ML20005B400

First Set of Interrogatories Directed to Applicant Re Emergency Planning.Certificate of Svc Encl.Related Correspondence

ML20005B400
Person / Time
Site:	05000471
Issue date:	07/01/1981
From:	Shotwell J MASSACHUSETTS, COMMONWEALTH OF
To:	BOSTON EDISON CO.
References
NUDOCS 8107080177
Download: ML20005B400 (26)

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• UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION o N

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BEFORE THE ATOMIC SAFETY Docg g

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In the Matter of: )

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

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COMMONWEALTH OF MASSACHUSETTS

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FIRST SET OF C JUL07 M "h, '

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k5 INTERROGATORIES TO oun BOSTON EDISON COMPANY RELATIVE TO EMERGENCY PLANNIN y a, &

Pursuant to 10 C.F.R. SS2.740b and 2.741, the Intervenor Commonwealth of Massachusetts requests that the following Interrogatories be answered fully, in writing, and under oath by an officer or agent of Boston Edison Company.

I Each question is to be answered in four parts as follows:

A. Provide the direct answer to the question.

I B. Identify each document, and the particular parts thereof, which in any way serves as a basis for the i

answer.

C. Identify all documents, known to BE Co. which pertain to the subject matter questioned but which D

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do not serve as bases for the Staff's answer, including documents which provide or support an i answer different f rom that provided by BE Co.

D. Identify the expert (s) , if any, whom BE Co. intends to have testify on the subject matter questioned and f

l state their qualifications.

For purposes of these instructions the term " document (s)"

refers to the original and copy (but not.both if identical in i

every respect) of any printed, written,. recorded, transcribed, punched, taped, filmed, photographed or graphic matter , whether l sent or received or neither , whether a draf t or otherwise, however produced or reproduced, and both sides thereof, l

! including but not limited to, any memorandum, correspondence, I

letter, affidavit, court paper, transcript, diary, report, i study, telegram, table, telex message, record, chart, paper,

-work paper, graph, index, book, notebook, pamphlet, periodical,

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tape, data sheet, data processing card, note, notation, minute desk ct lendar , appointment book , sound recording, computer print-out or microfilm.

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INTERROGATORIES

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

I procedures, and data used in reaching this conclusion and the consideration given each of the factors listed in the footnote below as it relates specifically to the emergency response needs and capabilities at Pilgrim II. If your answer is anything other than an unconditional affirmative, provide the dimensions of the plume exposure pathway EPZ which BE Co.

concludes is appropriate for Pilgrim II.

• In iaentif ying every document or study which forms a basis for your answers to question 1 or which pertains to the subject matter of that question, as required by the instructions e.bove, include any site-specific or generic study which addresses any one or more of the following factors:

(1) demography, including permanent and seasonal residents and transients (2) meteorology (3) topography (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 fractions (10) plume dispersion, including plume rise (11) deposition velocity (12) dose-effects (13) sheltering and shielding (14) radiation treatment (15) breathing rates

2. In the opinion of BE Co., is a 50-mile ingestion pathway EP"J appropriate f or Pilgrim II?* (radius)

Describe in detail all theories, assumptions, procedures, and data used in reaching this conclusion and the consideration given each of the factors listed in the footnote below as it relates specifically to the emergency response needs and capabilities at Pilgrim II. If your answer is anything other than an unconditional affirmative, provide the dimensions of the ingestion pathway EPZ which BE Co. concludes is appropriate for Pilgrim II.

3. Has BE Co. (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 equiva. lent to the PWR-1 to PWR-7 releases defined in WASH-1400 or releases from Pilgrim I equivalent to the BWR-1 to

• In identif ying every document or study which forms a basis for 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 following factors:

(1) demography, including permanent and seasonal residents and transients (2) meteorology (3) topography (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 fractions (10) plume dispersion, including plume rise (11) deposition velocity (12) dose-effects (13) sheltering and shielding (14) radiation treatment (15) breathing rates ,

(16) time of year of release I i

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BWR-4 releases defined in WASH-1400? If so, set forth in detail the results of any such analysis , including calculations of early f atalities , delayed f atalities , early injuries, delayed inj uries , developmental or genetic birth defects , and land and water contamination.

4. Has Be Co. (or anyone on its behalf or to its know1dge) conducted any generic or site-specific accident consequence analysis for accidents with containment f ailure modes such that the radioactive releases exceed those set forth in the design basis accident assessment described in Chapter 15 of the Pi'.. grim II PSAR? If so, set forth in detail the results of any such analysis , including calculations of early fatalities, delayed fatalities, early injuries, delayed injuries, developmental or genetic birth defects, and land and water contamination.

5. In the opinion of BE Co., is it possible to evacuate safely the total permanent, seasonal and transient popi:lations within each of the following areas during the day on a summer weekend? If any of your answers varies depending on assumptions made, provide a list of each assumption made and a description of how your response would dif fer if that assumption were changed. Disclose any assumptions made with respect to an acceptable level of risk to the evacuating l

population.

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a. The area which BE Co. believes should constitute the plume exposure pathway EPZ for Pilgrim II;

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b. Each of the evacuation sectors drawn in the Pilgrim II PSAR;

c. The circular zone surrounding the Pilgrim site having a 20-mile 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 in the PSAR extended to 20 miles from the Pilgrim site.

6. In the opinion of BE Co., could there ever be a need to order protective action (s) on any portion of Cape Cod or in any other area outside the plume exposure pathway EPZ drawn in the PSAR? If so, in what areas and under what circumstances 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 affirmative or negative , explain in detail the bases for your response, including any assumptions which you make with respect to an ecceptable level of risk to the pv'clic.

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7. . . Thc .PSAR pr ovi. des, ..(a t., pp . 13 A;-3.5. ,to .1.3.A -3 61 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 traffic 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, of f-Cape traf fic can be halted, and if necessary, reverse routed away from the bridges. Similarly, evacuating traf fic at the Sagamore Bridge traffic circle (nodes 800 and 801) would be directed down Route 6A by State Police."

a. How does BE Co. anticipate that the State Police will make the determinations as to whether spontaneous evacuation off the Cape is interfering with or impeding the flow of vehicles leaving the EPZ and whether traffic should be reverse-routed away f rom the bridges? What, if any, analyses has BE Co. perf ormed to assist in the making of such determinations?

b. To what extent will an impediment to traf fic flow out of the EPZ be allowed before traffic off Cape Cod is halted? Do the evacuation time estimates prepared by HMM Associates take account of this impediment? If so, how? If not, explain in detail the ef fect which this impediment would have on HMM's estimates, disclosing any assumptions made.

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c. For what period of time is the Cape population likely to be prevented from leaving the Cape? What behavior can be expected f rom individuals aware of the accident which has ccourred and wanting to leave the Cape during that period of ti~e, including individuals who are using the only f amily vehicle and whose f amily 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. Explain the meaning of the last sentence quoted a bove . Specifically , to what " evacuating tr af fic" does the statement refer--traffic from the Cape?

from within the EPZ? And which portion of Route 6A will the traffic be directed down?

8. In the opinion of BE Co., 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 evacuation times; and

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

With respect to each 't these areas, describe the types of shelter available, indicate the numbers of each type of shelter

vailable and the shielding factors associated with each type (providing separate figures for wood-frame houses with no basements , wood-f rame houses with basements , masonry houses with no basements , masonry houses with basements , and large of fice , industrial or public buildingo) , describe the nature 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 publi.

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The term " shielding factor" as used herein means the ratio of the dcle received inside the structure to the dose that would be received outside the structure.

9. Describe in detail any design modifications which could be made to Pilgrim II as proposed to reduce the early and/or delayed f atalities and/or health effects associated with accidents. Specif y the type of accident (s) the consequences of which each such modification would reduce and estimate , for each modification, the exte ' of reduction (providing separate figures f or reductions in early f atalities , early injuries ,

delayed f atalities, delayed injuries, and developmental or genetic birth defects) .

10. The PSAR provides (at p. 13. 3-4 7) that BE Co. will

" recommend to civil authorities those protective actions as described in EPA-520/1-75-001 (Rev . 6/7 9) . "

a. Does this include the administration of radioprotective drugs , such as potassium iodide?

b. If so, how and where are said drugs to be stored, stockpiled, and disseminated?

c. In the opinion of BE Co. , 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 BE Co. 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?

11. What is BE Co. '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 Of ficer , Middleboro State Police, will

" Contact the State Police Barracks in Bourne and have two cruisers block the westbound lane of

Route 6 at tne Sagamore Bridge and re-route traf fic to the Bourne Bridge using the by-pass on the East side of the C an al . "

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 f ormer , how many people will be lef t car-less within the plume exposure pathway EPZ drawn in the PSAR by virtue of the fact that family members on Cape Cod with the f amily cars will be unable to return home? Explain the bases for your answers in detail, disclosing any assumptions made and indicating the effect on your answers of changing each such assumption.

12. In the opinion of BE Co., 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 drawn in the PBAR will be working at locations outside that proposed EPZ, leaving other f amily members at home without automobiles? Explain the bases for your answers in detail, disclosing any assumptions made and indicating the effect on your answer of changing each such assumption.

13. How many people within the plume exposure pathway EPZ drawn in the PSAR 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 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.

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14. What is the appropriate method of accounting for ambulatory and non-ambulatory public transportation-dependent populations in arriving at evacuation time estimates? Did HMM Associates use this method in its calculation of evacuation time estimates? If not, explain the reasons for this f ailure and describe in detail any substitute methodology which was employed by HMM.

15. In the opinion of BE Co., how much time will be required to evacuate the public transportation-dependent population within thc plume exposure pathway EPZ drawn in the PSAR? Explain the bases for your answer in detail, disclosing any assumptions made and indicating the effect on your answer of changing each such assumption.

16. In the opinion of BE Co., how much time will be required to evacuate fully the population of each of the special f acilities discussed at pp.13A-32 to 13A-33 cf the PSAR? Disclose all assumptions made , indicating the ef fect on the estimates of changing each such assumption.

17. In the opinion of BE Co. , how many non-resident employees work within the plume exposure pathway ET'3 drawn in the PSAR on summer weekends? Explain the bases f or your answer in detail, disclosing any assumptions made and indicating the effect on your answer of changing each such assumption.

18. 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 reliable data, adjusted as necessary, f or growth. "

[ Emphasis Supplied] In the opinion of BE Co. what is the appropriate tar get date for adjusting population figures for growth--the expected date of commencement of operations, the expected terminal date of operations , etc.? Why did HMM Associates use unadjusted 1980 data in arriving at its es timates? Explain your answers in detail.

19. Under the preliminary emergency plans set forth in the PSAR, will emergencies of various classifications be declared whenever the Emergency Action Levels indicate that such declarations are in order? Or will the Emergency Director have the discretion not to declare an emergency even though it is indicated by the applicable EAL?

notify state and local authorities

20. Will BE Co.

within 15 minutes of the declaration of an Unusual Event? If not, within what period of time f rom the declaration of the Unusual Event will such notification be made? Regardless of the timing , what will be the substantive content of any such notification?

21. BE Co. sets forth in its PSAR (in Figure 13. 3-6) a notification matrix which calls for "First-line Notification" and Second-line Notification." Will the firs t-line and second-line agencies all be notified of en eme'r'gency within 15 minutes of its declaration or is it only the firs ne agencies which will be notified within that time period? If the latter is the case, within what period of time will the second-line agencies be notified?

22. What, if any, analyses or studies have been conducted by or for BE Co. of past traffic j ams in the Town of Plymouth and/or on Cape Cod? Describe in detail the methodology , findin gs , and conclusions of any such analysis or study and any use BE Co. has made thereof.

23. In the opinion of BE Co. , what is the proper way to acco unt f or each of the following possibilities in preparing evacuation time estimates:

a. vehicles breaking down or running out of fuel during the evacuation;

b. abandoned vehicles;

c. vehicles having insufficient f uel at the commencement 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 HMM's calculation of evacuation time estimates accounted for each of these possibilities or , if it did not account f or any one or more of these possibilities , describe the eff ect of accounting for each such possibility on HMM's 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.

24. The letter reproduced at App. B, p. B-1 of Supplement No. 5 to NUREG-75/054 contains a recommendation that southbound Route 3 be closed at Route 128. Does BE Co. endorse this recommendation? If so, how does BE Co. expect that the Town of Plymcuth will obtain the additional buses which it currently nlans to have dispatched f rom towns north of the proposed EPZ to Plymouth via Route 3? Has BE Co. discussed with Plymouth officials the need for revisions in that plan?

If BE Co. 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 by HMM Associates, Inc.? Explain your answers in detail, disclosing any assumptions made and indicating the effect on your answers of changing each such assumption.

25. Has FEMA conducted any of f-site drills at Pilgrim?

If so, describe in detail the findings and conclusions resulting therefrom. If not, when will such drills take place?

26. Explain in detail any and all results of HMM's analysis of evacuation times not reported in the PSAR. Explain in detail any and all results of any other computer model (other than the CLEAR model run by Battelle for the NRC Staf f and the EVAC model run by HMM) run by or f or BE Co. for the purpose of simulating the evacuation process at Pilgrim and/or estimating evacuation times for the Pilgrim area. Provide a detailed description of any such computer model.

27. The PSAR states (at p. A-2) that, in calculating evacuation time estimates, HMM assumed that the evacuation traf fic network was empty at the commencement of the evacuation. Explain in detail the reasons why BE Co. believes this is an appropriate assumption and the effect which changing that assumption would have on HMM's estimates. In the opinion of BE Co., what is the average daily traf fic flow on that portion of Route 3 which is included in the evacuation traffic network?

28. The PSAR contains two mutually inconsistent st atements . It states (at p . 13 A-15) that HMM Associates, in calculating its evacuation time estimates for the adverse weather case, reduced road capacity to 70% of normal capacity.

It states (at p.13A-98) that HMM reduced road capacity by 70%. Please resolve this inconsistency.

29. Did HMM assume, in calculating its evacuation time estimates f or the adverse weather case , that the adverse weather condition aff ected travel speed? If so, what effect did HMM assume? If not, explain in detail the reasons why BE Co. believes HMM's estimates are accurate without accounting for this effect.

30. 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 population (the applicant] should consider rain, flooding , or fog as the adverse [ weather ]

condition as well as snow with winter population estimates."

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What, in the opinion of BE Co. is the appropriate summer adverse weather condition which it should .use in estimating evacuation times at Pilgrim? Explain your answer in detail and provide an evacuation time estimate assuming that condition for each cf the evacuation cases considered in the PSAR. Disclose all other assumptions made. If your choice of the adverse summer weather condition is anything other than a summer rainf all occurring mid-day on a summer weekend, explain your rejection of that condition and provide an evacuation time es timate assuming that condition for each of the evacuation cases considered in the PSAR. Again, disclose all other assumptions made.

31. In the opinion of BE Co. , did HMM Associates , Inc.

properly account for every reasonably foreseeable external event in calculating its evacuation time estimates? Did it account f or hurricanes? earthquakes? tornadoes? snow storms? ice or sleet storms? snow and ice / sleet storms?

Explain in detail the manner in which HMM accounted for each of these externalities or the reasons for its f ailure to account ther ef or .

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32. Annex E to 513A of the PSAR (at p. 13A-101) makes use of the notation "F" for purposes of indicating that

" parking along [a] link (is] prohibited." Explain what is meant by " prohibited" in this context. Does it.nean that parking is legally prohibited? If so, how was this L

I i determined? Does it represent a recommendation by HMM that

par king be prohibited along such links? Or does it merely represent an observation by HMM that vehicles do not in fact par k along such links?

33. Estimate the number of each of the following types of vehicles which will be needed to implement each of the evacuation cases outlined in the PSAR and the number of trips to and f rom areas within the particular evacuation sectors which will be taken by each such vehicle--buses; ambulances; tow tr ucks; traffic control vehicles; and vehicles to be used in notif ying the public and/or confirming evacuation. Explain the bases for your estimates in detail, disclosing any assumptions made . Have these trips been accounted f or in HMM's calculation of evacuation time estimates? If so, how? If not, explain in detail the reasons why BE Co. feels that it is not necessary to account for these trips.

34. How does BE Co. anticipate that the public transportation-dependent population will get to collection l points for loading onto buses? Given this method, how many i collection points will be necessary within the plume exposure I

pathway EPZ drawn in the PSAR?

35. Do there now exist the administrative and physical means to notify the public in the event of an accident at l Pilgrim I required by 10 C.F.R. Part 50, Appendix E, Section IV, D. 3 and NUREG-0 654? If not , when will those exis t? If so, explain in detail the no'cification system which has been established and its capabilities, including the time within

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which the population of the plume exposure pathway EPZ drawn in the PSAR can be notified and the compatibility of the system with any staggered notificatio'n scheme which might be employed in the event of an accident at the Pilgrim site.

36. Assuming the existence of a notification system in compli ance with 10 C. F.R. Part 50, Appendix E, and NUREG-0654, how much time does BE Co. believe should be added to the evacuation time estimates calculated by HMM to account for notification time? Does your answer vary depending on whether notification is staggered? If so, provide figures for both simultaneous and staggered notification. Explain the reasons f or your answers in detail.

37. Does BE Co. recommend staggered notification of the public in the event of an accident at Pilgrim II? If so, who does BE Co. expect to make the decisions as to what segments of the population will be notified at what tines? If the decision is to be made by one or more state officials, will local officials remain free to notify persons within their localities without regard for the state's staggered notification scheme?

Is it reasonable to expect that those not yet receiving formal l l

notice will await such notice before evacuating? Explain your )

answers in detail.

38. Explain in detail the bases for the omission f rom the evacuation time estimates calculated by HMM of preparation / mobilization and confirmation times. In the i l

opinion of BE Co. , how much time should be added to those

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estimates to account for these components of evacuation time?

Explain your answers in detail.

39. Explain in detail the ef f ect on HMM's evacuation time estimates of accounting f or the need f or work-to-home travel within the evacuation traffic network at the commencement of the evacuation period. Explain your answer in detail, providing an estimate of the number of vehicles which would be involved in such work-to-home travel and disclosing all assumptions made .

40. Will provisions be n ide for direct lines of communication between Pilgrim II and the Executive Office of Public Saf ety? Between Pilgrim II and the Massachusetts Civil Defense Agency? Between Pilgrim II and the Governor of Massachusetts? If the answer to any of these questions is in the af firmative , describe the direct lines of communication which will be provided.

41. Explain in detail the meaning of the " radiological criteria" contained in 513.3.5.3 of the PSAR (at p . 13. 3-4 7) .

Are they criteria that will be used in deciding whether to declare various categories of emergencies? Or are they criteria for assisting in judgments as to recommendations for protective action, as the section title " Protective Action Guides" would suggest?

42. Explain this apparent inconsistency in the PSAR:

513.3.5.3. states (at p . 13. 3-4 7) that the radiological criteria for declaring a General Emergency will be 1 Rem whole

Body and 5 Rem thyroid. However, 513.3.5.4.2.2 provides (at

p. 13. 3-50) , as an example of a situation in which BE Co. will recommend sheltering for of f-site populations , the case where the integrated whole body dose is projected to be "substantially below 1 rem and thyroid dose less than 5 r em . "

43. List the names of all state and local agencies which have reviewed the evacuation study performed by HMM Associates, as required by NUREG-0654, and describe the nature and source of all comments which resulted f rom said reviews.

44. In the opinion of BE Co, are the combined on-site and of f-site emer gency plans of BE Co . , local officials, and state officials requirea to be in f ull compliance with the emergency planning measures set forth in Section III of NUREG-0718?

45. If the answer to 44 is anything other than an unconditional af firmative , list each requir ement of Section III of NUREG-0718 which is not applicable and explain the reasons f or its inapplicability.

46. In the opinion of BE Co., are the combined on-site and of f-site emer gency plans of BE Co. , local of ficals , and state officials now in full compliance with the emergency planning measures set f orth in Section III of NUREG-0718?

47. If the answer to 46 is anything other than an unconditional af firmative , list each requirement of Section III of NUREG-0718 which is not currently complied with and provide, for each, the date when BE Co. believes the non-compliance will be corrected.

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48. In the opinion of Be Co., must emergency 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 .

49. If the answer to 48 is in the af firmative , list and explain every requirement relative to mitigating such consequences which applies to a 50-mile (r adius ) inges tion pathway EPZ for Pilgrim.

50. In the opinion of Be Co. , do the combined of f-site emer gency plans of BE Co. and the local and state authorities now adequately addr ess the ef f ects of releases to the liquid pathway resulting f rom 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 BE Co. believes the non-compliance will be corrected.

51. Describe in detail the potential consequences due to hypothetical releases through the liquid pathway resulting f rom a core-melt accident at Pilgrim II. Disclose all assumptions made.

52. Describe each Pilgrim II design feature, including interdiction barriers, which BE Co. 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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53. In the opinion of Be Co., does its PSAR comp..y 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 for that alternative approach.

54. For each measured variable identified in Reg. Guide l

1.97, revision 2, Table 3, describe the instrument (s) or other methods BE Co. intends to use to make the measurement. Which i

l of these instruments and/or methods have been added to satisfy the post-accident monitoring needs identified in Reg. Guide 1.97, revision 2?

55. What instruments does BE Co. plan to install in Pilgrim II to monitor the plant status and reactor core during l inadequate or degraded core cooling conditions? Which of these I

were added in response to Reg. Guide 1.97, revision 2? 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?

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56. What instruments does BE Co. plan to install both on-site and off-site to measure continuously Iodine and other l halogens in the Pilgrim II plant? What are the monitoring ranges of those instruments? What qualification requirements must those instruments meet?

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57. List the date, location, attendees , and agenda items f or every meeting , whether f ormal or inf ormal, which has occurred between any director , of ficer , employee ,

representative, agent or attorney of BE Co. and any other party regarding the licensee / applicant, state, or local emergency plans f or Pilgrim I or II, whether past, curre=:, or proposed.

58. List the name, title, and qualifications of every officer , director , employee , agent , or represer.t:tive of BE Co.

or HMM Associates, Inc. who participated in preparing Amendment 40 or 41 to the Pilgrim II PSAR.

59. Identify any officer, director, employee or representative of BE Co. or HMM Associates, Inc. who dissents f rom any finding, conclusion, or statement contained in Amendment 40 or 41 to the Pilgrim II PSAR or to any protion of the answer to any of the foregoing interrogatories. Describe in detail the nature of any such dissent.

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UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION BEFORE THE ATOMIC S AFETY AND LICENSING BOARD

^

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In the Matter of )

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

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(Pilgrim Nuclear Gener ating )

Station, Unit 2) )

)

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CERTIFICATE OF SERVICE I hereby certify that the within Interrogatories have been served on the following by deposit of copies thereof in l

the United States Mail, first class mail, postage prepaid this 1st day of July,1981:

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• Andrew C. Goodhope , Esq. Henry Herrman , Esq.

Chairman Room 104 5 l 50 Congress Street Atomic Saf ety and Licensing Board Boston , Massachusetts 02109 3320 Estelle Terrace Wheaton, Maryland 2090 6 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 , Massachusetts 02109

• Dr . Richard F. Cole Atomic Saf ety and Licensing Board

• Thomas G . Dignan , Jr . , Esq.

I U. S. Nuclear Regulatory Ropes & Gray l

Commission 225 Franklin Street j

Washington , D.C. 20555 Boston , Massachusetts 02110 i

Patrick J. Kenny, Esq. Atomic Saf ety and Licensing f Appeal Board Edwar d L. Selgrade, Esq.

i Deputy Director U.S. Nuclear Regu.1 -tory Mass. Office of Energy Commission I Washington, D.C. . 455 Resources 73 Tremont Street Bosten , Mass achuserts 02108

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Atomic Saf ety and Licensing Office of the Secretary Board Panel D ocketing and Service Section U. S. Nuclear Regulator y U.S. Nuclear Regulatory Commission W as hington , D.C. 20555 Commissi on Washin gton , D .C. 20555 Chief Librarian Jack R. Goldberg Flyncuth Public Library Of fice of the Executive North Street Legal Director Plymouth , Massachusetts 02360 U.S. Nuclear Regulatory William S . S towe , Esquire Commissi on Boston Edison Company Was hin gton , D .C . 20555 E 30 Soylston Street E cston , Massachusetts 02199 Richar d S. S alzm an , Ch ai rman Atomic Saf ety and Licensing F r taci s S . Wri gh t , Esquire Appeal Boar d Eerman & Lewenber g U. S. Nuclear Regulatory 111 Congr ess St.

Commission E cston , Massachus etts 02110 Was hington , D .C. 20555 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 Re gulatory U.S. Nuclear Regulatory Commission Commission 20555 Washington , D .C. 20555 Washington, D.C.

"* Stephen U. Lewis U.S. Nuclear Regulatory Commission .

Office of the Executive Legal Director Washington, D.C. 20555 go ff M_j Ann Snorwellsistant Attorney Gener al Environmental Protection Division Public Protection Bureau Depar tment of the Attorney General l Cne Ashburton Place ,19th Floor Ecston , Massachusetts 02108

~617) 727-2265

• Ey Hand