ML20005B925

Response to NRC First Set of Interrogatories Directed to Commonwealth of Ma.Certificate of Svc Encl.Related Correspondence

ML20005B925
Person / Time
Site:	Callaway, 05000471
Issue date:	09/01/1981
From:	Shotwell J MASSACHUSETTS, COMMONWEALTH OF
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8109160124
Download: ML20005B925 (7)

Text

m V . ta g;;;j; iPERC W 7'G ro NP b %

.h UNITED STATES OF AMERICA s NUCLEAR REGULATORL' COMMISSION  %, g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ~6

)

In the Matter of )

)

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

)

(Pilgrim Nuclear Generating )

Station, Unit 2) ) p e RESPONSE OF THE COMMONWEALTH Ij2Qf[g' (y 9 OF MASSACHUSETTS TO THE

\sgij g'88 k'etr a5 7p FIRST SET OF INTERROGATORIES TO THE COMMONWEALTH OF N MASSACHUSETTS FROM THE NRC STAFF Pursuant to 10 C.F.R. S2.740b, the Commonwealth of Massachusetts files the within Response to the Staff's First Set of Interrogatories. In general, the Commonwealth states that said interrogatories inquire as to the detailed nature of the Commonwealth's contentions regarding emergency planning and are, therefore, answered by the Detailed Statement of the Commonwealth's Emergency Planning Contentions filed on August 21.

Interrogatories

1. Question: Does the Commonwealth contend that NRC's regulations regarding emergency planning are inadequately specific to protect health and safety in relation to Pilgrim 2?

h 8109160124 01090L PDR ADOCK ::___.5R G P 05#00fW b9\

u

r Answer: No. As the Detailed Statement of the Commonwealth's Emergency Planning Contentions demonstrates, the Commonwealth does not challenge, but rather relies upon, the Commission's emergency planning regulations.

2. Question: Please specify those parts of the Commisision's regulations pertaining to emergency planning with which the Commonwealth contends BECO cannot, does not, or will not comply. Explain why BECO is or will be unable to comply with the Commission's emergency planning requirements, with specific reference to the characteristics of the area in an6 around the Pilgrim 2 site, including but not limited to population densities, transportation networks, land use, and distribution of food and water.

Answer: See Detailed Statement of the Commonwealth's Emergency 11anning Contentions.

3. Question: Does the Commonwealth contend that the plume exposure EPZ for Pilgrim 2 ranging from 9.5 to 12 miles does not satisfy the requirements of the NRC's emergency planning regulations? Explain the basis for this answer.

Answer: See Detailed Statement of the Commonwealth's Emergency Planning Contentions,Section I.

_ _ _ . _ . . = - _ - - - . - _ - . . - , . - _ _ _ _ , . - - - . - . - _ - . - - - . - - -

l

4. Question: Is it implicit in either of the Commonwealth's contentions (and if so which) that use of the criteria and conclusions of NUREG-0396 do not lead to establishment of a plume exposure EPZ for Pilgrim 2 adequate to protect health and safety in the event of an accident? Explain the basis for this answer and identify any supporting documents or studies.

Answer: See Detailed Statement of the Commonwealth's Emergency Planning Contentions,Section I. As that document reveals, the Commonwealth contends that the Applicants' and Staff's reliance on the generic guidance of NUREG-0396 and NUREG-0654 without regard for local emergency response needs and capabilities at the Pilgrim site does not comply with the Commission's regulations regarding the proper means for establishing plume exposure EPZ boundaries so as to ensure adequate protection in the event of an accident. Those regulations specifically require that plume exposure EPZ boundaries be determined in relation to local conditions (See 10 C.F.R. Part 50, Appendix E,Section II), a requirement which is suggested

! by the authors of both NUREG-0396 al.d NUREG-0654 (@gg NUREG-0396: " Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants," at 16-17; l

NUREG-06 54 : " Criteria for Preparation and Evaluation of l

. l

}

1 Radiological Emergency Response Plans and Preparedness in i

Support of Nuclear Power Plants," at 11,17) . The Applicants' f ailure to account for local conditions in establishing plume exposure EPZ boundaries for Pilgrim II is one respect in which the Commonwealth contends that the preliminary emergency plans as set forth in the PSAR are inadequate.

5. Question: Does the Commonwealth contend that the criteria of NUREG-0396 have been misapplied in establishing a plume exposure EPZ of 9.5 to 12 miles for Pilgrim 2? If the answer to this question is yes, then explain the basis for it and identify any supporting documents or studies.

Answer: See Detailed Statement of the Commonwealth's Emergency Planning Contentions,Section I, and the answer to interrogatory 4 above.

6. Question: Does the Commonwealth contend that the protective action strategies recommended in SAND-78-0454 i

are inadequate for Pilgrim 2? If so, how?

l l Answer: See Detailed Statement of the Commonwealth's Emergency Planning Contentions,Section II.. As that document explains, the Commonwealth contends that the Applicants' PSAR contains insufficient evidence to ensure the feasibility of the protective actions recommended in SAND-78-0454 in the event of a PWR-1 to PWR-7 accidental release, or its equivalent, at Pilgrim II.

1

7. Question: Does the Commonwealth contend that the evacuation studies regarding Pilgrim 2 performed by or for BEC0 and the NRC Staff are inadequate or erroneous in cheir assumptions, methodologies, or conclusions? If so, how?

Answer: See Detailed Statement of the Commonwealth's Emergency Planning Contentions,Section II, Paragraphs E through J.

SIGNATURES The foregoing answers are true to the best of my knowledge, information, and belief.

By: -

ue -

JQ/ ANN SHOTWELL" Assistant Attorney General Environmental Protection Division Public Protection Bureau Swcen to before me this 1st day of September ,1981.

0

( / h Nc(ary Pu lic ,

h07 N' Nl ^

k '

As to objections:

L c 40 ANN SHOTWELL "

' Assistant Attorney General Environmental Protection Division Public Protection Bureau Department of the Attorney General One Ashburton Place ,19th Floor t-Boston, Massachusetts 02108

I 1

UNITED STATEG OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

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

)

(Pilgrim Nuclear Generating )

Station, Unit 2) )

)

)

i CERTIFICATE OF SERVICE I hereby certify that the within Response has been served o: the following by deposit of copies thereof in the United States Mail, first class mail, postage prepaid this 1st day of September, 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 02038 Union Carbide Corporation P.O. Box Y William S. Abbot, Esq.

Oak Ridge, Tennessee 37830 Suite 925 50 Concress 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 Street 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 Resources Washington, D.C. 20555 73 Tremont Street Boston, Massachusetts 02108 L _.

~

I . .

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

Washington, D.C. 20555 Boston, Massachusetts 02110 Christine N. Kohl, Esquire Dr. John H. Buck 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 Office of the Executive Boston, Massachusetts 02110 Legal Director Washington, D.C. 20555

• Michael Blume U.S. Nuclear Regulatory Commission i

Office of the Executive l

Legal Director Washington, D.C. 20555 wm -

ydo Ann Shotwell Assistant Attorney General l

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

• By Express Mail, per requent

. . . . _ _.