ML20005B933

Supplemental Response to First Set of Interrogatories Re Emergency Planning in Compliance W/Aslb 810820 Ruling on Discovery.Certificate of Svc Encl.Related Correspondence

ML20005B933
Person / Time
Site:	05000471
Issue date:	08/28/1981
From:	Stowe W BOSTON EDISON CO.
To:	MASSACHUSETTS, COMMONWEALTH OF
References
NUDOCS 8109160139
Download: ML20005B933 (5)

Text

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. .s UNITED STATES OF AMERICA g b

NUCLEAR REGULATORY COMMISSION 4

before the E ATOMIC SAFETY AND LICENSING BOARD 2 01961, A.

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kb J' In the Matter of

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BOSTON EDISON COMPANY, et al.

Docket No. 50-47 (Pilgrim Nuclear Generating Station, Unit 2) j- [ff d

q APPLICANTS' SUPPLEMENTAL RESPONSES 2 <.gP 4 15198;5 -

TO COMMONWEALTH'S FIRS' SET OF INTERROGATOR]

IN COMPLIANCE WITH BOARD RULING ON DISCOVER ',

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m In response to the Board's August 20, 1981 ruling on A.

.y matters relative to the Commonwealth's first set of interrogatories relative to emergency planning the Applicants herebv respond as follows:

Interrogatories 3 and 4 The only such study of which Applicants are aware is a study entitled " Calculation of Reactor Accident Consequences for the Pilgrim Nuclear Power Statit.1 Site, Application of the CRAC Computer Model, June, 1961" prepared by Robert W. Sawdye. A copy of such study is available for inspection at the Company's offices at 800 Boylston Street, Boston, MA 02199.

Interrogatory 26 The only such studies of which Applicants are aware which have not p'.eviously been made available to tne Commonwealth

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I' are " Evacuation Time Estimates for Cape Cod", a d:;t* -iocument dated May, 1981 prepared by HMM Associates, and "C. w t.i r. ion Traffic Management Plan for Sagamore / Buzzards Bay" .t  ; raft document dated August, 1981 prepared by HMf: 'ssociates. A copy of each document is available for inspection at the Company's offices at 800 Boylston Street, Boston, MA 02199.

InterrogTtory 35 Appl.icants believe that all such material (relating in its entirety to the emergency alerting system for the Pilgrim Unit 1 Nuclear Plant) has previously been made availabla to the Commonwealth. To the extent it has not (such material consists of a report entitled " Prompt Alerting and Notification System, Pilgrim Nuclear Power Station" prepared by Stone & Webster Engineering Corporation dated March, 1981 and a letter from Boston Edison Company to the NRC dated July 21, 1981 relative to the status of such system) it is available for inspection at the Company's offices at 800 Boylston Street, Boston, MA 02199.

Interrogatory 43 The only such written response which has been located consists of a January 26, 1980 letter to Boston Edison Company from the Commonwealth of Massachusetts Civil Defense Agency and Office of Emergency Preparedness, a copy of which letter is avail-able for inspection at the Company's offices at 800 Boylston Street, Boston, MA 02199 k

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- 1 4 . 4 Interrogatory 58

The Applicants believe their original response complies with the Board's order.

By their attorneys, i]

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William S. Stowe Boston Edison Company 800 Boylston Street Boston, MA 32719 Telephone: 424-2544 l

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4 Dated: August 28, 1981 f

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. I UNITED STATES 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) )

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4 CERTIFICATE OF SERVICE I hereby certify that the RESPONSE OF BOSTON EDISON COMPANY, et al. to COMMONWEALTH OF MASSACHUSETTS' FIRST SET OF INTERROGA-TORIES TO BOSTON EDISON COMPANY RELATIVE TO TMI ISSUES and APPLICANTS' SUPPLEMENTAL RESPONSES TO COMMONWEALTH'S FIRST SET OF INTERROGATORIES IN COMPLIANCE WITH BOARD RULING ON DISCOVERY filed in the above-captioned matter has been cerved on the following by deposit of a copy thereof in the United States mail, firs + class, postage prepaid:

Andrew C. Goodhope, Esquire Stephen M. Leonard, Esquire Chairman Jo Ann Shotwell, Esqui*e Atomic Safety and Licensing Board Environmental Protection Division 3320 Estelle Terrace Department of the Attorney General Wheaton, Maryland 20906 One Ashburton Place, 19th Floor Boston, MA 02108 Dr. A. Dixon Callihan Union Carbide Corporation Francis S. Wright, Esquirs P.O. Box Y Berman & Berman Oak Ridge, Tennessee 211 Congress Street Bosten, MA 02110 Dr. Richard F. Cole Atomic Safety and Licensing Board '!enry Herrmann, Esquire U.S. Nuclear Regulatory Commission Room 1045 Washington, D.C. 20555 50 Congress Street Boston, MA 02110 Atomic Safety and Licensing Board Panel Mr. and Mrs. Alan R. Cleeton U.S. Nuclear Regulatory Commission 22 Mackintosh Street Washington, D.C. Franklin, MA 02038 Atomic Safety and Licensing William S. Abbott, Esquire Appeal Board Suite 925 U.S. Nuclear Regulatory Commission 50 Congress Street Washington, D.C. 20555 Boston, MA 02109

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Michael B. Blume, Esquire Patrick J. Kenny, Esquire Jack R. Goldberg, Esquire Edward L. Selgrade, Esquire Stephen H. Lewis, Esquire Mass. Office of Energy Resources Office of the Executive Legal 73 Tremont Street Director Boston, MA 02110 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Office of the Secretary Docketing and Service Section Chief Librarian U.S. Nuclear Regulatory Commission Plymouth Public Library Washington, D.C. 20555 North Street

' Plymouth, MA 02360 Dr. John H. Buck Atomic Safety and Liceasing Thomas S. Moore, Chairman Appeal Board Atomic $afety and Licensing U.S. Nuclear Regulatory Commission Appeal Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Christine N. Kohl, Esquire Atomic Safety and Licensing '

Appearl Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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v < < <4 Dated: August 28, 1991 s

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