ML20005B401

First Set of Requests for Documents Directed to NRC Re Emergency Planning.Certificate of Svc Encl.Related Correspondence

ML20005B401
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 8107080180
Download: ML20005B401 (7)

Text

RElaTED CORRESPONDENCH

. / 63

- p

,f s 9

OCKragg

• //.\ g N/ 9 3 UNITED SCATES OF AMERICA 2 .l g __

O'l-AN

%[ # NUCLEAR REGULATORY COMMISSION ;

\q 0 ISSI . ~&l

% .4 v. . . , meu,

b '

kb/ g Before the Atomic Safety and Licensino Board g

\,

NE In the Matter of

$ )

)

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

Station, Unit 2) )

)

)

COMMONWEALTH OF MASSACHUSETTS ' FIRST SET OF REQUESTS FOR DOCUMENTS FROM THE NUCLEAR REGULATORY COMMISSION STAFF RELATIVE TO EMERGENCY PLANNING Pursuant to 10 C.F.R. S2.744, the Intervenor Commonwealth of Massachusetts hereby requests the NRC Staff to prG .ce and permit the Commonwealth to inspect and copy the documents designated below at the offices of the Attorney General, One Ashburton Place,19th Floor, Boston, Massachusetts 02108, on or before July 31,.1981, at 10:00 a.m.

DEFINITIONS (1) The term " document (s)" refers to the original and l

copy (but not both if identical in every respect) of any printed, written, recorded, transcribed, punched, tcped, filmed, photographed or graphic matter in the possession or subject to the control of the NRC or any Commissioner ,

employee, agent or attorney thereof, whether sent or received 8107080180 810701 ?

PDR ADOCK 05000471i y6g3 l G PDR)

[ .

or neither, whether a draft or otherwise, however produced or reproduced, and both sides thereof, including but act 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, mintite desk calendar ,

appointment book, sound recording, computer print-out or microfibn.

(2) All references to " Boston. Edison Company" or "BE Co." herein sha11' include any officer, director, employee, agent, or attorney thereof.

DOCUMENTS REQUESTED (1) All documents identified by the Staff in answer to the Commonwealth's Interrogatories to the Sta.Ef regarding emergency planning, including those listed *n response to interrogatory number 76. The Commonwealth states, as required by 10 C.F.R. 52.744 (a) , that these documents are clearly relevant to this proceeding as they have been identified by the Staff as pertaining to the subject matter of and /or forming bases for Staff answers to interrogatories which relate specifically to the issues of the feasibility of emergency measures at Pilgrim and the adequacy of current plans therefor.

(2) All documents not produced in response to request number (1) above which relate in whole or in part to taking protective action (s) (including evacuation, sheltering, and the

r administration of radioprotective drugs) in any area within the circular zone having a 50-mile radius surrounding the Pilgrim site, Any documents responsive to this request are clearly ralevant to this proceeding as they relate directly to the Commonwealth's contention regarding the feasibility of emergency measures at Pilgrim.

(3) All documents not produced in response to request number (1) above which relate in whole or in part to former, current or proposed licensee / applicant, state, or local

, emergency plans for Pilgrim I or Pilgrim II, or any portion thereof. To the extent any such documents relate to Pilgrim II, they are clearly relevant to this proceeding as they relate directly to the Commonwealth's contention regarding the inadequacy of the preliminary emergency plans set forth in Boston Edison Company's (hereinaf ter , "BE Cc.") PSAR.

Likewise, any such documents relating to Pilgrim I are relevant to this proceeding since deficiencies noted in the emergency

-plans for Unit I may well have significance with respect to the content of preliminary plans for Unit II. And the Commonwealth is entitled to inspect documents which relate to provisions no longer contained in emergency plans as currently written so that it can be advised of the positions taken and any compromises made by the Staf f in the course of its negotiations over the content of plans.

(4) All documents not produced in response to prior requests which relate in whole or in part to the methods to l

_4_

be used or assumptions to be made in calculating evacuation time estimates or performing evacuation studies or to the adequacy or inadequacy of the evacuation study performed by HMM Associates , Inc. for BE Co. Any such documents are clearly relevant to this proceeding since they relate directly to the Commonwealth's contention regarding the f easibility of emergency measures at Pilgrim.

(5) All documents not produced in response to prior requests which relate in whole or in part to the reactions of

. persons to the stress associated with nuclear accidents and/or the behavior to be expected of persons participating in protective actions in the event of such an accident. Any documents responsive to this request relate to both the feasibility of taking protective action (s) at Pilgrim and the adequacy of current plans regarding such action (s) .

(6) All documents not produced in response to prior requests which relate in whole or in part to the penetration of radioiodide into buildings that could be used as shelters in

, the event of a nuclear accident. Any such documents are clearly relevant to this proceeding as they relate to the adequacy of sheltering as a protective measure and , hence, to both the feasibility of emergency measures at Pilgrim and the adequacy of the preliminary plans outlined in BE Co. 's PSAR, which plans provide that BE Co. will recommer.d sheltering as a orotective action under certain circumstances.

(7) The document named in Reference 1 to supplement No. 5 to NUREG-75/054 (at p. A-10) . This docenent is clearly relevant to this proceeding as it describes the CLEAR Model used by Battelle Pacific Northwest Laboratories in calculating evacuation time estimates for the Pilgrim site.

(8) All documents not produced in response to prior requests which relate in whole or in part to meetings, conversations, or discussions, whether formal or informal and whether taking place in person or by telephone , between any member, representative, agent or attorney of the Staff or Commission and any other party regarding the licensee / applicant, state, or local emergency plans for Pilgrim I or II, whether past, current, or proposed. Any such documents are relevant to this proceeding for the reasons outlined in request number (3) above ,

l l

l l

k .. l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

-)

In the Matter of )

)

BOSTON EDISON C TMPANY et al. ) Docket No. 50-471

)

(Pilgrim Nuclear Generating )

Station, Unit 2) )

)

)

CERTIFICATE OF SERVICE I hereby certify that the within Request for Documents has been served on the following by deposit of copies thereof in the United States Mail, first class mail, postage prepaid this 1st day of July, 1981:

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

Chairman Room 1045 Atomic Safety and 50 Congress Street Licensing Board Boston, Massachusetts 02109 3320 Estelle Terrace Wheaton, Maryland 20906 Mr. & Mrs. Alan R. Cleeton 22 Mackintosh Street Dr. A. Dixon Callihan Franklin, Massachusetts 020't8 .

Union Carbide Corporation P.O. Box Y William S. Abbot, Esq.

Oak Ridge, Tennessee 37830 Suite 925 50 Congress Street Dr. Richard F. Cole Boston, Massachusetts 02109 Atomic Safety and Licensing Board Thomas G. Dignan, Jr., Esq.

U.S. Nuclear Regulatory Ropes & Gray Commission 225 Franklin Strc't Washington, D.C. 20555 Boston, Massachusetts 02110 Patrick J. Kenny, Esq. Atomic Safety and Licensing Edward L. Selgrade, Esq. Appeal Board Deputy Director U.S. Nuclear Regulatory Mass. Office of Energy Commission Rerources Washington, D.C. 20555 73 Tremont Street

- Boston, Massachusetts 02108

e . ..

l

Atomic Safety and Licensing Office of the Secretary Board Panel Docketing and Service Section f U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Comrission Washington, D.C. 20555 Washington, D.C. 20555 Chief Librarian Jack R. Goldberg Plymouth Public Library Office of the Executive North Street 02360 Legal Director Plymouth, Massachusetts U.S. Nuclear Regulatory Commission William S. Stowe, Esquire Washington, D.C. 20555 Boston Edison Company 800 Boylston Street Richard S. Salzman , Chairman Boston, Massachusetts 02199 Atomic Safety and Licensing Appeal Board Francis S. Wright, Esquire U.S. Nuclear Regulatory Berman & Lewenberg Commissi on 211 Congress St.

. Washington, D.C. 20555 Boston, Massachusetts 02110 Christine N. Kohl, Esquire Dr. John H. Luck Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Stephen H. Lewis R. K. Gad III U.S. Nuclear Regulatory Ropes & Gray Commission 225 Franklin Street Boston, Massachusetts 02110 Office of the Executive Legal Director 20555 Washington, D.C.

na Ann Shotwelf Assistant Attorney General Environmental Protection Division Public Protection Bureau Department of the Attorney General One Ashburton Place, 19th Floor Boston , Massachusetts 02108 (617) 727-2265