, would State Police prevent persons f rom leaving Cape Cod by way of the Sagamore Bridge, but allow departure by way of the Bourne Bridge?
e. Is there any other existing or proposed reactor site in the country where existing or proposed emergency plans provide for precluding spontaneous evacuation? If so, please specify. If not, and if the Staff is accepting that approach in this case, please explain the rationale for permitting such in this case.
12. 10 C.F.R. Part 50, Appendix E, provides that "the Preliminary Saf ety Analysis Report shall contain sufficient information to ensure the compatibility of proposed emergency plans f or both onsite areas and the EPZs with f acility design f eatures , site layout, and site location, with respect to such considerations as access routes, surrounding population distributions, land use, and local jurisdictional bounJaries of

the EPZs." In the opinion of the Staff, does BE Co.'s PSAR, as amended, satisfy this requirement? Does it satisfy this requirement if you assume that there is ordered or spontaneous evacuation of some or all of the population on Cape Cod and/or of any other persons outside the plume exposure EPZ proposed by BE Co.? Explain the bases for your responses in detail.

13. In the opinion of the Staff, are there adequate f acilities available to shelter simultaneously the total permanent and peak seasonal and transient populations in each of the following areas?
a. All of Cape Cod;
b. Those portions of Cape Cod located within 20 miles of the Pilgrim site;
c. The entire Town of Plymouth and those portions of Cape Cod. located within 20 miles of the Pilgrim site;
d. Each of the 10-mile 90 sectors drawn by BE Co.

for purposes of estimating evaucation times; and

e. The circular zone surrounding the Pilgrim site having a 30-mile radius.

With respect to each of these areas, describe the types of shelter available, indicate the numbers of each type of shelter available and the shielding f acters associated with each type (providing separate figures for wood-frame houses wi:h no basements , wood-f rame houses with basements , masonry houses with no basements, masonry houses with basements, and large office, industrial or public buildings) , describe the nature

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and location of the shelter to be used by the transient and seasonal populations, and disclose any assumptions which you are making as to an acceptable level of risk to the public. j The term " shielding f actor" as used herein means the ratio of I l

the dose received inside the structure to the dose that would 1 l be received outside the structure.  :

! 14. 10 C.F.R. S50.4 7 (s) (2) provides , as to operating reactors, that "If after April 1, 1981, the NRC finds that the i

! state of emergency preparedness does not provide reasonable assurance that appropriate protective measures can and will be taken in the event of a radiological emergency and if the deficiencies are not corrected within 4 months of that finding, the Commission will determine whether the reactor shall be shut l down . . .

a. What, if any, determinations have the Staf f and/or Commission made with respect to the state of emergency preparedness at Pilgrim Unit I?

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b. What, if any, deficiencieu have been identified by the Staf f and/or Commission? Have they been j corrected?
15. Describe in detail any design modifications which l could be made to Pilgrim II as proposed to redu'e the early and/or delayed f atalities and/or health ef f ects associated with accidents. Specify the type of accident (s) the consequences of which each such modification would reduce and estimate, for each modification, the extent of reduction (providing separate l

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figures f or reductions in early f atalities, early injuries ,

delayed fatalities, delayed injuries, and developmental or genetic birth defects) .

16. In the opinion of the Staf f, what constitutes an acceptable level of risk to the public surrounding the Pilgrim site in the event of an accident? Specifically, what is the uppennost number of each of the following health ef fects which is acceptable: early fatalities, early injuries, delayed l

fatalities, delayed injuries, and developmental or genetic birth defects? If your answer varies depending on the type of

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accident which occurs, previde answers with respect to releases at Pilgrim II equivalent to the PWR-1 to PWR-7 releases defined in WASH-14 00.

17. Describe the current status of the Ccmmission's i

safety geal project and any findings , studies , conclusions , or decisions , whether preliminary or final, which have been made i

by any department or division of the NRC relative '.o a safety l

l goal or an acceptable level of risk to the public.

18. BE Co. states in its PSAR (at p. 13.3-47) that it "would recommend to civil authorities those protective actions l

as described in EPA-520/1-75-001 (Rev. 6/7 9) ."

a. Is it the understanding of the Staf f that this ,

includes the administration of radioprotective drugs , such as potassium iodide?

b. It so, how and where are said drugs to be scored, stockpiled, and disseminated?

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c. In the opinion of the Staff, would the administration of radioprotective drugs to individuals off-site ever be necessary or desirable in the event of an accident at Pilgrim II? If not, why not? If so, to what radial distance from the site could dissemination of the drugs be necessary?

What is the maximum quantity of potassium iodide or other radioprotective drug that could be needed?

What means does the Staff recommend be used for storing, stockpiling, and disseminating the drugs?

What repositories in the vicinity of the Pilgrim site currently stock such drugs and what quantities are maintained?

d. What, if any, guidance has been issued by the Commision or other 'ederal agencies with respect to the use, storage, stockpiling, distribution, or conditions for use of potassium iodide or other radioprotective drugs?
19. What is the Staff's understanding as to the meaning of the provision in App. 3, Section C of the Commonwealth of Massachusetts Comprehensive Emergency Response Plan (at Attachment C.1-6, p. 2) that the Duty Officer, Middleboro State Police, will

" Contact the State Police Barracks in Bourne and have two cruisers block the westbound lane of Route 6 at the Sagamore Bridge and re-route traffic to the Bourne Bridge using the by-pass on the East side of the Canal."

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Does the ref erence to blocking the westbound lane of Route 6 mean the westbound lane of the Sagamore Bridge or the westbound lane of Route 6 on either side of the Cape Cod Canal? If the latter, which side? If the former , how many people will be lef t car-less within the plume exposure pathway EPZ proposed by BE Co. by virtue of the f act that f amily members on Cape Cod with the f amily cars will be unable to return hame? Explain the bases f or your answers in detail, disclos_ng any assumptions made and indicating the effect on your answers of changing each such assumption.

20. In the opinion of the Staff, if an accident occurs at Pilgrim II on a weekday during working hours what percentage of the permanent population within the plume exposure pathway EPZ proposed by BE Co. will be working at . locations outside that proposed EPZ, leaving other family members at home without automobiles? Explain the bases for your answers in detail, i

l disclosing any assumptions made and indicating the effect on your answer of changing each such assumption.

21. How many people within the plume exposure pathway EPZ proposed by BE Co. are likely to be dependent on public transportation as their means of evacuation in the event of an accident at Pilgrim? How many of these people are j non-ambulator y? Explain the bases for your answers in detail,

! disclosing any assumptions made and indicating the ef fect on your answer of changing each such assumption.

22. What is the appropriate method of accounting for ambulatory and non-ambulatory public transportation-dependent populations in arriving at evacuation time estimates?
23. In the opinion of che Staf f, has BE Co. satisfied the requirement contained in NUREG-0654 (at p. 4-9) , a requirement cited by the Staf f in its March 3,1981 comments to Amendment 40 of the PSAR, that an estimate be made of the " time required to evacuate that segment of the non-car-owning

" If so, has population dependent upon public transport . . .

BE Co. used an appropriate method in making the estimate? If not, explain in detail the reasons why the Staff has not objected to BE Co's f ailure to do so.

24. Explain in detail the reasons why the Staff has not insisted that BE Co. submit separate evacuation time estimates f or evacuating special f acilities , despite the f act that such estimates are required by NUREG-0654 and were requested by the Staff in its March 3,1981 comments to Amendment 40 of the PSAR.
25. In the opinion of the Staf f , how much time will be required to evacuate the public transportation-dependent population within the plume exposure pathway EPZ proposed by BT Co.? Explain the bases for your answer in detail, disclosing any assumptions made and indicating the effect on your answer of changing each such assumption.
26. In the opinion of the Staf f , how many non-resident employees work within the plume exposure pathway EPZ proposed by BE Co. on summer weekends? Explain the bases for your

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l answer in detail, disclosing any assumptions made and indicating the eff ect on your answer of changing each such ass umption .

27. NUREG-0654, App. 4 provides (at p.4-2) that, in preparing evacuation time estimates , "The number of permanent

! residents . shall be estimated using the U.S. Census data or other r eliable data, adjusted as necessary, for growth."

[ Emphasis Supplied] In the opinion of the Staf f , what is the appropriate target date for adjusting population figures f or growth--the expected date of commencement of operations, the

expected terminal date of operations , etc.? Why did the Staff use unadjusted 1980 data in arriving at its estimates? Explain your answers in detail.
28. Is it the understanding of the Staf f , based on l

BE Co. 's PSAR, that emergencies of various classifications will be declared whenever the Emergency Action Levels indicate that

! such declarations are in order? Or does the Emergency Director have the discretion not to declare an emergency even though it is indicated by the applicable EAL? If your understanding is that the Emer gency Director has discretion in this matter ,

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explain in detail the reasons why you believe that to be acceptable, citing any Commission guidance relevant to the su bj ect .

29. Is it the understanding cf the Staf f, based on BE Co. 's PSAR, that state and local authorities will be i

notified within 15 minutes in the case of an Unusual Event? If

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not, explain in detail the reasons why you believe that to be acceptable, citing any Commission guidance relevant to the subj ect .

30. According t3 BE Co. 's PSAR (at p. 13. 3-3 7) , the only state agency which will be notified in the event of an Unusual Event is the Massachusetts Department of Public Health. In the opinion of the staff, does this comply with NUREG-0654? Is it consistent with the purpose of off-site notification in the case of an Unusual Event as explained in NUREG-0654--namely, to

" assure that the first step in any response later found to be necessary has been carried out"? Exp]ain your answers in detail, citing any relevant. Commission guidance .

31. BE Co. sets forth in its PSAR (in Figure 13.3-6) a notification matrix which calls for "First-line Notification" l

and "Second-line Notification . " In the opinion of the Staff, must the first-line and second-line agencies all be notified of l

an emergency within 15 minutes of its declaration or is it sufficient if only first-line agencies are notified within that time period? Explain the reasons f or your answer , citing any relevant Commission guidance .

l l 32. What, if any , analyses or studies have been f

! conducted by or for the Staff regarding past traf fic j ams in the Town of Plymouth and/or on Cape Cod? Describe in detail the methodology, findings, and conclusions of any such analysis or study and any use which the Staff has made thereof.

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33. In the opinion of the Staff, what is the proper way to account for each of the following possibilities in preparing evacuation time estimates:
a. vehicles breaking de,wn or running out of fuel during the evacuation;
b. aoandoned veaicles;
c. vehicles having insufficient fuel at the ccmr2encement of the evacuation, to the knowledge of their owners;
d. disregard of traf fic control devices;
e. evacuees using inbound traffic lanes for outbound travel; and _
f. blocking of cross-streets at intersections.

Explain in detail the method by which the CLEAR model analysis accounted for each of these possibilities or , if it did not account f or any one or more of these possibilities, describe the ef f ect of accounting for each such possibility on the CLEAR estimates, disclosing all assumptions made. In the case of items a, b, and c above , estimate the numbers of vehicles which will experience the particular problems.

34. NUREG-0654 provides (at p. 4-6) that in calculating evacuation time estimates in the case of ". . a northern site with a high summer tourist popu'.ation (the applicant] should consider rain, flooding, or fog as the adverse (weather]

condition as well as snow with winter population estimates."

What, in the opinion of the Staff, is the appropriate summer

adverse weather condition which BE Co. should use in estimating evacuation times at Pilgrim? Explain your answers in detail, providing the reasons for the Staff's f ailure to insist that BE Co. provide these estimates.

35. In the opinion of the Staff, did HMM Associates, Inc. properly account for every reasonably foreseeable external event (such as hurricanes , earthquakes , tornadoes , snow storms ,

ice or sleet storms, and snow and ice / sleet storms) in calcualting its evacuation time estimates? If your answer is anything other than an unconditional af firmative , describe any external event which was not properly accounted for and explain in detail the manner in which it should have been considered. _

If it is the Staff's opinion that any one or more of the external events specifically mentioned above need not be l considered in calcualting evacuation time estimates, explain in detail the bases for that opinion, citing any relevant Commission guidance.

36. Describe the nature of all current Commission, Environmental Protection Agency, ard other federal guidance regarding the levels of whole body and thyroid exposure to airborne racloactive material and of exposure to radiation via the food pathway which should initiate various protective actions (sometimes called Protective Action Guides) . Explain in detail the method by wh'.ch these exposure levels were set ,

noting specif1: ally what consideration, if any, was given to l

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the costs of implementing the protective actions. De3cribe any f uture Commission or other federal guidance which you expect to be issued regarding this subject, indicating the expected date of issuance.

37. Does the Staf f agree with the f ollowing statement contained -in EPA's " Manual of Protective Action Guides" (at
p. 1.24)-

. . . the projected dose should not include unavoidable dose that has been received prior to the time the dose proj ections are done."

Explain the reasons for your answer in detail, citing any relevant Commission guidance .

38. The le ter reproduced at App. B, p. B-1 of

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Supplement No. 5 to NUREG-75/054 contains a recommendation that southbound Route 3 be closed at Route 128. Does the Staff endorse this recommendation? If so, how does the Staf f expect that the Town of Plymouth will obtain the additional buses s

which it currently plans to have dispatched f rom towns north of i

l the proposed EPZ to Plymouth via Route 3? Has the Staff ,

i discussed with Plymouth officials the need for revisions in l

that plan? If the Staff disagrees with the recommendation for closing southbound Route 3, what impact does it expect that added traffic congestion to have on the evacuation time estimates prepared for the Staff and on those prepared by HMM Associ ates , Inc . f or Be Co. ? Explain your answers in detail, disclosing any assumptions made and indicating the ef fect on l

your answers of changing each such assumption.

39. What, if any, findings or conclusions have been made oy the Commission and/or FEMA as to the adequacy or capacity f or implementation of the Commonwealth of Massachusetts

-Comprehensive Emer gency Response P'an (Appendi 3) , Section C of that Appendix (the Pilgrim Area Plan) , and/o_ the local emergency response plans for the towns located within the plume exposure pathway EPZ proposed by BE Co.?

t 40. In the opinion of the Staff, what minimum distance should there be between the edge of the plume exposure pathway EPZ and the reception centers for evacuees? Explain the reasons fe - answer in detail, citing any relevant Commission or other f eder al guidance .

41. Is the Staff in agreement with the following conclusionc of SAND 78-0454, " Examination of Offsite Radiological Emer gency Measures f or Nuclear Reactor Accidents Involving Core Melt," June , 1978 (at pp.5-6)-

"Within five miles, evacuation appears to be more ef f ective than sheltering in reducing the number of early health efrects. Beyond five miles, this distinction is less , or not , apparent. Within ten miles, early health effects are strongly influenced by the speed and efficiency with which the protective measures are implemented. Outside of ten miles, they are not.

In the opinion of the Staf f , do these conclusions apply to Pilgrim? Explain your answers in detail, citing any relevant Commission guidance .

42. SAND 78-0454 cautions (at p. 66-6 7) that there is a considerable degree of uncertainty associated with the absolute results of the projected doses and public health ef fects

determined for the protective actions analyzed. What degree of uncertainty (error f actor) is associated with each of the following inputs? Explain the reasons for the uncertainty with respect to each variable.

(a) release magnitude (b) release probabilities (c) release characteristics (d ) atmospheric dispersion and cloud depletion (e) dosimetry modeling (f) dose-response criteria used in the calcualtion of health ef fects.

43. Has the Staf f conducted any on-site implementaton reviews of BE Co. 's emergency plans f or Pilgrim I or proposed emer gency plans for Pilgrim II? If so, describe in detail the Staff's findings and conclusions. If not, when will such
reviews take place?
44. Have the Staf f and/or FEMA conducted any of f-site drills at Pilgrim? If so, describe in detail the findings and conclusions resulting theref rom. If not, when will such drills I

take place?

45. NUREG-03 96 s tates (at p. 5) that "As an alternative to attempting to define a specific accident sequence, the Task Force decided to identify the bounds of the parameters for which planning is recommended based upon a knowledge of the potential consequences, timing, and release characteristics of a spectr um of accidents ." Describe in detail the various l

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accident scenarios upon which the Task Force based its r ecommendations and, f or each , the inf ormation relied upon by the Task Force as to potential consequences , timing, and release char acteristics.

46. Describe in detail any modifications or improvements which have been made by any departnent or divisicn of the Staff , or by any other individual or organization, to the Reactor Saf ety Study accident consequence model (the so-called "CRAC Code") since its original development. List all proposed or existing reactor sites with respect to which the Staf f has conducted a CRAC Code or comparable analysis. List all proposed or existing reactor sites with respect to which the Commission or Staf f has ordered the applicant or licen;*e to conduct a CRAC Code or comparable analysis.
47. Describe in detail the nature of all current Commission or other f ederal guidance regarding protective j actions which can or should be taken in the f ace of l

contaminated food and/or water supplies.

l 48. Explain in detail any and all results of the CLEAR analysis conducted for the Staff not reported in Supplement No. 5 to NUREG-75/054, including but not limited to any calculations performed as to the estimated time required for the population within the proposed EPZ to exit the west extended EPZ.

" " ~ .--._ ,_. , , , , _

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49. Supplement No. 5 to NUREG-75/054 states (at p. A-9) that "Further studies of the important intersections within the extended EPZ are recommended prior to inclusion of the evacuation time estimates into [ sic] emergency evacuation proced: ." List all of the "important intersections" referred to in this statement.
50. Supplement No. 5 to NUREG-75/054 includes a reference (at p. B-1) to "Battelle's running of the EVACCC model." Did Battelle run an EVACCC model with respect to the pilgrim site in addition to the CLEAR model? If not, explain this reference. In any event, explain in detail the .

methodology, assumptions, and results of any EVACCC Model or any other computer model (other than the CLEAR Model run by Battelle and the EVAC model run by HMM Associates, Inc.) run by or for the Staff (or which the Staff knows to have been run by another party) for the purpose of simulating the evacuation process at Pilgrim and/or estimating evacuation times for the l

l Pilgrim area.

51. Supplement No. 5 to NUREG-75/054 states (at p. A-6) that, in calculating evacuation times by means of the CLEAR Model, " Pre-planned evacuation routes [were] devised for populations .within the EPZ based upon field analysis and evaluation." Are the routes that were used identical to those which the communities within the proposed EPZ plan to use as evacuation routes? Are the populations that were assigned to each evacuation route identical to those which these same

_27-communities plan to direct to those routes? If the answer to either of these questions is anything other than an unconditional affirmative, i 3entify all of the pre-planned evacuation routes used and the populations assigned to each route and explain, in detail, the Staf f's justification for use of this methodology despite its inconsistency with planned evacuation routing.

52. Supplement No. 5 to N'UREG-75/0 54 states (at p. A-5) that the following assumption was made f or or by the CLEAR model with respect to f ree flow rate: "1700 vehicles per i

lane-hour at vehicle speeds between 55 and 15 mph." This rate is considerably lar ger than , and at times double, the lane capacity figures used by HMM Associates, Inc., in preparing its evacuation time estimates for BE Co. Explain in detail the reason f or this inconsistency and the justification for your higher figure. Explain in detail the ef f ect which using HMM's assumptions with respect to lane capacities would have on the l estimates derived by use of the CLEAR model.

\

53. Provide a map of the model traffic network used in calculating evacuation time estimates by means of the CLEAR l model comparable to Figure 3-3, p.13A-14 of BE Co. 's PSAR, showing all links and nodes. Provide a list of the characteristics of all links in that traffic network comparable i

I to and including all characteristics described in Annex E, pp.

13A-99 through 13A-105 of BE Co. 's PSAR.

I

c

54. Supplement No. 5 to NUREG-75/054 states (at p. A-6) that the assumption was made by or for the CLEAR Model that the network was empty at the commencement of the evacuation.

Explain in detail the reasons why the Staf f beJ ieves this is an appropriate assumption and the effect whica taanging that assumption would have on the CLEAR model evacuation time es tim ates . In the opinion of the Staff, what is the average daily traf fic flow on that portion of Route 3 which is included in the evacuation traffic network?

55. In the opinion of the Staf f , by what method should calculations of evacuation time estimates account for work-to-home travel within the evacuation traf fic network at the commencement of the evacuation period? Have the calculations performed by means of the CLEAR Model accounted f or such travel? If so, how? If not, explain in detail the eff ect on those estimates of accounting f or this travel, providing an estimate of the number of vehicles which would be l involved and disclosing all assumptions made.
56. Estimate the number of each of the following types of vehicles which will be needed to implement evacuations in each of the sectors outlined in Supplement No. 5 to l

NUREG-75 /0 54 ( a t p . A-7 ) and the number of trips to anc! f rom those - ectors which will be taken by each such vehicle--buses; ambulances; tow trucks; traf fic control vehicles; and vehicles for use in notif ying the public and/or confirming evacuation.

Explain the bases for your estimates in detail, disclosing any

ass umptions made. Have these trips been accounted for in the CLEAR Model evacuation time estimates? If so, how? If not, explain in detail the reasons why the Staff feels that it is not necessary to account f or these trips .

57. The Staff concludes in Supplement No. 5 to NUREG-75/054 (at p. 13.3-9) that the bottleneck at the Sagamore Bridge rotary " . . . will not result in unwarranted delays in effective evacuation of the plume EPZ if consider ation of this bottleneck is incorporated into state and local governments' i

evacuation traffic management planning." Explain in detail the bases for this conclusion, describing the alterations in traffic management plans which would be necessary to alleviate this problem. If those alterations would include any changes in planned evacuation routes, have the new routes been incorporated into the " pre-planned evacuation routes" used by or for the CLEAR Model?

58. Do the CLEAR model evacuation time estimates include notification time? If so, what portion of the estimates is I

attributable to notification and what are the bases for that figure? If not, what figure must be added to the estimates to i account for notifica: ion time and what are the bases f or that figure? In the opinion of the Staff, is it appropriate to l

stagger notification times in estimating evacuation times for the Pilgrim area? Explain your answers in detail,

59. Describe in detail the bases for the various -

preparation times assumed by or for the CLEAR Model and the various percentages of the population assigned to each

prepar ation time. Explain in detail .the reasons why the Staff believes it is appropriate to stagger preparation times and the effect on the CLEAR model evacuation time estimates of not staggering either notification or preparation times.

60. Do the CLEAR model evacuation time estimates include confirmation time? If so, what portion of the estimates is attributable to confianation and what are the bases for that figur e? If not, what figure must be added to the estimates to account f or confirmation time and what are the bases for that figure?
61. In the opinion of the Staf f , are the combined on-site and of f-site emer gency plans of BE Co. , local officials, and state officials required to be in full compliance with the emer gency planning measures set f orth in Section III of NUREG-0718?
62. If the answer to 61 is anything other than an unconditional affirmative , list each requirement of Section III of NUREG-0718 which is not applicable and explain the reasont l

l f or its inapplicability.

63. In the opinion of the Staf f are the combined on-site and of f-site emer gency plans of BE Co. , local officals , and state officials now in f ull compliaace with the emergency planning measures set f orth in Section III of NUREG-0718?
64. If the answer to 63 is anything other than an l unconditional af firmative , list each requirement of Section III of NUREG-0718 which is not currently complied with and provide,

P 1

for each, the date when the Staff believes the non-compliance will be corrected.

65. In the opinion of the S taf f , must emer gency planning measures be designed to mitigate the consequences of hypothetical releases to the liquid pathway as a result of core melt accidents? Explain your answer in detail, citing any relevant Commission guidance.
66. If the answer to 65 is in the affirmative , list and explain every requirement relative to mitigating such consequences which applies to a 50-mile (r adius ) ingestion pathway EPZ f cr Pilgrim.
67. In the opinion of the S taf f , do the combined of f-site emer gency plans of BE Co. and the local and state authorities now adequately address the eff ects of releases to the liquid pathway resulting from core-melt accidents? Explain your answer in detail. If your answer is anything other than an unconditional affirmative, list each requirement which is not currently complied with and, for each, provide the date when the Staff believes the non-compliance will be corrected.

l 68. Describe in detail the potential consequences due to i

t hypothetical releases through the liquid pathway resulting f rom l

[

a core-melt accident at Pilgrim II. Disclose all ascumptions made.

69. Describe each Pilgrim II design f eature, including interdiction barriers, which the Staf f believes serves to mitigate the potential consequences of hypothetical releases through the liquid pathway as a result of core-melt accidents.

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70. In the. opinion of the Staff , does BE Co. 's PSAR comply with each and every item applicable to PWR's in Reg.

Guide 1. 97, revision 2? If your answer is anything other than an unconditional affirmative , describe in detail every item of noncompliance , the alternative approach proposed by BE Co. , and the saf ety justification f or that alternative approach.

71. For each measured variable identified in Reg. Guide 1 .97, revision 2, Table 3, describe the ins tr ument (s ) or other methods BE Co. intends to use to make the measurement. Which of these instruments and/or methods have been added to satisf y the post-accident monitoring needs identified in Reg. Guide 1.97, revision 2?
72. To the knowledge of the S taf f , what instruments does BE Co. plan to instal.'. in Pilgrim II to monitor the plant status and reactor core during inadequate or degraded core cooling conditions? Which of these were added in response to Reg. Guide 1.97, revision 27 What other techniques , methods and procedures does BE Co. intend to use to measure or determine the onset of inadequate core cooling and to measure the core temperature during degraded core cooling conditions?
73. To the knowledge of the Staf f , what instruments does BE Co. plan to install both on-site and of f-site to measure continuously Iodine and other halogens in the Pilgrim II plant? What are the monitoring ranges of those instruments?

What qualif ication requirements must those instruments meet?

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74. List the date, location, attendees, and agenda items for every meeting, whether formal or informal, which has occurred between any member, representative, agent, or attorney of the Staff or Commission and any other person regarding the licensee / applicant, state or local emergency plans for Pilgrim I or II, whether past, current, or proposed. Describe any other manner in which the Staff has solicited and/or received state or local input regarding the Pilgrim I or II emergency plans and describe the nature of any input received, by whatever means, from state or local sources.
75. List the name, title and qualifications of every Staff member and every employee or representative of FEMA or Battelle Pacific Northwest Laboratories who reviewed any portion of Amendment 40 or 41 to the Pilgrim II PSAR. Describe in detail the nature of any instructions or guidelines which any of these individuals was asked to follow or did in fact follow in conducting his or her review. If any individual's review was limited to a particular aspect or aspects of the PSAR Amendments, so specify.
76. Provide a comprehensive list of all documents, studies (whether site-specific or generic) , rules, regulations, guidelines, and policy statements upon which the Staff relied in evaluating Amendments 40 and 41 to the Pilgric. II PSAR. j
77. List every field visit made by or for the Staff or j Battelle Pacific Northwest Laboratories to the Pilgrim site or the surrounding area. Specify for each visit the individuals l

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who participated and their titles and affiliations, the exact locations visited (including the names of all roadways traversed for purposes of evaluating the transportation network in the Pilgrim vicinity), the length of the visit, the itinerary or agenda, and all findings and conclusions which resulted therefrom (including any inventories which were developed as to available roadways, road capacities , shelter facilities, or the like).

78. Identify any Staf f or Commission member and any employee of FEMA or Batelle Pacific Northwest Laboratories who dissents from any finding, conclusion, or statement contained i

in Supplement No. 5 to NUREG-75/054 or to any portion of the answer to any of the foregoing interrogatories. Describe in detail the natu.e of any such dissent.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAF?,TY AND LICENSING BOARD

)

In the Matter of )

BOSTON EDISON COMPANY et al. ) Docket No. 50-471

)

(Pilgrim Nuclear Gener ating )

Station, Unit 2) )

)

)

CERTIFICATE OF SERVICE I hereby certif y that the within Interrogatories have been served on the following by deposit of copies ther eof in the United States Mail, first class mail, postage prepaid this 1st day of July,1981:

-- *Andr ew C. Goodhope , Esq. Henry Herrman , Esq.

Chaianan Room 104 5 Atomic Saf ety and 50 Congress Street Boston , Massachusetts 02109 Licensing Board 3320 Estelle Terrace Wheaton, Maryland 20906 Mr . & Mrs . Alan R. Cleeton 22 Mackintosh Street Franklin , Massachusetts 02038

-*Dr. A. Dixon Callihan Union Car bide Corporation

  • William S . Abbot, Esq.

P.O. Box Y Suite 925 Oak Ridge, Tennessee 37830 50 Congress Street Boston , Masst.chusetts 02109

  • Dr . Richar d F. Cole Atomic Safety and Licensing Board
  • Thoinas G . D ign an , Jr . , Esq.

U.S. Nuclear Regulatory Ropes' & Gray Commissi on 225 Franklin Street Washington , D.C. 20555 Boston , Massachusetts 02110 Atomic Saf ety and Licensing Patrick J. K enn y , Esq . Appeal Board Edwar d L. Selgrade, Esq. U.S. Nuclear Regulatory Deputy Director Mass. Of fice of Ener gy Commission Was hi ngton , D.C. 20555 Res our ce s 73 Tremont Stree:

Bos ten , Mass achus etts 02108

[

Atomic Saf ety and Licensing Office of the Secretary Boar d Panel D ocketing and Service Section U.S. Nuclear Regulator y U. S. Nuclear Regulator y Commission Washington , D.C . 20555 Commission Washington , D .C. 20555 Chief Librarian Jack R. Goldberg Pipcuth Public Librar y Office of the Executive North Street F1pouth , Massachusetts 02360 Legal Director U..S. Nuclear Regulatory William S . Stowe, Esquire Commission E cston Edison Company Was hington , D .C. 20555 E DO Ecylston Street E csten , Massachusetts 02199 Richard S. Salzman , Chairman Atomic Saf ety and Licensing Francis S. Wright , Esquire Appeal Boar d Eernan & Lewenber g U.S. Nuclear Regulatory Commission 2.11 Congr ess St.

20555 E cston , Massachus etts 02110 Was hington , D .C.

Christine N. Kohl, Esquire D r . John H. Buck Atomic Saf ety and Licensing Atcmic Saf ety and Licensing Appeal Board Appeal Boar d U.S. Nuclear Regulatory U.S. Nuclear Regulatory Comnission Cccmission Washington , D.C. 20555 Washington , D .C. 20555

"* S tephen H. Lewis U.S. Nuclear Regulatory Commi ssion '

Office of the Executive Legal Director Washington, D.C.. 20555 .

4 of Ann S horw e11 M=sistant Attorney General r_nvironmental Protection Division Public Protection Bureau Department of the Attorney Gener al Cne Ashburton Place , 19th Floor Ecston , Massachusetts 02108

'6_7) 727-2265

  • By Hand i

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