ML20005B954

Response to Commonwealth of Ma First Set of Interrogatories Re Emergency Planning.Prof Qualifications & Certificate of Svc Encl.Related Correspondence

ML20005B954
Person / Time
Site:	05000471
Issue date:	07/20/1981
From:	Cunningham R, Dignan T, Stowe W BOSTON EDISON CO., ROPES & GRAY
To:	MASSACHUSETTS, COMMONWEALTH OF
References
NUDOCS 8109160180
Download: ML20005B954 (100)

Text

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,' &ED%%suggen UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION O

BEFORE THE ATOMIC SAFETY A_ND LICENSING BOARD

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s,fkD In the matter of )

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

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(Pilgrim Nuclear Generating ) g  : g

-Station, Unit 2) )

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n RESPONSE OF BOSTON E0ISON COMPANY, et al.

TO COMMONWEALTH OF MASSACHUSETTS' FIRST SET OF INTERROGATORIES TO BOSTON EDISON COMPANY RELATIVE TO EMERGENCY PL ANNING 9 $0b 1 p Oil DATE0: July 20, 1981 8109160180 810720 PDR ADOCK 05000471 Q PbR

• INTERROGATORY #1 In the opinion of Boston Edison Company (hereinaf ter, "BECo"), is the 9.5 to 12 mile plume exposure pathway EPZ set forth in BECo's PSAR appropriate for Pilgrim II?* Describe in detail all tneories, 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 respor.se 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 BECo concludes is appropriate for Pilgrim II.

• In identifying every document or study which forms a basis for your answer to question 1 or which pertains to the subject matter of that question, as required by the inscructions 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-e f fects

13) Sheltering and shielding

14) Radiation treatment

15) Breathing rates

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RESPONSE #1 s

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l A. The plume exposure pathway EPZ described in the PSAR is considered by Boston Edison to be appropriate for Pilgrim 2.

[ The selection of the zone is based on the NRC's guidance provided in NUREG-0396 and footnoted in Section I of 10 CFR 50 Appendix E.

Of the 15 factors identified in the interrogatory, the only one which directly af fected the definition of the plume exposure EPZ was item (6), local jurisdictional boundaries.

Since planning activities are organized by town, it made sense to follow town boundaries within the context of the guideline that a plume exposure EPZ should consist of an area about 10 miles in radius. Consideration of the boundaries led to the definition of the zone which is not a perfect circle, but is compatible with the recommended 10-mile radius. The remaining 14 factors did not specifically af fect selection of the size of the plume exposure EPZ since these characteristics for the Pilgrim site will be accommodated in the detailed emergency plans.

As summarized in NUREG-0654,Section I.D. 2, the selection of a radius of about 10 miles for the plume exposure EPZ was based on the conclusion that "it would be unlikely that any I protective action for the plume exposure pathway would be required beyond the plume exposure EPZ. Also, the plume exposure EPZ is of suf ficient size for actions within this zone to provide for substantial reduction in early severe health effects (injuries or deaths) in the event of a worst-case core melt accident."

8.1. NUREG-0396

EPA 520/1 78-016, " Planning Basis for the Development of State and Local Government Raulological Emergency Response Plans in Support of Light Water Nuclear Power Plants", December 1978.

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2. 10 CFR 50 Appendix E - Emergency Planning and Preparedness for Production and Utilization Facilities.

3. IlUREG-0654: FEMA-REP-1, Rev. 1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants";Section I . D . 2.

Boston Edison objects to Part B of this interrogatory, and to Part B of each interrogatory, to the extent that it is construed to call for more than the principal documents (and documents referenced therein) relied upon by Applicants' Direct Panel at the time thesa answers are prepared.

C. None. Boston Edison objects to Part C of this interrogatory, and to Part C of each interrogatory, to the extent that it is construed to call for a search of the literature by it or by the members of the Applicants' Direct Panel. The answer to this part is given based on the present recollection of the Applicants' Direct Panel at the time these answers are drafted, and does not include documents published and available in the general literature.

D. Boston Edison presently proposes to call the following persons to testify on emergency planning matters:

Robert H. Curiningham, Borton Edison Thomas Sowdon, Boston Edison Scott T. McCandless, HMM Associates Robert J. Merlino, HMM Associates The qualifications of these persons are attached.

Hereinafter referred to as " Applicants' Direct Panel".

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INTERROGATORY #2 l In the opinion of BECo, is a 50-mile (radius) ingestion 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 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 af firmative, provide the dimensions of the ingestion pathway EPZ which BECo concludes is appropriate for Pilgrim II.

• In identifying 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 RESPONSE #2 l

A. In the opinion of Boston Edison, a 50-mile (radius) ingestion pathway EPZ is appropriate for Pilgrim II. This j conclusion was reached based upon guidance developed

jnintly t; .he NRC and EPA (NUREG-0396/ EPA 520/1-78-016)  !

issued in December,1978, and later incorporated into joint NRC/ FEM A emergency response planning guidance l (NUREG-0654/ FEMA Rep. 1, Rev. 1) issued in November, 1980. In discussing the planning basis for of f-site response plans, NUREG-0654 recommends ar ingestion exposure pathway EPZ of about 50 miles, and states that this size EP7 was selected because:

a) "The downwind range within which contamination will generally not exceed the Protective Action Guides is limited to about 50 miles from a power plant because of wind shifts during the release and travel periods; b) "There may be conversion of atmospheric lodine (i.e. , iodine suspended in the atmosphere for long time periods) to chemical forms which do not readily enter the ingestion pathway; c) "inuch of any particulate material in a radioactive plume would have been deposited on the ground within about 50 miles from the facility; and d) "the likelihood of exceeding ingestion pathway protective action guide levels at 50 miles is comparable to the likelihood of exceeding plume l exposure pathway protective action guide levels at

! 10 miles."

The size of any area in which protective actions will be l

taken will be determined by of f-cite authorities, but Boston Edison accepts the generic guidance promulgated by EPA, FEMA and the NRC as conservatively prudent. Boston l Edison knows of no theories, assumptions, procedures, or data which would support a dif ferent conclusion.

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.1 NUREG-0396 EPA 520/1-78-016, December, 1978.

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2 NUREG-0654 FEMA Rep. 1, Rev. 1, November, 1980.

C. None D. Applicants' Direct Panel i

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i INTERROGATORY #3 t

Has BECo (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 BdW-1 to BWR-4 releases defined in WASH-1400? If so, set forth in detail the results of any such analysis, including calculations of early fatalities, early injuries, delayed injuries, developmental or genetic birth defects, and land and water contaminction.

RESPONSE #3 Boston Edison objects to this interrogatory on the ground that it is not relevant to any issue litigable in this proceeding.

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- INTERROGATORY #4 Has BECo (or anyone on its behalf or to its knowledge) conducted any generic or site-specific accident consequence analysis for accidents with containment failure modes such that the radioactive releases 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 of any such analysis, including calculations of early fetalities, delayed fatalities, early injuries, delayed injuries, developmental or genetic birth defects, and land and water contamination.

RESPONSE #4 Boston Edison objects to this interrogatory on the ground that it is not relevant to any issue litigable in this proceeding.

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INTERROGATORY #5 In the opinion of BECo, is it possible to evacuate ssfely 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 varies depending on assumptions made, provide a list of each assumption made and a description of how your response wculd dif fer 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 BECo believes should constitute the plume exposure pathway EPZ for Pilgrim II; I

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 0 sector drawn in the PSAR extended to 20 miles from the Pilgrim site.

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4:..WJ .i RESPONSE #5 A. In the opinion of Boston Edison, it is possible to safely evacuate the total permanent, seasonal, and transient

• populations in each case suggested in the interrogatory.

However, Boston Edison believes that in virtually any credible accident scenario, radiation effects beyond the plume exposure EPZ would not warrant evacuation. By answering this question, Boston Edison does not waive any objection to the litigability of the possibility of evacuting the areas described in subparts (c)-(h) of the question.

B.1 Pilgrim Station Unit 2 PSAR, Amendments 40 and Appendix 13A.

2 Massachusetts Comprehensive Emergency Response Plan.

3 Pilgrim Station Unit 2 SER.

7. None D. Applicants' Direct Panel

J_NTERROGATORY #6 In the opinion of BECo, could there ever be a need to I order protective action (s) on any portion of Cape Code or in i

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 1

> protective action (s) might be needed, and how much time would

, be available from 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, explain in detail the bases for your response, including any assumptions which you make with respect to an acceptable level of risk to the public.

RESPONSE #6 l

4 A. Boston Edison concurs with the findings of the joint NRC/ EPA Task Force which concluded i, hat "it would be unlikely that any protective actions for the plume exposure pathway would be required beyond the (roughly 10-mile radius) plume exposure EPZ", and further concluded that " detailed planning within 10 miles would provide a substantial base for exoansion of response efforts in the event that this proved necessary." (NUREG-0654, p. 12)

Generally, in the opinion of Boston Edison, the greater degree of dispersion involved in plume travel over these 4

distances would make sheltering indoors the most viable plume exposure protective action outside the plume L exposure EPZ, and that the greater time involved in plume l travel, together with the relatively lower levels of

! radionuclide concentration (compared to areas closer to i the site) would ensure that ample time would be available to implement this action.

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In the opinion of Boston Edison, protective actions l

recommended for areas outside the plume exposure EPZ would generally be limited to those associated with the l ingestion pathwry, i.e., identification and interdiction of potentially cc,itaminated foodstuffs, water supplies, and animal feeds.

B. NUREG-0654, Rep. 1, Rev. 1 l

C. None i

D. Gpplicants' Direct Panel

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- INTERROGATORY #7 The PSAR provides (at pp.13A-35 to 13A-36) as follows:

"The evacuation time estimates include no vehicle volumes associated with ispontaneous 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 tt3 two bridges. These details can allow orderly flows off the Cape at those times when they will not interfere 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 rcuted away from the bridges.

Similarly, evacuating traffic at the Sagamore Bridge traffic circle (nudes 800 and 801) would be directed down Rr','te 6A by State Police."

a) How does BECo 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 from the bridges? What , if an , , analvses has BECo performed to assist in tae n.cking of such determinations?

b) To what extent will an impediment to traffic flow out of the EPZ be allowed before traf fic 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 effect which this impediment would have on HMM's estimetes, disclosing any assumptions made.

l c) For what period of time is the Cape population likely to be prevented from leaving the Cape? What behavior can be expected from individuals aware of the accident which has occurred and wanting to leave i

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the Cape during that period of time, including individuals who are using the only family 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 froa 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 above. Specifically, to what " evacuating traf fic" does the statement refer -- traffic from the Cape?

from within the EPZ7 And which portion of Route 6A will the traffic be directed down?

RESPONSE #7 A.a Existing State Police traffic control plans provide for dispatch of two cruisers to the Sagamore Bridge from the Bourne barracks to implement closure of the bridge, and reroutir" ,e traffic. Boston Edison believes that the State ' are suf ficiently experienced in traf fic control to adequately determine for themselves the requisite traffic management response. However, it would be fairly obvious if spontaneous evacuation of the Cape were to interfere with evacuation of the EPZ. Traffic would begin to form queues at the Route 3 and Route 3A approaches to the Sagamore Rotary Circle. When this ef fect is evident, State Police can halt the flow of vehicles across the Sagamore Bridge.

HMM is in the process of developing suggested revisions to the evacuation traffic management plans for consideration by the State and local police. These plans will include

I explicit directions for traf fic control at and near the two bridges. Boston Edison expects these draft evacuation traf fic management plans to be ready for discussion purposes in August 1981.

b. As explained in response 7a, Bosten Edison believes that the Sagamore Bridge should be closed at the first sign of queuing on the Rcute 3 and Route 3A approaches to the Sagamore Rotary. State Police m ay elect to close the bridge even before queuing takes place, however, as noted L above.

As stated by HMM in the paragraph cited in this interrogatory, "The evacuation time estimates include no

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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 crderly flows of f the Cape at those times when they will not interfere with the evacuatio.' of the EPZ. "

c. It is possible that of f-Cape movements could be halted at one or both bridges for several hours. A maximum delay of six to seven hours it conceivable with the simultaneous

< evucuation of the entire EPZ.

Boston Edison has not attempted to predict the behavior of persons wishing to leave the Cape during such a scenario.

d. As stated in response 7a HMM is currently working on draft plans for traffic management at and near both bridges. Until these plans are discussed with and adopted by the State Police (and Bourne Police), this questico

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r cannot be answered by Boston Edison. It ic expected that discussions of the traf fic control plans suggested by HMM will take place during August 1981.

e. HMM refers to southbound evacuation traffic departing from the EPZ. The reference to Route 6A, however, is a typographical error. The southbound traffic departing the EPZ (through nodes 800 and 801) will he directed to the southwest, towards Buzzards Bay, on Route 6.

B. Pilgrim Station Unit 2, PSAR, Amendments 40 and 41, Appendix 13A.

C. None D. Applicants' Direct Panel 4

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e INTERROGATORY #8 In the opinion of BECo, are there adequate facilities available to shelter simultaneously the total permanent and peak seasonal and transient populations in mach 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 Iccated within 20 miles of'the Pilgrim site; d) Each of the 10-mile 900 sectors drawn by BECo for purposes of estimating evacuation timed; 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 factors associated with each type (providing separate figures for wood-frame houses with no basements, wc?d-frame houses with basements, masonry houses with no basements, masonry houes with basements, and large of fice, industrial or public buildings), describe the nature and location j of the shelter to be used by the transient and seasonal oopulations, and disclose any assumptions which you are mt. ing as l

to an acceptable level of risk to the public. The te1m

" shielding factor" as used herein means the ratio of the dose received inside the structure to the dose that would be received l

outside the structure.

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RESPONSE #8 A. It is the opinion of Boston Edison that there are adequate facilities available in those commun

• es surrounding the Pilgrim Nuclear Power Generating Station to shelter the total permanent and peak seasonal and transient populations.

Information is not available with which to accurately estimate the number of shelter facilities avallanle in each of the areas specified in the interrogatory. Information does axist with which to estimate the sheltering capabilities in terms within the 10-mile EPZ and in Barnstable County, however, this information does not af ford the level of detail or accuracy called for in the j interrogatory.

Sheltering of persons in the event of an emergency situation at the Pilgrim power station would be primarily accomplished through a " shelter-in-place" notification utilizing the existing homes and businesses in the area. All of the permanent residents and those transients working in the towns around the power station would remain in their structures according to instructions to be provided by local and state Civil Defense of ficials.

In addition to these facilities, spaces are available in public buildings and of fices which could accommodate peak stastaal populations and those persons who may be away from their homes or businesses at the time of notification of an emergency. For the towns within the 10-mile EPZ a total of approximately 25,500* public -Fa'.ter spaces currently exist, with another approximately 374,000 spaces upgradable to a category 2 level of protection.

• This figure includes the 7 towns either partially or wholly within the EPZ and assumes a 10% existing ratio for the Plymouth total of both existing and upgradable spaces.

In a study done for Boston Edison by HMM Associates it was concluded that 300,000 persons could be provided with significant sheltering from radiation in Barnstable County in spaces currently available in public shelters with no 1

modification. The report also concluded that up to 1.1 million public shelter spaces could be upgraded to a protection factor category 2 with minimal effort.

Information regarding the " shielding factors" of various

, buildings and structures is contained in the documents

{ referenced below.

B.1 Potential for Providing Radioactive Fallout Shelter in Barnstable County, September 1979.

2 U.S. Army Corps of Engineers Shelter Survey Data,1980 C. None D. Applicants' Direct Panel 4

INTERROGATORY #9 Describe in detail any design modifications whjch could be made to Pilgrim II as proposed to reduce the early and/or delayed fatalities and/or health effects associated with accidsnts. 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 figures for reductions in early fatalities, early injuries, delayed fatalities, delayed injuries, and developmental or genetic birth defects).

RESPONSE #9 Boston Edison objects to this interrogatory on the ground that it is not relevant to any issue litigaole in this proceeding, and on the grounds set forth 1,9 the objection of the Staff to interrogatory #15 propounded to the Staf f. Without waiving this objection, Boston Edison has not made any such study.

INTERROGA10Rf #1C The PSAR provides (at p. 13.3-47) that BECo will

" recommend to civil authorities those protective actions as described in EPA-520/1-75-001(Rev. 6/79) . "

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 BECo, would the administration of radioprotective drugs to individuals off-site ever be neceasary or desirable in the event of an accident et Pilgrim II? If not, why not? If so, to what radial distance from the site could dissemination of druDs be necessary? What is the maximum quantity of potassium iod.ide or other radioprotective drug that could be ne23ed? What means does BECo 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 quantitles are maintained?

RESPONSE #10 A. Question 10, involving recommendations to civil authorities on protective actions, involves three questions on the use of radioprotective drugs, each of which is answered separately below.

a) Boston Edison will recommend to civil authorities those protective actions which they are prepared to carry out, as indicated by state and local response

7 plans. In the absence of a policy and program for the administration of radioorotective drugs, Boston Edison's recommendations for the plume exposure EPZ would be limited to shelter, evacuation, control of access to af fected areas, and inhalation protection.

b) It is Boston Edison's understanding that the Massachusetts Department of Public Health (MDPH) has not completed formulating its policy on the use of radioprotective drugs, but that it is unlikely that this policy will involve provisions for administration of such drugs to the general public.

If the MDPH determinas that use of radioprotective drugs will be necessary or desirable, provisions for storage, stockpiling, and dissemination will be msde by of f-site authorities and reflected in of f-site response plans.

c) In the opinion of Boston Edison, the necessity or desirability of administering radioprotective drugs

to individuals eff-site is properly a decision to be made by medical and health physics professionals of the MDPH. Based on their determinations, the MDPH would also be responsible for providing fcr implementation of the protective action.

Impicmentation would include developing guidelines on populations and areas involved, and storing, stockpiling and disseminating radioprotective drugs. Boston Edison recognizes the responsibility of the MDPH in this area, and will support the Departnent's policies and programs.

B. Massachusetts Radiological Emergency Response Plan, Section B-1, December 1979.

C. None D. Applicants' Direct Panel

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INTERROGATORY #11 What is BECo's understanding es to the meaning of the provision in App. 3, Section C of the Comeonwealth 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 the Sagamore Bridge and re-route traffic to the Bourne Bridge using the by-pass on the East side of the Canal."

Does the reference 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 left 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 family 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.

RESPONSE #11 A. It is Boston Edison's interpretation that the State's Emergency Response Plan directs the State Police to block the approach to the Sagamore Bridge from the Cape side of the bridge. Westbound traf fic fr am Route 6, the Mid-Cape Highway, would then be directed southwest, on the by-pass l on the Cape side of the canal to the Bourne Rotary (on the i

j southeast s'.de of the canal).

Boston Edison has no basis for estimating the number of cars which would desire to travel from the Cape to the EPZ during an evacuation.

8. The Massachusetts Radiological Emergency Respor.se Plan, Attachment C.I.

C. None D. Applicants' Direct Panel

.a INTERROGATORY #12 In the opinion of BECo, if an accident occurs at Pilgrim II on a weekday during working hours what percentage of the permanent population within tne plume exposure pathway EPZ drawn in the PSAR 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, disclosing any assumptions made and indicating the effect on your answer of changing each such assumption.

RESPONSE #12 A. Thers is no data base which can provide a well-founded response to this interrogatory.

B. None C. None D. Applicants' Direct Panel

INTERROGATORY #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-ambulatory? Explain the bases for your answers in detail, disclosing any assumptionc made and indicating the effect on your answer of changing each such assumption.

RESPONSE #13 A. Boston Edison assumes that nearly none of the transient or seasonal population will be dependent on others for tran;portation. This population segment would leave the EPZ in the vehicles in which they entered it. Boston Edison also assumes that a maximum of 10% of the households in the plume exposure EPZ are without automobiles of their own.

This estimate is based on 1970 Census data that indicates that 15% of the households in the Town of Plymouth were without automobiles in 1970, and about 6% of the households in rural non-farm areas in Massachusetts were without automobiles. Boston Edison further estimates that about 90%

of the autoless households will be transported by friends, relatives, or neighbors during an evacuation. This leaves approximately 1% of the permanent population, or about 500-600 people, that might be expected to rely on publicly provided transportation to evacuate. Assuming 40 people per bus, about 15 bus trips could accommodate this demand.

Boston Edison has no data upon which to estimate the number of nonambulatory residents of the EPZ which would be dependent on public transportation.

B.1 Housing Characteristics for States, Cities, and Counties, Volume I, Part 23, Massachusetts, August 1972.

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. , 2 Pilgrim Station Unit 2 PSAR, Amendments 40 and 41 Appendix 13A.

C. None D. Applicants' Direct Panel

. INTERROGATORY #14 What is the appropriate method of accounting for ambulatory and ncn-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 failure and describe in detail any substitute methodology which was employed by HMM.

RESPONSE 614 A. In the opinion of Boston Edison, HMM Associates used an appropriate method to account for public transportation dependent populations, both ambulatory and nonambulatory, in calculating evacuation time esti ;tes.

In developing demand estimations, HMM estimated auto occupancy by permanent residents and transients, and described special populations, including schools, on an institution by institution basis, as provided in Section Il o f Appendix 4 of NUREG-0654. K4M further used conservative distribution functions in loading the modeled traf fic network as provided for by Section IVB of Appendix 4 to NUREG-0654. The conservative preparation time estimates implicitly reflected in the model reflect, in part, the greater mobilization times involved in assembling public transport capabilities.

Additional conservatisms similarly reflect, in part, extra time needed to evacuate the public transportation dependent. The analysis, for instance, reflects 9 conservative 2.5 permanent residents per evacuating vehicle. This assumption overpredicts the number of vehicles on the road, since there are more than 2.7 persons per household in Plymouth County, and since no reduction in auto traffic was ascribed to carpooling among

neighbors. The resulting overprediction in vehicles in use also accounts for vehicles used to transport evacuees to pick-up points, and to evacuate them.

The response to Interrogatory #27 amplifies the nature of tl:ese conservative loading assumptions.

B. Pilgrim Station Unit 2 PSAR, Amendments 40 and 41, Appendix 13A.

C. None D. Applicants' Direct Panel I

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INTERROGATORY #15 In the opinion of BECo, how much time will be required to evacuate the public transportation-dependent population within the 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.

RESPONSE _f15 A. Boston Edison believes that the public transportation dependent population can be evacuated within the time frames estimated for the general evacuation scenarios.

For example, Boston Edison feels that the public transport

)

dependent population within the entire EPZ could be evacuated within 6-7 hours. This estimate is based on the relatively limited number of persons Boston Edison expects to seek public transportation. (This estimate is outlined in the response to interrogatory #13. ') Boston Edison believes that 500-600 people can readily be collected and evacuated in this time frame with transportation resources available to state and local emergency authorities.

B. Pilgrim Station Unit 2 PSAR, Amendments 40 and 41, Appendix 13A.

C. None D. Applicants' Direct Panel

- . INTERROGATORY #16 In the opinion of BECo, how much time will be requireo to evacuate fully the population of each of the special facilities discussed at pp. 13A-32 to 13A-33 of the PSAR7 Disclose all assumptions made, indicating the effect on the estimates of changing each such assumption.

RESPONSE #16 A. It is Boston Edison's understanoing that the Massachusetts Civil Defense Agency (MCDA) is currently examining the facility-specific emergar.cy response plans for these special facilities. Tnese ef forts include discussing with the facility operators the feasibility of evacuation as a protective action, transportation needs for evacuating, and plans for menaging responses to an accident at Pilgrim Station. At this time, ao facility specific time estimates are available. It is likely that these estimates will be available this Fall.

B. None C. None D. Applicants' Direct Panel

INTERROGATORY #17 In the opinion of BECo, how many non-resident employees work within the plume exposure pathway EPZ drawn in the PSAR on summer weekends? Explain the bases for your answer in detail, dis: losing any assumptions made and indicating the effect on your answer of changing each such assumption.

RESPONSE #17 A. Boston Edison has nte data describing the number of nonresident employees working within the EPZ on summer weekends.

B. None C. None D. Applicants' Direct Panel l

. INTERROGATORY #18 NUREG-0654, App. 4, provides (at p.4-E) that, in preparing evacuatico time estimates, "The number of permanent residents shall be estimated using the U. S. Census data or other reliable data, adjusted as necessary, for growth." [ Emphasis supplied.]

In the opinion of BECo, what is the appropriate target date for adjusting population figures for growth -- the expected terminal date of operations, etc.? Why did HMM Associates use unadjusted 1980 data in arriving at its estimates? Explain your answers in detail.

RESPONSE #18 NRC has recently requested that Boston Edison prepare 2stimates of the evacuation time for Pilgrim Station to account for population growth through 1990. Accordingly, Boston Edison has authorized HMM to begin such an estimate.

This estimate will be completed by September 1983.

Boston Edison concurs that 1990 is a reasonable future date to be studied. This date is reasonable since the combined potential for errors in population projections, projections of highway improvement, and projections of the state of transportation technology make estimates for dates further in the future extremely speculative.

At the time HMM did its evacuation time estimates (summer 1980), Boston Edison had received neither the guidance cited in the interrogatory (see response to Interrogatory #30 for an explanation of the chronology of NRC evacuation time estimate guidance), nor the NRC request to provide evacuation time estimates for a future date.

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O. Non?

C. None D. Applicants' Direct Panel l

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INTERROGATORY #19 i

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 emerge.1cy even though it is indicated by the applicable EAL?

RESPONSE #19 A. Under the preliminary emergency plans set forth in the PSAR, emergencies of variou ' classifications will be declared whenever the Emergency Action Levels indicate that such declarations are in order. The Emergency Director will not have the discretion not to declare an emergency in such circumstances.

B. Pilgrim Station Unit 2 PSAR, Amendments 40 and 41.

C. None D. Applicants' Direct Panel e

INTERROGATORY #20 Will BECo notify state and local authorities within 15 minutes of the declaration of an Unusual Event? If not, within what period of time from 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?

RESPONSE #20 A. Bocton Edison will maintain a capability to notify state and local authorities of any emergency or potential emergency within 15 minutes of its declaration. State and local authorities will be notified in accordance with provisions of of f-s'te emergency plans, and through procedures reflected in on-site plans. Presently, plans provide for immediate notification of an unusual event to State officials and to the Town of Plymouth. The substantive content of such notifications will depend on the nature of the event, but will generally contain information on: the class of the emergency (unusual event) and its nature; whether a release is takir g place or expected; potentially aff ected population and aresas; whether protective actions may be necessary; and xequests for assistance, if required. Follow-up messages will be consistent with emergency plan orovisions and applicable federal guidance (NUREG-0654).

B. Commonwealth of Massachusetts Radiological Emergency l

i Response Plan, Section C, Pilgrim Area Plans.

C. None D. Applicants' Direct Panel l

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. IriTERROGATORY #21 BECo 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 first-line and second-line agencies all be notified of an emergency within 15 minutes of its declaration or is it only the first-line 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?

RESP,0NSE #21 A. All off-site public agencita reflected in the notification diagram will be notified of an Alert, Site, or General level emergency classification within 15 minutes of its declaration.

B. Pilgrim Station Unit 2 PSAR, Amendments 40 and 41.

C. None i

D. Applicants' Direct Panel l

_ - - . _ _ .~. _ -. _ -_-- __- - , . . -. . - _.- . - .--... -

INTERROGATORY #22 What, if any, analyses or studies have been conducted by or for BECo of past traffic jams 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 BECo has made thereof.

RESPONSE #22 A. Boston Edison has conducted no formal studies of past traffic jams in Plymouth and/or on Cape Cod for purposes of evacuation planning. Certain testimony and documents regarding traffic flow for zoning purposes were prepared for Boston Edison, and of fered in evidence in Hall v.

Franks, Plymouth Superior Court No. 77-5106 (Findings and Judgment entered October 1977, and available from the Clerk of the Court).

j B. None C. None D. None i

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INTERROGATORY #23 In the opinion of BECo, what is the proper way to account for 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 insuf ficient fuel at the commencement of the evacuation, to the knowledge of their ownars;

d. disregard of traffic control devices;

e. evacuees using inbound traf fic 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 acccunted for each of these possibilities or, if it did not account for any one or more of these possibilities, describe the effect 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 l problems.

l l

PESPONSE #23 A. In Boston Edison's opinion, there are no proven predictive techniques for accounting for the incidents outlined in j the interrogatory. Therefore, HMM did not attempt to model the infinite range of possibilities suggested in the interrogatory and Boston Edison does not feel that it is i possible to ".. .descriLe the ef fect of accounting for each such possibility.. ." in a realistic and useful manner.

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• - In its current planning efforts, MCDA is addressing some of these issues, however. The Emergency Planning Information brochure being prepared, for example, will advise those with cars in poor repair or with little fuel to seek transportation in another vehj le. Likewise, public informational messages will be instructive on these matters. It is Boston Edison's position that, with proper planning, public information and instructions, the evacuating public will behave rationally with minimal disruptions to planned action. Where breakdown incidents occur, the public and the local emergency response personnel will be able to deal with the situations that arise. This position is supported by available literature. In 202 disaster field studies, Ohio State University researchers concluded that "Those who experienced disasters are not immobilized by even the most catastrophic of events. They are neither devoid of initiative, nor passively dependent or expectant that others. . .will take care of them and their disaster created neeos."* Additionally, the conservative assumptions of the model usea by HMM Associates to develop the evacuation time estimates help to account for the referenced possibilities. These assumptions are discussed in the response to Interrogatories #27 and 29.

B.

• Evacuation Risks - An Evaluation, EPA-520/6-74-002.

C. None l D. Applicants' Direct Panel

- INTERROGATORY #24 The letter reproduced at App. 8, p. B-1 of Supplement

?!c. S to NUREG-75/054 contains a recommendation chat southbound Route 3 be closed at Route 128. Does BECo endorse this recommendation? If so, how does BECo expect that the Town of Plymouth will obtain the additional buses which it currently plans to have dispatched from towns north of the proposed EPZ to Plymouth via Route 3? Has BECo discussed with Plymouth officials the need for revisions in that plan? If BECo disagrees with the recommendation for closing southbound Route 3, that 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?

RESPONSE #24 l A. Boston Edison feels that a determination to close Route 3 (southbound) at Route 128 should be lef t to the discretion of the State Police. As a practical matter, however, Boston Edison believes the access controls described in the State Plan are adequate. Rather than closing Route 3 (southbound) at Route 128, the State Police plan to control access to Route 3 (southbound) at Route 228, which is about nine (highway) miles southeast of the Route 3/ Route 128 interchange, but still about 22 miles from Pilgrim Station. Thus the present pJan preserves access to Quincy, Hingham, Cohasset, and Scituate.

Boston Edison fails to see how the choice of access control points will affect the availability of buses dispatched from the north. Emergency vehicles would be pGssed through either access control point, if necessary,

, O but it is more likely that the buses would be dispatched from towns within either control point. This being the case, Boston Edison foresees no change in evacuation time estimates.

It should be noted that Boston Edison and MCDA are in contact with Plymouth and other towns on a continuing basis. State and local plans are discussed and updated frequently as the basis for emergency planning changes and provisions for modification to such plans, when and if required, can be made by local officials with assistance from the State.

B.1 The Town of Plymouth Radiological Response Plan, December 1980 3

2 Attachment C.1-6 to the Massachusetts Radiolgoical Emergency Response Plan (June 1981 draft).

C. None D. Applicants' Direct Panel I

O

. . INTERROGATORY #25 Has FEMA conducted any off-site drills at Pilgrim? If so, describe in detail the findings and conclusions resulting therefrom. If not, when will such drills take place? l 1

RESPONSE #25 A. It is not the responsibility of FEMA to conduct off-site ,

drills at Pilgrim. Of f-site drills are conducted by the state, with local participation. Observers from FEMA, or members of its hegional Assistance Committee (RAC), are often invited to monitor or critique these drills. Orills and exercises for Pilgrim II have not yet been scheduled.

B. NUREG-0654/ FEMA. REP. 1, Rev. 1, Part II, Section N,

" Exercises and Drills".

C. None D. Applicants' Direct Panel

s

. . INTERROGATORY #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 ran by Battelle for the NRC Staff and the EVAC model run by HMM) run by or for BECo for the purpose of simulating the evacuation process at Pilgrim and/or estimati.sg evacuation times for the Pilgrim area. Provide a detailed description of any such computer model, RESPONSE d26 A. In addition to the evacuation analysis reported in the PSAR, HMM has prepared another draf t report of evacuation times for the exposure pathway EPZ, which is entitled Evacuation Time Estimates for Areas Near Pilgrim Station, February 4, 1960.

These estimates were compiled in response to the NRC Emergency Preparedness Task Group letter dated November 29, 1979. This NRC request for evacuatlun time estimates was sent to all licensees authorized to cperate a nuclear power reactor (hence Boston Edison was included as the operator of Pilgrim Unit I), and to all applicants for a license to operate a power reactor with a cocketed FSAR. These original evacuation time estimates were undertaken using NETSIM, a Federal Highway Administration computer model. The cases modeled, assumptions, results, and a description of the nodel are included in the draft report.

In addition, HMM is current)y preparing the analysis described in the answer to Interrogatory #18, above.

. . 3oston Edison ob.jects to this interrogatory to the extent that it calls for analyses other than for the plume exposure pathway EPZ.

B. None C. None D. Applicants' Direct Panel 1

y m, , . - - ~ , . + ~ . . , , - , , , ,.-r,...., _ - . . , _ , ., - . - . . , , , . , ,,,..e.,,_ - m%_ .- - , . . , - . . . , , , , - . . . ~ ~ , . . . - . .

INTERROGATORY #27 Ths PSAR states (at p. A-2) that, in calculating evacuation time estimates, HMH assumed that the evacuation traffic network was empty at the commencement of the evacuation. Explain in detail the reasons why BECo believes this is an appropriate assumption and the effect which changing that assumption would have on HMM's estimates. In the opinion of BECo, what is the aver 0ge daily traffic flow on that portion of Route 3 which is included in the evacuation traffic network?

RESPONSE #27 A. In Annex D to Appendix 13A o f the PSAR Amendment 40, October 10, 1980, assumptions incorporated into the evacuation simulation inodeling are outlined. On page 13A-98, assumption number 18 explains that HMM

" Assumed empty network at start e.g. , non-resident or non-transient cars on network were not accounted for. It was assumed that residents cars originate from homes. Pass through traffic on Route 3 going between Boston and Cape not included."

This was a simplifying assumption necessary to undertake evacuation time calculations. Such an assumption presumes that the evacuation, per se, begins with the actuel attempt of the vehicle to leave the plume exposure EPZ.

The assumption further presumes that work to home trips, and any other trips within the EPZ that are not specific to exiting the EPZ, are part of the " preparation to evacuate" rather than the evacuation per se. HMM implicitly handled the effects of the preparation pericd phenomena with its loading rate assumptions. As explained in assumption number 6, on page 13A-97, cars were loaded onto the evacuat16n network, from the entry nodes, at the rate of 15 cars per minute. The resultant staggered

, initiation of evacuation movements is considered a reasonthle means for considering the time required to prepare for evacuation. Only the evacuation movements, per se, were explicitly simulated by the modeling.

A more explicit simulation of the preparation to evacuate is not feasible. Such a simulation would involve modelirg movements of traf fic from place of work to home and movements of vehicles on the network to home, then simulating the evacuation movements exiting the EPZ. For such an explicit simulation, an analyst would require a reasonable basis for estimating initial traffic volumes on the network and a reasonable basis for estimating origins and destinations of the vehicles on the network. No such data base exists, nor could an analyst reasonably be expected to compile one. Furthermore, there is currently no simulation model available to handle such a complex data set. HMM chose not to undertake its simulations with a partial loading of the network with pre-evacuation traf fic to approximate " friction" associated with conflicts between the traffic preparing to evacuate and the actual evacuation movements, because such an assumption would result in a considerable double-counting error. The autos on the network at the time an evacuation is initiated would be the autos of the population to be evacuated (with the single possible significant exception of traf fic on Route 3*). An t

assumption to evacuate autos on the network, as well as autos from residences and transient population locations, l

l

• Many of the automobiles on Route 3 could be through traffic.

In the opinion of HMM, however, there is little potential for the through traffic to compete with evacuating traffic on Route 3. Traf fic entering the EPZ could be ef fectively halted by State Police before the evacuation was initiated. This would leave only travel time through the EPZ required for this tr a ffic volume. Approximately 20 minutes would be required to trnvel the length of Route 3 within the EPZ. This t;avel time could be accomplished during the public notification process j

rather than uuring the evacuation.

1

r

, , would therefore be incorrect. Such a technically incorrect assumption appears to provide little or no advantage over implicitly considering the possible initial evacuation traf fic conflicts with the d6ferred loading assumptions.

Changing the assumption of an empty network could affect tha evacuation time estimates in a number of ways. If the network were to be loaded with a corresponding decrease in the number of cars loaded at the designated entry nodes (to eliminate double countingh the evacuation times would probably be reduced. If the network were partially loaded with traf fic, with no reduction in volumes to be loaded at the entry nodes, little or no increase in the evacuation times would be likely. If the network were heavily 1ocded, with no corresponding reduction of vehicles loaded at the entry node to reduce douDie counting, an increase in predicted evacuation times could be expected but the results for the reasons set forth above, would not be meaningful.

Boston Edison had no request or requirement to study average daily traf fic on the portion of Route 3 which is included in the evacuation traffic network. For this reason, it has no opinion regarding average daily trafile flow on that or any other local highway.

B.1 Pilgrira Station Unit 2 PSAR, Amendment 40 and 41, Appendix 13A.

2 Massachusetts Comprehensive Emergency Response Plan.

C. None D. Applicants' Direct Panel

. . _ . . .. -- - .- - -- . ~ . - . .

I INTERROGATORY _#28 The PSAR contains two mutually inconsistent statements.

It states (at p. 13A-15) that HMM Associates, in calculating l Its evacuation time estimate 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.

RESPONSE #28 A. The statement on page 13A-15 is correct. The adverse

weather cases were simulated using 70% of the normal weather highway capacity. To resolve the inconsistency, assumption number 14 on page 13A-98 should be revised as follows: "14) Network capacity decreases to 70% of normal weather capacity during adverse weather."

8. Pilgrim Station Unit 2 PSAR, Amendment 40 and 41,

. Appendix 13A.

C. None D. Applicants' Direct Panel i

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INTERROGATORY #29 Did HMM assume, in calculating its evacuation time estimates for the adverse weather case, that the adverse weather condition af fected travel speed? If so, what effect did HMM assume? If not, explain in detail the reasons why BECo believes HMM's estimates are accurate without accounting for this effect.

RESPONSE #29 A. Ef fects on travel speed were implicitly included in the analysis in the form of reduced highway capacities. Durlog adverse weather each roadway in the network was modeled as having 70% its normal weather capacity (i.e. , a roadway capable of handling 1,000 cars per hour during normal weather was able to serve only 700 cars during adverse weather). The reduced capacities caused lower travel speeds, particularly where there is traf fic congestion (i.e. , where volume / capacity ratios are high).

In the past, HMM has informally tested the ef fects of adding caps te vehicle speeds at other sites. Those unpublished test s indicated that there is little or no change in evacuation times caused by assuming both reduced capacity and reduced travel speed. Vehicle delays were almost entirely dependent upon highway capacity rather than travel l speed, except for extremely low population situations where l there is no potential for traffic congestion. Since the Pilgrim EPZ is not such an extremely low population site, HMM judged a cap on travel speeds to be unnecessary.

B. None C. None D. Applicants' Direct Panel 1

. . INTERR00ATORY #30 HUREG-0654 provides (at p. 4-6) that in calculating cyacuation 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."

What, in the opinion of BECo, 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 estimats assuming that condition for each of the evacuation cases considered in the PSAR. Disclose all other assumptions made. If your choice of the adverse weather condition is anything other than a summer rainfall occurring mid-day on a summer weekend, explain your rejection of that condition and provide an evacuation time estimate assuming that condition for each of the evacuation cases considered in the PSAR. Again, disclose all other assumptions made.

RESPONSE #30 A. The citation offered in this interrogatory is an excerpt from NUREG-0654 Rev. I which postdates Amendment 40 to the Pilgrim Station Unit 2 PSAR. The PSAR Amendment is dated October 10, 1980; the NUREG publishing date is November 1980, but Rev. I was not generally available until January and February 1981. No such guidance existed during the preparation of the evacuation time estimates for the PSAR Amendment. The more applicable guidance considered by HMM was contained in a letter from the NRC staf f dated July 2, 1980, which incorporated guidance issued as NUREG-0654, l

Appendix 4, issued in January,1980, for interim use and l

I comment. A copy is attached to this response.

It should also be noted that the citation, if expanded slightly, reads as follows: "More than one adverse condition may (emphasis added) need to be considered. That

[

is a northern site with a high summer tourist population i should consider rain, flooding, or fog as the adverse condition as well as snow with winter population estimates". In compiling the evacuation time estimates, HMM did consider adverse summer weather, but decided against modeling it. The decision not to modal this case was based on the fact that peak summer population would not occur during such an adverse weather situation. For example, it is unlikely that peak occupancy could be expected at hotels, motels, and guest houses (peak use is 2,448 persons per Table B-3, Annex B, Appendix 13A, PEAR Amendment 40); at camps and campgrounds (peak use is 5,202 persons per Table B-4); at tourist and historic sites (peak une is 2,745 per Table B-7); and at public beaches and parks (peak use is 346,213 per Teole B-8) during adverse summer weather. In addition, the peak seasonal population of 24,002 (Per Figure 4) would be greatly reduced during adverse weather. Seasonal home owners might cancel or curtail weekend trips to seasonal homes and weekend visitors to seasonal homes would be reduced during inclement weather. HMM concluded that these reductions in transient and seasonal population would offset highway capacity lost to adverse summer weather and modeled the adverse winter weather cases to fulfill the single adverse weather case suggested by NUREG-0654 at the time.

In Boston Edison's opinion, the cases modeled for inclusion in the PSAR remain reasonable choices. The peak summer population case postulated for study is likely only a j

handful of times per year. The adverse weather cases, with I less than peak summer population, are also likely a handful of times per year. In Boston Edison's opinion, evacuation scenarios more difficult than those reported in the PSAR would have such a low probability that they would be of little use to State and local agencies engaged in emergency planning.

. , 8.1 Pilgrim Station Unit 2 PSAR, Amendment 40, Appendix 13A.

2 NUREG-0654 Rev.1 Appendix 4, November 1980.

4 3 NUREG-0654 Appendix 4, January 1980.

C. None

, D. Applicants' Direct Panel 4

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INTERROGATORY #31 In the opinion of BECo, did HMM Associates, Inc. properly account for every reasonably foreseeable external event in calculating its evacuation time estimates? Did it account for 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 failure to account therefor.

RESPONSE #31 A. Yes.

3 The HMM studies were designed to be responsive to the NRC guidelines originally suggested to Bosten Edison in a letter of November 29, 1979. This letter, which was subsequently incorporated, almost in toto, as Appendix 4 of NUREG-0654, January 1980, suggests that each nuclear power plant operator develop evacuation time estimtes for up to 20 scenarios. The following excerpt from the letter outlines the guidance suggested by NRC:

"The areas for which evacuation estimates are required must encompass the entire area within a circle of about 10 miles radius, and have outer boundaries corresponding to the plume exposure EPZ. These areas are as follows:

Distance Area 2 miles two 180 0 sectors 5 miles four 90 U sectors about 10 miles four 90 0 sectors Estimates for the outer sectors should assume that the inner adjacent sectors are being evacuated simultaneously. To the extent practical, the sector boundaries should not divide densely populated areas...

i l

Two estimates are requested in each of the areas i defined in item 1 for a general ev3cuation of the I population (not including special racilities). A l best estimate is required and an adverse weather 1 estimate is required for movement of the population."

To provide the suggested information, HMM developed a total of twenty-four cases to be modeled with the EVAC traf fic simulation model. These cases include eight geographical areas. For each of these areas, three cases were modeled.

These include:

1) Peak Population Case. This is an adverse case that includes peak summer weekend population that is unlikely to occur more than a handful of times per year, and an unconstricted roadway network. It is expected to occur on a summer weekend day.

2) Adverse Weather Case. This includes the permanent population and off-season transients. It is assumed that the roadway network is operating at 70% of its capacity due to a snow storm, or to heavy rainfall or due to other weather phenomena that could impede tra f fic movement.

3) Typical Case. This case uses the same population as the adverse weather case, but assumes good weather and unconstricted roadways. This case is typical of days from September to June.

It was Boston Edison's primary intent in studying these l cases to be responsive to the guidance provided by NRC.

At the same time, Boston Edison had the secondary objective of supplying information that could be of value

in the state and local emergency planning process. The

~

estimates provided by Boston Edison can be used to help decide whether evacuation is a feasible protective action over a practical range of circumstances. Boston Edison

( feels that the est'imates provided in the PSAR meet both these objectives.

Studying the catastrophic cases suggested in the interrogatory are not mandated by the regulatory requirement, and are of no real value to the emergency planners. The frequency of hurricanes, earthquakes and tornados put them beyond the f ounds of any reasonable

" adverse case" de finition.

B.1 Pilgrim Station Unit 2 PSAR, Anendment 40, Appendix 13A, October 10, 1980.

2 NUREG-0654 Appendix 4, January 1980.

3 NRC Letter of November 29, 1979.

C. None D. Applicants' Direct Panel

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

" parking along [a] link [is] prohibited." Explain what is meant by " prohibited" in this context. Does it mean that parking is legally prohibited? If so, how was this determined? Does it represent a recommendation by HMM that parking be prohibited along such links? Or does it merely represent an observation by HMM that vehicles de not in fact park along such links?

RESPONSE #32 A. For modeling purposes, HMM determined whether there was (T) or was not (F) parking at the downstream intersection approach for each link. The true/ false designation was determined during field studies. The "F" designation generally indicates signs prohibiting f.arking are posted in the appropriate intersection approach. In a few instances, the "F" designation represents a field l observation that no-parking situation is observed rather than signed.

B. Pilgrim 9tation Unit 2 PSAR, Amendment 41, Appendix 13A, Annex E.

C. None D. Applicants' Direct Pane!

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- - INTERROGATORY #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 from areas within the particular evacuation sectors which will be taken by each such vehicle -- buses; ambulances; tow trucks; traffic control vehicles; and vehicles to be used in notifying the public and/or confirming evacuation. Explain the bases for your estimates in detail, disclosing any assumptions made. Have these trips been accounted for in HMM's calculation of evacuation time estimates? If so, how? If not, explain in detail the reasons why BECo feels that it is not necessary to account for these trips.

RESPONSE #33 A. HMM's calculation of evacuation time estimates take into account the use of b'Jses, ambulances and other vehicles used by the public transportation dependent population in the conduct of an evacuation. The responses to Interrogatories 14, 15, and 17 explain how these trips are accounted for in calt_lating the estimates. The numbers of such vehicles (and trips) are estimated to be modest, as indicated in response to Interrogatory #13.

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Boston Edison has no firm data upon which to estimate the j number of vehicles necessary ta support an evacuation, such as tow trucks, traffic control vehicles and vehicles used to confJrm evacuation. In Boston Edison's opinion, t the commitment of virtually all town-owned vehicles to this l

l effort, as reflected in local response plans, and state capabilities to augment such resources where necessary,

! should ensure their adequacy. Since HMM's calculation of evacuation time estimates conservatively did not reflect extraordinary traf.'ic control, Boston Edison believes the

- . net result of the use of these vehicles will be to improve upon the estimates. The conservative assumptions involved are discussed in the resoonse to Interrogatory #23.

B.1 Massachusetts Radiological Emergency Response Plan, Section: A and C.

2 Pilgrim Station Unit 2 PSAR, Amendment 40, Appendix 13A.

C. None D. Applica .ts. ' Jirect Panel l

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. , INTERROGATORY #34 How does BECo anticipate that the public transportation-dependent population will get to collection points for loading onto buses? Given this method, how many collection points will be necessary within the plume exposure pathway EPZ drawn into the PSAR?

RESPONSE #34 A. Boston Edison anticipates that there will be a number of ways for the public transport-dependent population to depart the plume exposure EPZ. Disabled persons or those unable to walk a moderate distance will likely be collected from place of residence. From the residences they may be transported to collection points inside the EPZ where they board buses, or they may be removed directly to the designated reception centers outside the EPZ.

Able-bodied persons may be collected at place of residence, or they may be asked to walk to collection points established by the local Civil Defense directors. Those that walk will likely receive of fers of rides from evacuating cars of neighbors while walking to public transportation collection points.

The number of collection points necessary varies considerably based upon the evacuation scenario considered, and the number of requests received by the Civil Defense director at the time of the emergency. Local schools, fire stations, and other public buildings can be designated by each local director, as he sees fit, as collection points.

B. Massachusetts Radiological Emergency Response Plan, Section C.

C. None D. Applicants' Direct Panel

, , INTERROGATORY f35 Do there now exist the administrative and physical means to notify the public in the event of an accident at Pilgrim I required by 10 C.F.R. Part 50, Appendix E, Section IV, D. 3 and NUREG-06547 If not, when will those exist? If so, explain in detail the notification system which has been established arid its capabilities, including the time witnin 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 notification scheme which might be employed in the event of an accident at the Pilgrim site.

RESPONSE #35 Boston Edison objects to this interrogatory on the ground that 10 CFR, Part 50, App. E, Part IV does not apply to this application for a construction permit for Pilgrim 2.

INTERROGATORY #36 Assuming the existence of a notification system in compliance with 10 C.F.R. Part 50, Appendix E, and NUREG-0654, how much time does BECo 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 fcr both simultaneous and staggered notification. Explain the reasons for your answers in detail.

RESPONSE #36 A. Boston Edison believes that 30 minutes should be added tu the dvacuation time estimates compiled by HMM to account for notification and initial preparation. There is no basis for revising the estimates with the assumption of staggered notification.

B. The basis for this response is outlined in greater detail in the response to Interrogatory #38.

C. None D. Applicants' Direct Panel l

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. , INTERROGATORY #37 l

t Does BECo recommend staggered notification of the public in the event of an accident at Pilgrim II? If so, who does BECo expect to make the de;isions Ss to what segments of the population will be notified at what times? If the decision is to be made cy one or more state officials, will local of ficials 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 notice will await such notice before evacuating? Explain your answers in detail.

RESPONSE #37 A. Boston Edison does not recommend staggered notification.

Staggered notification will become impractical with the installation of the audible alert system. All those within the EPZ will receive the initial audible alert simultaneously. After receiving the alert, the public will tune in to the appropriate television and radio stations for notification messages which will describe the nature of the incident and protective actions to be taken. Boston Edison sees no reasonable means for staggering this process.

B. Pilgrim Station Unit 2 PSAR, Amendment 40, Appendix 13A.

C. None i

D. Applicants' Direct Panel

. . INTERROGATORY #38 Explain in detail the bases for the omission from the evacuation time estimates calculated by HMM of preparation / mobilization and confirmation times. In the opinion of BECo, how much time should be added to those estimates to account for these components of evacuation time?

Explain your answers in detail.

RESPONSE #38 A. HMM did not omit consideration of preparation / mobilization and confirmation times from its calculations. These times are incorporated in the evacuation network loading rate assumptions and in the notification and confirmation time discussions. On page 13A-33 of the PSAR Amendment 40, notification times of 35-60 minutes are cited. It is concluded that a portion of this time should probably be added to the clear times outlined in Table 5-1. Vehicles are loaded onto the evaccation network at the rate of 15 cars per minute over the course of up to 125 minutes, depending on entry node location and evacuation scenario.

Together the notification times and loading rates provide for considerable preparation and mobilization times (up to 2-3 hours for some evacuees).

On page 13A-34, the PSAR states that:

" Confirmation of evacuation will be undertaken by the same teams which are currently planned to be used to provide public notification. The confirmation will be provided by brief visual inspections for indications of continued human activity in an evacuated area. MCDA suggests that confirmation times for this process will be the same as the notification times estimated without the presence of an early warning system."

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- - In short, confirmation is estimated to require 35-60 minutes.

In Boston Edison's opinion, a period of about 30 minutes is a reasonable increment to add to the clear tine estimates outlined in Table 5-1 (p.13A-29) of the PSAR with an audible alert system in place. This would allcw 15 minutes from initial alert to completion of notification and 15 minutes of preparation prior to the departure of the first evacuating automobile. Boston Edison concurs with the comfirmation time estimates supplied by MCDA.

B. Pilgrim Station Unit 2 PSAR, Amendment 40, Appendix 13A.

1 C. None D. Applicants' Direct Panel l

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r INTERROGATP' #39 E: .aln in detail the ef fect on HMM's evacuation time estim .es of accounting for the need for work-to-home travel wit' t. the evacuation traffic network at the commencement of th. evacuation period. Explain your answer in detail, providing an estimate of the rumber of vehicles which would be involved in such work-to-home travel and disclosing all assumptions made.

RESPONSE #39 A. The response to this interrogatory is contained in the responses to interrogatories number 29 and 36.

)

In compiling the evacuation time estimates, HMM compiled no estimate of the number of work to home trips, therefore this information is not available.

B. None C. None i

D. Applicants' Direct Panel l

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- , INTERROGATORY #40 Will provisions be made for direct lines of communication between Pilgrim II and the Executive Office of Public Safety?

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 affirmative, describe the direct lines of communication which will be provided.

RESPONSE #40 A. Provisions will be made for direct lines of communication between Pilgrim II and the Massachusetts Civil Defense Agency's Headquarters Emergency Operating Center at Framingham, Massachusetts. Direct communications will also be provided between Pilgrim II and the Massachusetts Civil Defense Agency's Area II Emergency Operating Center at Bridgewater, Massachusetts. The mechanism for direct communication will be 2-way radio voice transceivers, operating on two administrative frequencies assigned to the Civil Defense Agency. (Radio and/or microwave direct communication capability will also be established with the Massachusetts Department of Public elealth in Boston, the Massachusetts State Police in Middleboro, and the alert points of each town in the plume exposure EPZ).

Since Hassachusetts' plans call for the Governor and the Secretary of Public Safety to function from the Civil Defense Agency Headouarters EOC during declared emergencies, direct communications with these of ficials will also have been provided for. Alternative mechanisms for communication between MCDA and state officials are reflected in the State Plans.

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- . Additionally, the Massachusetts State House, Civil Defense Headquarters (Framingham), Civil Defense Area II EOC (Bridgewater), Massachusetts State Police Heatiquarters (Boston), Massachusetts State Police (Middleboro) and Town of Plymouth EOC are all interconnected by the National Attack Warning System (NAWAS), a dedicated land line phone system providing redundant direct communications.. Boston Edison anticipates that NAWAS terminals will be installed at each nuclear power station.

B.1 Massachusetts Con 4rehensive Emergency Response Plan, Attachment 1,Section II, " Warning and Communications".

2 Massacnusetts Radiological Emergency Response Plan, ,

Section A-2, "ilarning and Communications".

C. None.  ;

D. Applicants' Direct Panel

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INTERROGATORY #41 Explain in detail the meaning of the " radiological criteria" contained in Section 13.3.5.3 of the PSAR (at

p. 13.3-47). 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?

RESPONSE #41 A. The " radiological criteria" ar* projected doses and dose rates based on estimated or measured releases of radioactivity from Pilgrim 2 during the course of an accident. These doses and dose rates serve two purposes.

In and of themselves, they are used to clas* ify an accident into either the General Emergency, Site Emergency, or alert category. Secondly, in combination with other plant status indicators and environmental factors, projected doses and dose rates would be used to assist in formulating a recommendation for protective action.

B.1 NUREG-0654/ FEMA-REP-1, Rev. 1, Apptadix 1.

2 EPA-520/1-75-001, Manual of Protective Action Guides and l Protective Actions for Nuclear Incidents, Environmental j Protection Agency. '

l C. None

, D. Applicants' Direct Panel i

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r INTERROGATORY #42 Explain this apparent inconsistency in the PSAR:

Section 13.3.5.3 states (at p. 13.3-47) that the radiological criteria for declaring a General Emergency will be 1 Rem whole Body and 5 Rem thyroid. However, Subsection 13.3.5.4.2.2 provides (at p. 13.3-50), as an example c' a situation in which BECo will recommend sheltering for off-site populations, the case where the integrated whole body dose is projected to be "substantially below 1 rem and thyroid dose less than 5 rem."

RESPONSE d42 A. Boston Edison does not believe that the two sections cited in the question are inconsistent. As indicated in the response to question 41, projected doses and dose rates serve two purposes. In Section 13.3.5.3, the numerical values for classifying a situat ion as a General Emergency are specified. In Section 13.3.5.4.2.2, an example is provided of the manner in which projected doses are used in combination with other factors to arrive at a protective action recommendation. It should De noted that the example provided is consistent with the EPA Protective Action Guides.

! B. EPA-520/1-75-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, Environmental Protection Agency, Section 5.5.

C. None D. Applicants' Direct Panel l

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. . INTERROGATORY #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 from said reviews.

RESPONSE #43 A. Formal reviews of HMM rwacuation studies were undertaken only by MCDA. MCDA concurred in the estimates provided by HMM.

Copies of results of HMM studies ware also provided to each town in the EPZ. Informal presentations of the nature and findings of HMM studies were made on several occasions. Both group sessions and smaller sessions were held. Larger sessions included HMM, Boston Edison, MCDA, State Police, State Dep artment of Public Works and representatives from each town. Smaller sessions were conducted individually with representatives of the Towns of Plymouth, Duxbury, Carver, Kingston, and Marshfield.

Informal comments were solicited by HMM and state authorities following these sessions. Comments were generally favorable; no proposals for substantive changes were received.

1 B. None C. None D. Applicants' Direct Panel l

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. . INTERROGATORY #44 l

In the opinion of BECo, are the combined on-site and of f-site emergency plans of BECo, local of ficials, and state officials required to be in full compliance with the emergency planning measures set forth in Section III of NUREG-0718?

RESPONSE #44 Boston Edison objects to this interrogatory on the o.ound that it calls solely for a conclusion of J aw. l

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, , INTERROGATORY #45 If the answer to 44 is anything other than an unconditional affirmative, list each requirement of Section III of NUREG-0718 which is not applicable and explain the reasons for its inapplicability.

RESPONSE #45 See respor.se to Interrogatory #44.

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- - INTERROGATORY #46 In the opinion of BECo, are the combined on-site and off-site emergency plans of BECo, local officials, and state officials now in full compliance with the emergency planning measures set forth in Section III of NUREGt-0718?

RESPONSE #46 A. NUREG-0718 does not require any compliance prior to the operating license stage.

B. NUREG-0718.

C. None D. Applicants' Direct Panel l

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- . INTERROGATORY #47 If the answer to 46 is anything other than an unconditional affirmative, list each requirement of Section III of NUREG-0718 which is not currently complied with and provide, for each, the date when BECo believes the noncompliance will be corrected.

RESPpNSE #47 A. See response to Interrogatory f46.

B. NUREG-0718.

C. None D. Applicants' Direct Panel l

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. , INTERROGATORY #48 In the opinion of BECo, must emergency planning measures be designed to mitigate the consequences of hypothetica.'.

releases to the liquid pathway as a result of core melt accidents? Explain your answer in detail, citinp. any relevant Commission guidance.

RESPONSE #48 Boston Edison objects to this interrogatory on the ground that it calls solely for a conclusion of law.

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_ INTERROGATORY #49 If the answer to 48 is in the affirmative, list and explain every requirement relative to mitigating such conseqyences which applies to a 50-mile (radius) ingestion pathway EPZ for Pilgrim.

RESPONSE #49 No answer required.

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_ INTERROGATORY #50 t

In the opinion of BECo, do the combined off-si?.e emergency plans of BECo and the local and state authorities now adequately address the effects of releases to the liquid pathway resulting from core-melt accidents? Explain your answer in detail. If your ansv er is anything other than an unconditional affirmative, list each requirement which is not currently complied with and, for each, provide the date when BECo believes the non-compliance will be corrected.

RESPONSE #50 Boston Edison objects to this interrogatory on the ground j that it is not relevant to any issue properly litigable in this proceeding.

Without waiving its objection, Boston Edison says that, in the opinion of Boston Edison, the of f-site plans of state and local authorities now adequately address the effects of releases to the liquid pathway resulting from core melt accidents. Boston Edison's on-site plans will adequately providt for timely notification and provision of adequate assessment data so that -

off-site plans can be implemented in a timely manner.

The , Massachusetts Radiological Emergency Response Plan l

cstablished required protective action guides for the ingestion l pathway, for sampling of foodstuf fs and water, and for interdiction of contaminated foodstuffs and water supplies. The Massachusetts department of Public Health, assisted by the l Massachusetts Division of Marine Fisheries, which maintains a program of environmental surveillance in coastal waters near the Pilgrim site, can adequately implement protective measures. (Such j measures have been ef ficiently implemented several times in recent years as a result of Red Tide contamination of shellfish beds).

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

RESPONSE #51 Boston Edison objects to this interrogatory on the ground that it is not relevant to any issue prap rly litigable in this proceeding. Without waiving its obje'etion, Boston Edison has not analyzed the potential consequences due to hypothetical releases through the liquid pathway resulting from a core-melt accident at Pilgrim II.

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. . INTERROGAYORY #52 Describe each Pilgrim II design feature, including interdiction barriers, which BECo believes serves to mitigate the potential consequences o.' hypothetical releases through the liquid pathway as a result of core-melt accidents.

RESPONSE #52 Bostor Edison restates its response to Interrogatory #51.

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, , INTERROGATORY #53 In the opinion of BECo, does its PSAR comply with each and every item applicable to PWR's in Reg. Guide 1.97, revision 27 If your answer is anything other than an unconditional affirmative, describe in detail every item of non-compliance, the alternative approach propos.'d by BECo, and the safety justification for that alternative approach.

RESPONSE #53 A. Yes, Edison complies with Regulato;; Guide 1.97, Rev. 2.

B. PSAR Amendment #43 ( April 29, 1981) p. 'C-48.

C. None D. Applicants' Direct Panel l

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. . INTERROGATORY #SA For each measured variable identified in Reg. Guide 1.97, revision 2, Table 3, describe the instrument (s) or other methods BECo intends to use to make the measurement. Which of these ins?.ruments and/or methods have been added 'o satisfy the nost-accident monitoring needs identified in Reg. Guide 1.97, revision 27 RESPONSE 454 A. This informat.on is not available at this time nor is it required to be available by the NRC Staff. Boston Edison will describe the instrumentation to meet the requirements of Reg. Guide 1.97, Rev. 2 in the Pilgrim Unit #2 FSAR.

B. PS AR Amendment #43 ( April 29,1981) pp. IC-48.

C. None D. Applicants' Direct Panel l

- - INTERROGATORY #55 What instruments does BECo plan to install in Pjlgrim II to monitor the plant status and reactor core during inadequate or degraded core cooling conditiuns? Which of these were added in response to Reg. Guide 1.97, revision 2? What other techniques, methode and procedures does BECc intend to use to measure or determine the onset of inadequate core cooling and to measure the core temperature during degraded core cooling conditions?

} RESPONSE #55 A. Boston Edison committed in Amendment #43 to the PSAR (page IC-48) to provide a nrimary coolant saturation meter j n order to provide unambiguous indication of inadequate core cooling. This component was added in response to item 4

II.F.2 of NUREG-0718.

Boston Edison has committed to perform an investigative study to identify appropriate additiona3 equipment which could be incorporated in the Pilgrim 2 design and used to indicate inadequate core cooling. The results of this study and preliminary design information will be submitted to the NRC Staf f for review following completion of prototypical testing and prior to procurement of the equipment.

Except as stated above, Boston Edison does not understand the questien as stated, or objects to the question on the ground that it is not relevant to any issue properly litigable in this proceeding.

B. NUREG-0718 and NUREG-0737.

C. None D. Applicants' Direct Panel

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. . INTERROGATORY #56 What instruments does BECo plan to install both on-site and of f-site to messere continuously lodine and other halogens in the Pilgrim II plant? What are the monitoring ranges of those instruments? What qualification requirements must those instruments meet?

RESPONSE #56 A. Boston Edison will maintain eleven on-site and off-site sampling stations which collect airborne particulate material (including particulate iodine) and gaseous iodine. These stations will operata continuously (natwithstanding equipment or power failure) and collect samples which are collected at approximately 7-day intervals. These samples subsequently will be analyzed for iodine radioactivity in a laboratory.

There are no " ranges" as such associated with these types of devices.

The devices will be comprised of standard commercial quality components and will be inspected and maintained ,

weekly.

B. None C. None D. Applicants' Direct Panel

. , INTERROGATORY #57 t

List the date, location, attendees, and agenda items for every meeting, whether formal or informa), which has occurred between any director, officer, employee, representative, agent or attorney of BECo and any other party regarding the licensee / applicant, state, or local emergency plans for Pilgrim I or II, whether past, current, or proposed.

RESPONSE #57 A, No such list of formal and informal meetings exists.

Neither does Boston Edison consider it feasible to attempt to compile one since numerous informal meetings lack documentation.

Boston Edison and its consultants have met frequently with members of MCDA, MDPW, MDPH and the Massachusetts State Police to discuss emergency planning topics. Likewise, Boston Edison and its consultants have met on numerous occasions with officials in each town within the plume exposure EPZ to discuss emergency plans. Meetings have been held with local selectmen, Civil Defense directors, l

and with police and fire departments.

To the extent not answered above, Boston Edison objects to l this interrogatory on the ground that it is unduly burdensome.

B. None l C. None D. Applicants' Direct Panel l

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- - INTERROGATORY #58 List the name, title, and qualifications of every officer, director, employee, agent, or representative of BECo or HMM Associates, Inc. who participated ir. preparing Amendment 40 or 41 to the Pilgrim II PSAR.

RESPONSE #58 A. The principal authors of Amendments 40 and 41 include the following personnel:

Mr. R. C. Cunningham, Boston Edison Mr. R. J. Merlino, HMM Mr. W. R Griffin, HMM Ms. M. Baldwin, HMM Mr. S. T. McCandless, HMM Resumes for these pecple are attachec.

B. Nona C. None D. Applicants' Direct Panel

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INTERROGATORY #59 1

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

RESPONSE #59 A. Boston Edison is aware of no officer, director, employee or representative of Boston Edison or HMM who dissents from any finding, conclusion, or statement contained in Amendment 40 or 41 to the Pilgrim 11 PSAR or to-any portion of the answers to the foregoing interrogatories.

B. None E. None D. Not applicable.

I

. , SIpNATURES The foregoing answers are true to the best of my knowledge, information, and belief, except insofar as they art based on information available to Boston Ed.ison Company but not within my personal knowledge, as to which I, based on such information, believe them to be .

L-bert H. Cunhin~gham Sworn to before me this day of July,1981.

As to objections:

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Thomas G. Dignah, Jr. k) * >>

R. K. Gad III Ropes and Gray 225 Franklin Street Boston, Massachusetts 02110 Telephone: 423-6100 i

llILW William S. Stowe Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199 Telephone: 424-25'54 i

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. . ATTACHMENT l

i The foJ1owing resumes are attached hereto and incolparated hereits in respanse to the indicated question (s):

Robert H. Cunningham, Boston Edison, Questions 1 and 58 Robert J. Merlino, HMM Associates, Questions 1 and 58 Scott T. McCandless, HMM Associates, Questions 1 and 58 Thomas Sowdon, Boston Edison, Q. action 1 William R. Griffin, HMM Associates, Question 58 Margaret T. Baldwin, HMM Associates, Question 58 l

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. ROBERT J. MERLINO Education B.S. Civil Engineering, Tufts University, 1963 Certificate in Reactor Engineering, Bettis Reactor Engineering School, 1965 M.B.A. Buriness Administration, Babson College, 1970 Summary of Experience Mr. Merlino has broad experience in environmental analysis, nuclear licensing and project management. He has served as project manager or principal investigator on licensing activities and environmental studies for nuclear and fossil power plants, pulp and paper mills and other industrial facilities. He has been activa in emergency planning for nuclear facilities for over ten years, and has been active in AIF and EEI emergency planning activities. He has appeared as an expert witness on emergency planning.

j Experience 1978 - H?iM Associates, principal and project manager.

Present He has led emergency planning activities on behalf of several nuclear utilities. This has included evacuation studies, plan writing for stations, state and local plans, and other activities.

Projects have included environmental analysis and permitting for a pulp and paper mill, preparation of a new source review application for oil-fired combustion turbines and performance of an air .

quality analysis for an industrial combustion source.

1977-1978 Environmental Research & Technology, Inc.

and (ERT). Mr. Merlino held a number of positions 1973-1976 at ERT as Project Manager, Manager of Air Quality Programs and Manager of Nuclear Services Division. He directed projects involving site selection, air Juality and meterological monitoring, radiological impact assessments and environmental baseline investigations. He represented clients at meetings with regulatory agencies and at public hearings.

Among the projects he directed were:

o Performance of environmental studies, preparation of environmental impact report and permitting for a pulp and paper mill expansion, o Evacuation analyses for two proposed nuclear power stations.

o A probabilistic analysis of loss of coolant accident doses.

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7 ROBERT J. MERLINO o Development of computer models for calcu-lating atmospheric dispersion.

O Installation and operation of meteorological and air quality monitoring networks and data acquisition systems around several fossil-fired and nuclear power stations.

1976-1977 Tera Corporation, Senior Project Manager.

Performed and managed engineering and environmental studies. This included the development of a sea breeze fumigation model for calculating ground level concentrat'ons from stack releases.

1968-1973 Yankee Atomic Electric Co. , Manager of Safety Analysis. Responsibilities included nuclear power plant site evaluations and participation in and direction of preparation of site-related portions of safety analysis and environmental reports for four nuclear power stations. Topics included land use, meteorology, population distribution, evaluation of potential hazards from nearby industrial and militsry facilities and radiological safety. Prepared testimony and participated extensively in public hearings as an expert witness before state and federal regulatory bodies.

1967-1968 Pioneer Service and Engineering Co., Nuclear Engineer. Performed safety and analyses for nuclear power stations and developed design requirements for engineered safety systems.

1963-1967 U.S. Navy, Division of Naval Reactors, Staff Engineer. While on active duty, directed government contractors in areas of nuclear propulsion plant mechanical systems design and testing.

Professional Affiliations / Registrations Registered Professional Engineer (Nuclear), State of California American Nuclear Society e 4/80

n SCOTT T. McCANDLESS Education B.S. Civil Engineering, Worcester Polytechnic Institute, 1971 M.U.A. Urban Af f airs, Boston University,1973 Adjunct Assistant Professor, Environmental Planning, W.P.I., 1975 Gummary of Experience Mr. McCandless has extensive experience in environmental planning and management. He has served as project manager or principaJ investigator for c wide variety of nuclear safety studies, environmental studies and training programs. He has been directly involved in studies for nuclear facilities, urban mixed use developments, transportation projects, and energy development prcjects.

Professional Experience 1978 - HMM Associates; principal and project manager.

Present Recent emergency planning projects have included development of state and local emergency plans, and evacuation study reports compiled for submission to NRC. Clients have included TVA, Arkansas Power &

Light, Florida Power & Light, Boston Edison and others. Other projects have included management of state EIRs and federal EISs for several urban developments in Boston, including the first to be performed under comprehensive new regulations, Massachusetts Environmental Policy Act and the largest urban commercial development ever proposed for New England. Mr. McCandless has also directed projects with emphasis on noise, air quality and transportation considerations.

1972-1978 Environmental Research & Technology, Inc. (ERT). In his most recent position he served as manager of the Environmenal Planning Division. In this position, he served as both a senior project manager and as administrative head of a multidisciplinary division of environmental professionals including specialists in acoustics, air quality, archaeology, economics, geology, landscape architecture, planning, socio-economics and transportation planning. During his tenure at ERT, Mr. McCandirs s was project manager for more than twenty different environmental studies.

Among them were the EIS for the SHERCO coal-fired power p1kat in Minnesota, the EI A for POD 3 of the

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SCOTT T. MCCANDLESS New Town at Battery Park City in Manhattan, an Environmental Assessment for the Columbja Green Springs SNG plant feedstock allocation, Air Quality Studies for several Washington METRO System EIS efforts, and an Environmental Reconnaissance for an ethylene plant site for the Mobil Chemical Company.

1971-1972 Needles, Tammen & Bergendof f, Staf f Planner.

Prepared the Route 2 EIS and the Land Use Plan for ,

the Manchester, NH Airport Master Plan.

1969-1971 Robinson & Fox, Staff Planner. Prepared tenant selection and Management Plans for proposed MHFA funded housing development in Worcester, MA.

Professi~onal Affiliations Member, American Society of Planning Officials l

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WILLIAM R. GRIFFIN, Esq.

Education J.D. Law, Suffolk University, 1978 M.S. Envircnmental Engineering, Northeastern University, 1974 -

B.S. Civil Engineering, Georgia Tech., 1970 Summary of Experience Mr. Griffin has specialized in energy and environmental regulation work since 1970. As an enginaer, manager, attorney, and scientist, ne has been involved in feasibility studies, emergency planning studies, alternative site studies, environmental impact studies, preparation of licensing documents, negotiations with state and federal regulatory agencies, preparation and presentation of expert testimony, preparation of emergency plans, and other activities associated with managing a major project through the regulatory orocess. The majority of his experience has involved energy projects, including electric power generation and transmission facilities, large industrial boilers and cogenerators, hydroelectric plants, resource recovery facilities, refineries, pipelines, offshore oil facilities, waste treatment and disposal facilities, and others. He is national chairraan of Federal Energy Bar Association Environment Committee and a member of the American Paper Institute Energy Law Committee. He has completed the Harvard School of Public Health course on Emergency Preparedness for Nuclear Facilities.

Frofessional Experience 1979 - HMM Associates. Projects have included participation Present in environmental licensing for a $250 million paper mill expansion in Alabama, providing legal support in federal hearings for the Pilgrim 2 nuclear project, directing emergency planning studies, directing environmental studies for nuclear power plant sites, involvement with hazardous waste regulations and air pollution law, work on natural gas supply and pricing regulation under PURPA, purchase and sale of electric power by PURPA cogenerators and small power producers, feasibility studies and licensing for small hydroelectric facilities, site selection and licensing for synfue.ls plants, devel.pment of contracts for protection of proplietary computer programs, and other projects.

1977-1979 Boston Edison Company. Federal Licensing Coordinator.

Responsible for obtaining all federal licenses for the proposed Pilgrim 2 nuclear project. Responsi-bilities included development of project licensing strategy, management of the preparation of licensing documents and expert testimony, appearing as an

expert witness in federal hearings, coordination with

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1 WILLIAF R. GRIFFIN, Esq.  !

in-house and hired counsel, acting as company spokesman in negotiations with federal agencies and project general contractor. Environmental and t safety related licensing involved the Atomic Energy Act, Administrative Procedures Act, Clean Air Act, Clean Water Act, and state public utilities statutes. Also acted es company public spokesman with media and intervenor groups on energy issues.

1975-1977 Anderson Nichols, Inc., Boston, MA Project Manager, Environmental Sciences Division. Responsibilities included negotiations with federal agencies, nanagement of the public meeting process, selection and management of subcontractors, msnagement of a staff of engineers, scientists, and planners.

1972-1975 United Engineers and Constructors, Boston. As Project Coordinator, responsibilities included management of licensing and planning projects such as alternative site studies for energy facilities.

As Project Licensing Engineer, responsibilities included managing the process for obtaining state permits for nuclear and fossil fueled electric power plants. As Environmental Scientist, responsibili-ties included evaluation of the environmental impact of construction and operation of large industrial energy facilities.

1970-1972 Commissioned Officer in U.S. Public Health Service assigned to U.S. Environmental Protection Agency, Winchester, MA. As Environmental Engineer, responsibilities included research and development of methods and devices for environmental surveillance at nuclear energy facilities.

Professional Affiliations Certifications:

Member of the Bar, Massachusetts, since 1978 Member of the Patent Bar, Registered to practice bef ore the U.S. Of fice of Patent and Trademark, R.M. #P-29,926 EIT, Georgia, since 1970 Legal Organizations:

Federal Energy Bar Association, National Chairman, Environment Committee American Bar Association Massachusetts Bar Association Boston Bar Association Phi Delta Phi

WILLIAM R. GRIFFIN, Esq.

Engineering and Scientific Organizations:

American Association for the Advancement of Scienca American Society of Civil Engineers Boston Society of Civil Engineers ~

American Nuclear Society Oceanic Society New England Antiquities Research Association -

Publications Editor: " Annual Report of the Environment Committee",

Federal Energy Bar Association, Energy Law Journal, 1980, 1981.

Author: "Allens Creek Nuclear Site EPZ Evacuation Time Estimate Study", Houstcn Lighting & Power Co., HMM Associates, 1980.

Author: Farley Nuclear Site EPZ Evacuation Time Estimate Study," Alabama Power Co.,

A HMM Associates, 1981.

Author: Book review of A Compilation of Qualification Considerations for Nuclear Generating Stations, 1978.

Author: " Mineral Resources Extraction from the Sea Floor: Legal, Political, Social and Technological Problems", 1977.

Author: " Environmental Regulation: An International Perspective", 1977.

Author: " Jacksonville Electric Authority Proposed Power Plant Sites: Review and Evaluation",

1975.

Editor: " Laws, Rules, Regulations and Procedures for Electric Power Plant and Transmission Siting in New York", 1973-74.

Author: " Conceptual Design of a Water Treatment System for a Bre,wery", 1973.

Author: " Observations of Airborne Tritium Waste Discharge from a Nuclear Fuel Reprocessing Plant", 1973.

Author: "A Sampler for Non-Aqueous Tritium", 1973.

Contributor: "A Study of Severe Vehicular Accidents", 1970.

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MARGARET T. BALDWIN Education B.A. Bxclogy, Middlebury College, 1978 ,

Summary of Experience Ms. Baldwin has a wide range of experience in environmental planning and impact assessment. She has been principal investigator for a number of Environment Impact Reports for urban mixed-use developments, noise impact studies, and transportation network analyses. She has extensive experience in emergency planning projects.

Professional Experience 1979 - HMM Associates. Ms. Baldwin has had major Present responsibility for several Environmental Impact Reports for urban mixed-use developments. Topics included noise, traffic, wind, and cultural resources. She has undertaken a number of noise impact analyses involving performing data collection, data analysis using computer modeling, and report preparation. She is experienced in assessing both construction and operational noise impacts. She is experienced in computer programming and permitting procedures.

Ms. Baldwin has been principal investigator for emergency planning studies for three nuclear power plants. She has had major responsibility for field data collection, conputer modeling, alysis, and report preparation for the=c projects. She i.s experienced in dealing with local emergency planning officials.

l 1978 Palmer & Dodge. Ms. Baldwin worked as a legal assistant on cases related to environ- mental issues. She was responsible for editing pre-trial testimony and examining technical laboratory data related to a litigation case.

Prior to Prior work involved extensive botanical and 1978 ecological studies including ecosystem identification, plant taxonomy and marine

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. l RESUME ROBERT H. CUNNINGHAM 17 ARTWILL STREET MILTON, MASSACHUSETTS 02186 696-7523 .

EXPERTISE:

Public Administration Attorney Industrial Labor Relations Program Managenent Budget and Program Analyst Industriel Security Disaster Preparedness Public Safety EMPLOYMENT HISTORY:

5/12/80 to Staff Assistant to the Vice President, Nuclear Present Boston Edison Company, Boston Massachusetts Serves as the advisor to the Vice President in regards to all emergency preparedness activities involved with the nuclear power facilities owned and operated by Boston Edison Company. Manages all radiological emergency response planning activity with the Federal State and local governments. Manages an intra-company task force on energency preparedness whose primary goal is to revise all energency plans and procedures for the Pilgrim Nuclear Power Station. As the Emergency Preparedness Coordinator, the applicant assists the Vice President in coordinating the utili-zation of all facilities equipment and personnel during the emergencies and recovery operations following a radiological emergency. Has responsibility for developing all emergency facilities and obtainir,g all of the specialized equipment necessary to implement the emergency plan. Iriterfaces with all managers within the Nuclear Department. Periodically assesses the emergency preparedness activities throughout the company, makes reconnend-ations for improvements and assists managers in improving energency preparedness capabilities. Serves as the primary spokesman con-cerning emergency planning in contacts with elected and appointed government officials, the news media, and citizen groups and appears before regulating bodies at all levels of government. Assures that adequate plans are in place that necessary facilities and equipment are operational and that all persons have been adequately trained to best minimize any threat to public health and safety should a radio-logical emergency occur at the Pilgrim Nuclear Power Station.

9/30/77 to Director of Massachusetts Civil Defense Agency and Office of Emer--

gency Preparedness Framingham, Massachusetts 5/11/80 s, Appointed by two G0vernors to serve as the Executive Head of the State Agency, the applicant was responsible for developing a com-

. 2 prehensive Emergency Preparedness Program for the Commonwealth of Ma ssachusetts. Served as the principal advisor to the Secretary of Public Safety and the Governor on all disaster preparedness and disaster recovery activities. Assured that all cities and towns throughout the state receive adequate guidance and : assistance in the development of local civil defense capabilities. Maintained liaison with all federal preparedness agencies and carried out a broad program of disaster preparedness on behalf of the Governor.

Was responsible for the administration and management of four area field offices; one training academy; three specialized federal coctracts; the solicitation, distribution and monitoring of fed-eral funds to local governments; th2 distribution and monitoring of excess federal property to state agencies, as well as the cities and towns; and assisted loca; governments in the development of personnel staffing patterns for Emergency Preparedness organizations.

Directed the fiscal affairs of the agency, including preparation of budgets preparation of federal grant requests and administers and managed the oversight of expenditures of all appropriations and federal funds received.

Served as the spokesman for all civil preparedness activities to the multi-news media, public elected and appointed officials, private sector organizations, and citizens groups. Solicited participation and vativated maximum efforts in emergency preparedness from indiv-iduals and groups. Supervised the activities of a staff of over sixty personnel . Evaluated the energency preparedness posture of all echelons of government in the state. Administered an extensive training program for all civil defense personnel and state and local officials.

Assessed and recommended to the Governor, through the Security of Public Safety, what actions should be taken by state agencies to best respond to imminent disaster. Directed the emergency operations of the agency during disasters, as well as served as principal advisor to the Secretary of Public Safety in the coordination of state re-sources to respond to disasters (e.g. " BLIZZARD OF 78", "Somerville Chemical Spill")

In addition to his duties as Civil Defense Director, Mr. Cunningham also served as a member of the Massachusetts Public Safety Council; the Executive Office of Public Safety; the Governor's Task Force on Dam Safety; the Governor's Task Force on Hazardous Materials; Governor's Special Task Force on Nuclear Power; the Governor's Representative on the Civil Defense Committee of the Coalition of Northeast Governors *;

the Governor's Represent-tive on the President's Federal Emergency Planning and Response Reorganization Project; the President's Com-mittee on Management Intern Selection; the Massachusetts Flood Relief Board; the Civil Defense Claims Board and the Massachusetts Advisory Council on Radiation Protection.

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12/15/68 U. S. Department of Defense Defense Civil Preparedness Agency to 9/30/77 Maynard, Massachusetts Progressed from a management trainee tc the Principal Advisor to the Regional Director in the development of annual budget request (16 to 20 million dollars). Also served ae, the Regional

. Representative in the development of the annual National Agency Budget. Advised the Regional Director of Field Services on employee-management relations problems and union contract neg-otiations. Perfomed the duties of a Program Analyst in the role as Advisor to Regional Director concerning development of a new budgeting and programming system, while coordinating all Regional programs within seven separate divisions.

Was primarily responsible for all DCPA programs in New Hampshire.

Performed analysis and made recomendations to improve the effect-iveness of the emergency capability of State and local governments to be used in comaatting disasters. Provided program management guidance, assistance and recomendations to State and local govern-ments concerning the development and integration of inter-governmental support systems required for the impiementation of Comunity 5helter Plans and other emergency plans necessary for emergency di3 aster opera tions . Reviewed and approved or disapproved requests from States and local goverments for Federal financial assistance, Per-sonnel Staffing and qualifications, as well as requests for Excess and Surplus Property.

Co-developed and produced the pilot training program for presenting prep"edness infonnation over the nation's first Regional govern-ment micro-wave tr.levision system.

Monitored the utilization of Federal funding and equipment to assure adherence to Office of Management and Budget criteria, objectives, principles and programs. Assisted in planning, conducting and eval-uating tests and exercises of local civil preparedness activities and Management Development training through the University of New Hamps hi re.

Served as guest lecturer at University of New Hampshire.

I Managed the activities of ten different Federal agency field offices with over fif ty personnel during the Executive Office of the Pres-l ident's response to Tropical Stonn Agnes.

12/15/67 to 12/13/69 Military Duty l

Coordinated administrative operating procedures of finance branch.

l Supervised work of 50 enlisted per. cannel, as well as aiding in quality l control program used in evaluating the finance procedures involved in processing military pay records of 30,000 trainees. Developed security procedures to safeguard payrolls amounting tn over a million dollars. Detennin'e d education and trainir.g requifements for 100

• military and civilian personnel. Assisted in determinatica and i disbursement of travel allowances, family allotments and financial aid to dependents of needy military personnel. ,

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< 4 7/10/67 to U. S. Departcent of Defense Defense Civil Preparedness Agency 12/15/67 Maynard, Massachusetts Management Trainee - Studied, prepared and r2 Viewed reports, plans and procedural material . Reviewed and revised orga ni-zational concepts and initialed draf t cf proposed agei.cy stand-ards. Aided in coordination of financial assistance to State agencies in order to implement national etvil defense programs, plans and operations. Acted as a liaison with many Federal, State and local government agencies, informing them of our National policies and thei- obligations to stimulate concern and part-icipation.

3 EDUCATION:

Boston College - AB 1967 Economics Cornell University - Graduate Residence - Completed 9/73 to 6/74 in the Graduate School of Public Administration and Industrial Labor Relations under Education for Public Management Fellowship.

New England School of Law - JD 1975 Dean's List Student US Army - NCO Leadership Academy 1969 US Civil Service - Middle Management Institute 1970

, Oak Ridge Associated Universities - Nuclear Power and the Energy Crisis AWARDS:

Education for Public Management Fellowship - 1973 US Civil Service Commission Dean's List, New England School of Law Certificate of Appreciation, Metropolitan Regional Council Certificate of Appreciation, US Defense Civil Preparedness Agency (DCPA)

Certificate of Appreciation, American Red Cross Letter of Commendation, Deputy National Director, US Office of Civil Defense (OCD)

Letter of Comnendation, Assistant National Director, DCPA Certificate of Conmendation, National Director, US Office of Bnergency Pre-paredness Three Letters of Comnendation, Regional Director, DCPA Good Citizenship Award, Knights of Pythias 1978 . .

o Nominated for Fellowship on Congressional Operations for Executives by Regional Director, DCRA,1972

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PT,er!'E g Tl'O"AS L. SOFDO!!

PERSONAL DATA Address: 130 Court noad, Winthrop,1' ass. 0.'352 Telephone: 617- E M- 3 ' 0 9 (Hero) ; 017 6 7 3- 0. 5 f: (l'or}-)

Lirthplace and Date: Lyrn, l' ass ; February 22, 1950 l'arital Status : l'arric( , Three chi 3(ren i

Height: 5'-10" Weight: 355f EDUCATION B.S., Nuclear Enrirecrino, Lcuell Techrelccien1 Innrite-e-(June 1972)

Graduate of the Stone an0 hi;cter Encint-or-in-Trairinc Progran (July 1973)

UOUORS and AWARDS

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Tau Epsilon Sinta Honor Society Registered Enginecr-in-Treining, Stato of f assachusetts Certificate (2814 ,

E>PERILUCE

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l'ay 1972 - STONE AMD U1:P.STTR EUCI"TTPII'C COPT.

Prescnt Scaron, l' ass achusetts Current Position: Ecdiation protectier Encire er Responsibilitics : Responsibilities inclurc -

the following:

1. Radiation Shic16ina Desicn Inclu6 inn the deterrir.aticr of rariation source strengths ,the estol lishi nnr of radiarier zonen thrcucheur. -he plert, speci ficenion of chc. thic! rers cri roterial for porrentnt a r t' terpercry nhie3/ino,er-posure estir.ates arc accens tir c. 031cvances for nair tenenen tas):s.

2. Radiction Ionitorinc Syster: Specjfiertier Including prcrarctic , of r.he speci fication for the purchase of 1orn a corvertieno3 analog syster. ar.C an advarce-/ cerputer based systen r,o provide rore efficient dece acouisition, Icocinc, analysis, crF rerort ocncratien. .

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O-~ g e .- 3. Licuid and rencous l'at' ioactivi ty Pc3 cases

, Includir.r the ca3culatien of the rcicane rates arr! resultinc activity ccncer.tratiens

. within uhe plant and in the envircrrent, cval-untion of the rccuirorcers fcr effluent treat-rrent syster.s ard establishrert of the tech-nical specificatiers fer the relcase of radioactivity.

4. Analysis of Envirenrcrtal Irrect of Plant Operatien Includino estiretien cf carra, beta ned -

thyroir* Co',cs due to ncrral crcretier, establishrent of site bour(ary distances and critical c::pesure pathways , c's ti rrtes of population exposure due to direct a rc' scattered ra61stien frer the plcnt ord frcr' the transrcrertier cf reficnctive ratericls.

5. Rafiolonical Consecuerces n' res tu 1.. e -0 Accidents Inclucirn the cc^plete nrolysis c the rei.icaccidtv teJ cene nni resulrir- dcscs due to the cecit'erts virrcssce ir "c Sa fets Analysis Repert, (cterr ir anier cf c e r rrrent~

classificaric.n acccr(ir e te Rern3eters. Cuides 1.2C ar6 1.29 , Cencrr ir.ati cr. of certd rer ent rccuircrents.

D:rericnco alse. irc3nacn crrersivc cri vu -or ucrh involvina devele,pecnt of a precrar to (Teterr'ine the concentrntic),s of all sicrificent isotrres in varicus creas of a Prensurire<i Unter Rcccter plant.

Present assionrcrt invc1 von radictier protectice responsibility fcr a .V 3r recarn.tt therrel

( 850 0*IT ) Doilinc Uatt'r Reacter p?nnt.

As cf Janua)',' 3,3977 I havc 1:<cr assicrcei as the project eg.cincer fer thc acvo3rrrert cf a corrutcrizc6 on-li).c (csc cascsarc nysrcr to 1:c offorcC to crccativo nuc.'.cor Trever n ter.icns .

The syster.' is cr.rab3c cf perfc.rrire r.hc fo] 3 cuinc

. functions:

1. Autor.tatic on'-3 f ec caler3 nt-ic.n of of f-site c' eses thrc.uch a31 pathwaus speci cic( j r. Rec-ulatory ruiDe 1.] ?n boser? cr ir Tcrr'cticr:

availabic frcr the presortly irstol3 c/

analog radiatien ronitors ard ratecrc3ccical instrur ents .

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2. Autcratic veri ficatier. 'of ccrp1.i ar ce uith the plant Techr ien3 Specificetiers irc:u/ ire the 1 new provesc/ crit clir ch chi ch lir i r orcr-i

, ation based on (cscs rather ther relcasas.

3. Autenatic cenerecien cf all reports recuired by the UEC in the areas of retecrclecy enf redienctive eff 3 narts er 0 /r ses.

4. Estirates cf offsite (cse ir the evert of a sitJnificant re.iccsr resultire frcr or abrorral occurrorce to aid in deterrinine what protective acticn, if ar.y , shou 2 n he tal en.

5. Previc?cs a ccrputerired fcci3ity fer rccer6-ing and reporting occuparicre] 6csc es recnired 1:y neculaterv Guide 1.1r .

Sept. 1908 - T7 TITOOE LN II: ACTS "cy 1972 Lovell, Massachusetts Tcsition: Frecess Encit eer Res por.sibilities : In charce c.f specirl projects includire experirepta3 preccsnr:s irvolvino critical-applications of hinh pressurc rc3rrire an( pherolic plastic lariratcs. Provi(e<' rcccrrcericticrs te Vicc-Presi6cr.t. Servce' as rcrnere] nssister.t to inchnical Director. Resrcnsibilit*f fcT FPirter.anCe of electrcnic cenirrent.

REFEREUCES WII.I. BU FI'PJ1IFUTD UPOP PTCPTF". '

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l UNITED STATES OF AMERIC?

NUCLEAR REGULATORY COMMISSION

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In the Matter of )

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BOSTON EDISON COMPANY, et ale ) Docket No. 50-471

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(Pilgrim Nuclear Generating )

Station, Unit 2) )

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CERT!FICATE OF SERVICE I

I hereby certify that the Respcases of Boston Edison Company, et al . , to Commonwealth of Massachusetts' First Set of Interrogatories to Boston Edison Company Relative to Emergency Planning filed in the above-captioned natter has been served on the following by deposit of a copy snereof in the United States mail, first class, postage prepaid:

Andrew C. Goodttope, Esquire Stephen M. Leonard, Esquire Chairman Jo Ann Shotwell, Esquire Atomic Safety and Licensing Board Environmental Protection Division 3320 Estelle Terrace Department of the Attorney General Wheaton, Maryland 20506 One Ashburton Place, 19th Floor Boston, MA 02108 Dr. A. Dixon Callihan Union Carbide Corporation Francis S. Wright, Esquire P. O. Box Y Berman & Berman Oak !(idge, Tennessee 211 Congress Street Boston, MA 02110 Dr. Richard F. Cole Atomic Safety and Licensing Board Henry Herrmann, Esquire U,9 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. Clecton U.S. Nuclear Regulatory Commission 22 Mackintosh Street Franklin, MA 02038 Washington, D.C.

Atomic Safety and Licensing William G. Abbott, Esquire i

Appeal Panel Suite 925 U.S. Nuclear Regulatory Commission 50 Congress Street >

Washington, D.C. 20555 Boston, MA 02109 3 i

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g Stephan H. Lewis,Jcck Esquire re R. Goldborg, Esqui Office of the Executive Director U.S. egal L Patrick J. Kenny, Esquire Edwar L. Selgrade, Esquire Mass.dOffice Washington, D.C. Nuclear Regulatory Com i 73 Tremont Streetof Energy Resources 20555 m ssion Boston, MA Chief Librarian 02110 North StreetPlymouth Public Library Office Plymouth, MA Docketing and Service Sof the Se 02360 U.S. Haclear Regulato ection Thoma s S. Moore, Washington, D.C. 20555ry Commis0 ion Atomic AppealSafety Board and Licen s ngiChairman U.S. Dr. John H. Buck Washington, D.C. Nuclearm Regulatory ssion Atomic Com Appeal i Safety Board and Licensing 20555 U.S.

Christine N. Washington, D.C. Nuclearm Regulatory C Atomic ssion U.S.

Appeal Safety Board and LicensiKohl, ng Esquire 20555 Washington, D.C. Nuclear Regulatory ssion Commi 20555 Dated:

W' July 20, 1981 1

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