ML20010B307

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

ML20010B307
Person / Time
Site:	05000471
Issue date:	08/05/1981
From:	MASSACHUSETTS, COMMONWEALTH OF
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8108140343
Download: ML20010B307 (8)

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UNITED STATES OF AMERICA } CZ g ettu R mt:7 -12 NUCLEAR REGULATORY COMMISSION \ hg

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BEFORE THE ATOMIC SAFETY cy ec 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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SECOND SET OF ')h,)* C INTERROGATORIES TO .

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RELATIVE TO EMERGENCY PLANNING \/h Y

Pursuant to 10 C.F.R. SS2.720 (h) (2) (ii) , the Intervenor Commonwealth of Massachusetts requests that the attached Interrogatories be answered fully, in writing, and under oath by NRC personnel [ hereinafter, " Staff"] with knowledge of the facts and designated by the Executive Director for Operations.

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

A. Provide the direct answer to the question.

B. Identify each document, and the particular parts thereof, which in any way serves as a basis for the answer.

C. Identify all documents known to the Staff which pertain to the subject matter questioned but which do not serve as bases for the Staff's answer, including documents which provide or support an answer different from that provided by the Staff.

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D. Set forth the name, affiliation and title of each individual who participated in any way in the preparation of the Staff's answer, whether-or not said individual is an official or employee of the NRC.

E. Set forth the name and title of any Staff member who did not participate in the preparation of the Staff's answer and who has, or may have, more direct personal knowledge of the subject matter of the question than the individual (s) identified in Section D.

F. Identify the person (s), if any, whom the Staff intends to have testify on the subject matter.

questioned and state their qualifications.

For purposes of these instructions, the term " document (U)"

refers to the original and copy (but not both if identical in every respec+,3 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 memcrandum, correspondence, letter, affidavit, court paper, transcript, diary, report, j

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. The Staff states, in its answer to Interrogatory No. 6 of the Commonwealth's First Set of Interrogatories to the Nuclear Regulatory Commission Staff Relative to Emergency l

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Planning [ hereinafter, "the First Set of Interrogatories"),

that "NUREG-0396 . . . is based on the analysis in WASH-1400 and provides the basis for off-site emergency preparedness."

Explain in detail the Staff's understanding as to the manner in which the uncertainties in.the WASH-1400 estimates of accident probabilities and consequences are taken into account in NUREG-0396. In the opinion of the Staff, is this reliance by NUREG-0396 on WASH-1400 justifiable, despite the uncertainties If so, why? Explain associated with the WASH-1400 estimates?

the-bases for your answers in detail.

2. In the opinion of the Staff, do the WASH-1400 estimates of accident probabilities and consequences accurately represent the probabilities and consequences to be expected for l Pilgrim II? Explain your answer in detail, disclosing any fact of which you are aware which would, in your opinion, increase or decrease the WASH-1400 probabilities, or mitigate or aggravate the WASH-1400 consequences, in the case of Pilgrim II.

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3. What is the Staff's understanding as to the time of year of release which was assumed in the WASH-1400 calculations of prcmpt and latent health effects? Have any studies been f

performed by or on behalf of the Commission or Staff with respect to the sensitivity of thn WASH-1400 conclusione regarding prompt and latent health effects to the time of year of release? If ro, identify those studies snd describe the results in detail. If not, does the Staff have an opini.on as l

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to the degree of sensitivity of the WASH-1400 conclusions to this factor? Explain the bases for your opinion in detail.

4. Please provide, asLsoon as this information is available, a detailed description of all findings and conclusions of the Staff's implementation review of BE Co.'s emergency plans for Pilgrim Unit I.

5. The Staff states, in response to Interrogatory Nos.

65, 66, and 67 of the First Set of Interrogatories, that

"[t]here are no NRC requirements or guidacce on emergency preparc2..ess measures for dealing with liquid releases during a core-melt accident other than monitoring of the plant environs." Does the Staff wish to be understood as indicating by this statement that, in its opinion, the combined off-site f plans of BE Co. and the local and state authorities now j

adequately address the effects of releases to the liquid

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pathway resulting from core-melt accidents? If not, what is the Staff's opinion as to this matter? Explain your answers in detail.

6. The Staff indicates, in its response to l

Interrogatory No. 41 of the First Set of Interrogatories, that it agrees with the statement in SAND 78-0454 that early health effects are not strongly influenced by the speed and efficiency l

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with which protective measures are implemented outside of ten miles. In the opinion of the Staff, is the same true with respect to delayed health effects? Explain your answer in detail.

NOTE: Instructions B - F above do not apply to the following Interrogatories Nos. 7 through 9.

7. Please provide, for Aach individual whom the Staff.

intends to call as a witness on emergency planning matters, a list of all proceedings of any kind before any tribunal in which said individual has testified (whether in person or by way of written testimony) and the subject matter of his/her testimony on each such occasion.

8. Please provide, for each individual whom the Staff intends to call as a witness on emergency planning matters, a list of all reports, studies, papers, articles, and books, whether published or not, and whether a draft or not, relating in any way to the subject of emergency planning and prepared, in part or in whole, by said individual or by a corporation, partnership, or other organization (other than the NRC) of which said individual is or at any time was an employee, officer, director, partner, or agent.

9. The Commonwealth has recently obtained a copy of FEMA's " Dynamic Evacuation Analyses: Independent Assessments of_ Evacuation Times from the Plume Exposure Pathway Emergency Planning Zones of Twelve Nuclear Power Stations," FEMA-REP-3 (February, 1981). That document indicates, at p. 8, that the Pilgrim site is one of 25 sites in the country which the NRC has identified as representing the most difficult sites for evacuating the surrounding populations in the event of an f __ - _ - - - - - - -- - - -

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accident. Please explain, in detail, the reasons why Pilgrim was included in this list, including a description of any special , factors which were viewed as contributing to the difficulty of evacuation there. Acccrding to FEMA-REP-3, Pilgrim is third on the second list of problem sites. Does this repre,sent a judgment by the NRC or the Staff that Pilgrim is the third most potentially problemsome site on that second list? If not, has any such judgment been made as to the relative potential difficulties associated with these sites?

If so, where does Pilgrim stand vis-a-vis the other sites?

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

)

In the Matter of )

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

)

(Pilgrim Nuclear Generating )

Station, Unit 2) )

)

)

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 5th day of August, 1981:

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

Chairman Room 1045 Atomic Safety and 50 Congress Street Licensing Board Boston, Massuchusetts 02109 3320 Estelle Terrace Wheaton, Maryland 20906 Mr. & Mrs. Alan R. Cleeton 22 Mackintosh Street l Franklin, Massachusetts 02038 Dr. A. Dixon Callihan 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 Li' censing Board Thomas G. Dignan, Jr., Esq.

U.S. Nuclear Fegulatory Ropes & Gray Commission 225 Franklin Street.

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

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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 Ec3ulatory 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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.o Ann Shotweli

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

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