ML20010A886

Second Set of Interrogatories Directed to Util Re Emergency Planning.Certificate of Svc Encl.Related Correspondence

ML20010A886
Person / Time
Site:	05000471
Issue date:	08/04/1981
From:	MASSACHUSETTS, COMMONWEALTH OF
To:	BOSTON EDISON CO.
References
NUDOCS 8108130068
Download: ML20010A886 (8)

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BEFORE THE ATOMIC SAFETY O g AND LICENSING BOARD In the Matter of: )

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

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COMMONWEALTH OF MASSACHUSETTS ' Z AUG 121981

• T SECOND SET OF , .;;

INTERROGATORIES TO V 8'" M BOSTON EDISON COMPANY 'I' RELATIVE TO EMERGENCY PLANNING q, ru '

Pursuant to 10 C.F.R. SS2.740b and 2.741, the Intervenor Commonwealth of Massachusetts requests that the following Interrogatories be answered fully, in writing, and under oath by an officer or agent of Boston Edison Company (hereinaf ter, 7:.> E C o . " )

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

I A. Provide the direct answer to the question.

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! B. Identify each document, and the particular

! parts thereof, which in any way serves as a j basis for the answer.

C. Identify all documents known to BE Co. which pertain to the subject matter questioned but which do not serve as bases for the Staff's i

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answer, including documents which provide or support an answer different from that provided by BE Co.

D. Identify the expert (s), if any, whom BE Co.

intends to have testify on the subject matter questioned and state their qualifications.

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

refers to the original and copy (but not both if identical in every respect) of any printed, written, recorded, transcribed, punched, taped, filmed, photographed or graphic matter, whether sent or received or neither, whether a draft or otherwise, however produced or reproduced, and both sides thereof, including but not limited to, any memorandum, correspondence, letter, affidavit, court paper, transcript, diary, report, study, telegram, table, telex message, record, chart, paper, work paper, graph, index, book, notebook, pamphlet, periodical, tape, data sheet, data processing card, note, notation, minute desk calendar, appointment book, sound recording, computer print-out or microfilm.

INTERROGATORIES

1. Please clarify the following aspects of BE Co's answer to Interrogatory No. 8 of the Commonwealth's First Set of Interrogatories to Boston Edison Company Relative to Emergency Planning:

a. BE Co. states, in the third paragraph of its answer, that ". . . spaces are availasle in public buildings and offices which could accommodate peak l

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seasonal populations . . . . -Does this reference to " peak seasonal populations" include the peak transient populations?

b. BE Co. refers in the last sentence of the third paragraph, and again in the last paragraph, to

" category 2" level of protection. Please explain 1 these references, citing any NRC or other federal guidance from which this system of categorization is derived.

c. Please' explain the meaning of the following phrase contained in the footnote on page 18 of BE Co. 's Answers 'to the Commonwealth's First Set of Interrogatories- "this figure'. . . assumes a 100%

existing rat,io for the Plymouth total of both existing and upgradable spaces."

l 2. The Staff has indicated, in response to Interrogatory No. 34 of the Commonwealth's First Set of Interrogatories to the NRC Staff Relative to. Emergency Planning, that it has asked BE Co. to provide evacuation time estimates assuming the weather condition of rain. Does BE Co.

intend to comply with this request? If so, by what date?

Describe the exact nature of the weather condition to be assumed. Specifically, will the assumption involve a rainfall

mid-day on a summer weekend after beaches are full? I f BE Co .

has already performed an analysis of evacuation times at Pilgrim assuming the condition of rain, explain in detail the results of that analysis.

3. BE Co. states, in its answer to Interrogatory No. 56 of the Commonwealth's First Set of Interrogatories to Boston Edison Company Relative to Emergency Planning, that "there are no ' ranges' as such associated with these types of devices."

This answer seems inconsistent with the reference in SER e Supplement No. - 6, at p. 39, to a "high-range radiation monitor." Please explain this apparent inconsistency and describe in detail any ranges which you determine are in f act associated with these devices.

4. BE Co. ref ers, at p.1C-8 of Amendment 43 to the Pilgrim PSAR, to "the current Emergency Preparedness evacuation model." Loes this ref er to the model used by HMM Associates, Inc. in its calculation of evacuation time estimates as If not, described in Amendments 40 and 41 of the PSAR?

describe the referenced model in detail.

5. BE Co. states, in its answer to Interrogatory No. 31 of the Commonwealth's First Set of Interrogatories to Boston Edison Co. Relative to Emergency Planning, that "[t]he frequency of hurricanes, earthquakes and tornados put them beyond the bounds of any reasonable ' adverse case' What, in the opinion of BE Co., is the frequency definition."

of each of these events at the Pilgrim site?

6. BE Co. explains, in its answer to Interrogatory No. 41 of the Commonwealth's First Set of Interrogatories to Boston Edison Co. Relative to Emergency Planning, that the projected doses and dose rates contained in Section 13.3.5.3 of the<PSAR are to be used to classify an accident into the General Emergency, Site Emergency, or Alert categories. Are these projected doses and dose rates identical to those included in NUREG-0654 as Example Initiating Conditions for each emergency class? If not, explain in detail the nature of and reasons for any deviation. With respect to any projected dose or dese rate which is not identical to that included in the applicable lis't of Example Initiating Conditions in NUREG-0654, indicate whether that projected dose or dose rate is consistent in all respects with each of the conditions included in that list and explain the nature of and reasons for any inconsistency.

NOTE: Instructions B-D above do not apply- to the following Interrogatories Nos. 7 and 8.

7. Please provide, for each individual whom BE Co.

1 intends to call as a witness on emergency planning matters, a list cf all proceedings of any kind before any ' tribunal in which 'said individual has testified and the subject matter of his testimony on each such occasion.

8. Please provide, for each individual whom BE Co.

intends to call as a witness on emergency planning matters, a list of all reports, studies, papers, articles, and books, i

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t whether published or not, and whether a draft or not, relating in any way to the subject of emergency planning and prepared, i in part or in whole, by said individual or-by a corporation,

partnership, or other organization of which said individual is an employee, officer, director, partner, or agent.

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

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In the Matter of )

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

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(Pilgrim Nuclear Generating )

Station, Unit 2) )

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CERTIFICATE OF SERVICE I hereby certify that the within Interrogatories-have been served on the.following by deposit of copies thereof in the United States Mail, first class mail, postage prepaid this 4th day of August, 1981:

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

Chairman Room 1045 Atomic Safety and 50 Congress Street Licensing Board Boston, Massachusetts 02109 3320 Estelle Terrace Wheaton, Maryland.20906 Mr. & Mrs. Alan R. Cleeton 22 Mackintosh Street Dr. A. Dixon Callihan Franklin, Massachusetts 02038 Union Carbide Corporation P.O. Box Y William S. Abbot, Esq.

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

U.S. Nuclear Regulatory Ropes & Gray i' Commission 225 Franklin Street Washington, D.C. 20555 Boston, Massachusetts 02110 i Patrick J. Kenny, Esq. Atomic Safety and Licensing Edward L. Selgrade, Esq. Appeal Board Deputy Director U.S. Nuclear Regulatory i Mass. Office of Energy Commission Resources Washington, D.C. 20555 73 Tremont Street Boston, Massachusetts 02108 l

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

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

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

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