ML20010D172
| ML20010D172 | |
| Person / Time | |
|---|---|
| Site: | 05000471 |
| Issue date: | 08/14/1981 |
| From: | Cunningham R, Dignan T, Dugnan T, Gad R, Stowe W BALTIMORE GAS & ELECTRIC CO., BOSTON EDISON CO., ROPES & GRAY |
| To: | MASSACHUSETTS, COMMONWEALTH OF |
| References | |
| NUDOCS 8108240075 | |
| Download: ML20010D172 (18) | |
Text
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- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
[@ (~ >,. s BEFORE THE ATOMIC SAFETY / -
\ -l~j; AND LICENSING BOARD l g g g 1981 9
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In the matter of )
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i BOSTON EDISON COM PAN Y , et al. ) Docket No. 50-471
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(Pilgrim Nuclear Generating ) Q ,
Station, Unit 2) f g@ Z
/ y RESPONSE OF BOSTON EDISON COMPANY, et al.
l l TO COMMONWEALTH OF MASSACHUSETTS' SECOND SET OF INTERROGATORIES TO BOSTON EDISON COMPANY RELATIVE TO EMERGENCY PLANNING
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(INCLUDING MOTION FOR PROTECTIVE ORDER) l $03 5
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DATED: August 14, 1981 i
0108240075 810814 PDR ADOCK 05000471 PDR
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- lNTERROG A TOR Y #1
- 1. Please clarify the following aspects of BECo's answer to Interrogatory No. 8 of the Commonwealth's First Set of Interrogatories to Boston Edison Company Relative to Emergency Planning:
- a. BECo states, in the third paragraph of its answer, that
. . . spaces are available in public buildings and of fices which could accommodate peak seasonal populations
" Does this reference to " peak seasonal populations" include the peak transient populations? ,
- b. BECo refers in the last sentence of the third paragraph, and again in the last paragraph, to " category 2" level of protection. Please explain 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 l I
contained in the footnote on page 18 of BECO's Answers te the Commonwealth's First Set of Interrogatories- " this figure . . .
assumes a 100% existing ratio for the Plymouth total of both e'xisting and upgradable spaces."
l
- RESPONSE #1 A. a. Yes.
- b. " Category 2" is a designation currently in. use by the Federal Emergency Management Agency to define the degree of radiation protection afforded by a structure. A protection fa c t or (i .e. , dose reduction factor) o f 40 corresponds to
' Category 2".
4
\ '
co A specific estimate of the number of
" Category 2" shelter spaces in Plymouth was not available.
Based on information provided by the Massachusetts Civil Defense Agency, 10% of the total available shelter spaces in Plymouth were estimated to be at the Category 2 level.
B. " Protective Construction," FEMA TR-39, December 1979. 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 Direct documents referenced therein) relied upon by Applicants' Panel at the time these 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 l
recollection of the Applicants' Direct Panel at the time these
!' answers are drafted, and does not include documents published I and availble in the general literature.
I D. Boston Edison presently proposes to call the f
following persons to testify on emergency plannin,g matters: l l
Robert H. Cunningham, Boston Edison Thomas Sowdon, Boston Edison !
Scott T. McCandless, HMM fssociates l
Robert J. Merlino, HMM Ase miates l l
The qualifications of these persons were attached to Boston Edison Company's responses to Commonwealth of Massachusetts' First Set of Interrogatories to Boston Edison Company Relative to Emergency Planning, Dated July 20, 1981. Hereinafter l ;
re ferred to as " Applicants' Direc t Panel".
! ~~ -- - - _ , _ , _ _ _ , ,, _
e INTERROGATORY #2
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4 T he Staf f 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 i
BECo to provide evacuation time estimates assuming the weather i
condition of rain. Does BECo intend to contply with this I 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 af ter f beaches are full? If BECo has already performed an analysis of i evacuation times at Pilgrim assuming the condition of rain, explain in detail the results of that analysis.
RESPONSE #2 A. The Staff has requested that Boston Edison Company l
lg provide evacuation time estimates for the f!rst year of plant operation, including our estimate of evacuation times for the l
high summer tourist population during rain. Boston Edison Company has agreed to provide this information by August 24.
This information is inclu~ded in a letter from .NRC to Boston l
Edison Company dated July 24, 1981. The NRC's distribution list indicates that a copy of this letter has been sent to the Commonwealth of Massachusetts, The analysis is presently underway and the assumptions to j
I be used have not yet been defined. A report will be written
' which documents the data, assumptions and results. A copy will i
be provided to the Commonwealth of Massachusetts at the time of 1
l its transmittal to the NRC.
B. None.
l I
C. None.
D. Applicants' Direct Panel, i
_3-
' INTERROGATORY #3 BECo 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 ritn these types of devices." Tnis f
answer seems inconsistent with the reference in SER Supplement l 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 fact associated with these
. devices.
I RESPONSE #3 A. Interrogatory #56 requested information on instruments to " measure continuous iodine and other halogens. "
' SER Supplement 6 at p. 39 refers to the " containment high range radiation monitor which meets the specifications of Table This monitor will be a " gross" I I . F .1- 3 oi NUREG 0737".
monitor, that is, it will not be designed to distinguish l
between noble gases, halogens and other gamma or gamma and beta emitting nuclides and, therefore, cannot properly be classified as an instrument to conti.nuously measure lodine and other halogens.
In addition, inplant sampling of halogens in airborne effluent paths will be conducted by collecting a representative
' sample of the halogens on a charcoal (or other medium) cartridge followed by on-site laboratory analysis.
There are no " ranges" associated with these halogen sampling devicer.
- 8. None.
C. None.
- D. Applicants' Direct Panel.
INTERROCATORV #4 BECo refers, at p. IC-8 of Amendment 43 to the Pilgrim PSAR, to "the current Emergency Preparedness evacuation model." Does this refer 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 PS AR7 describe the referenced model in detail.
RESPONSE #4 A. Yes.
B. None.
C. None.
D. Applicants' Direct Panel.
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'fMTERROGATORV #5 BECO states, in its answer to Interrogatory No. 31 o f the Commonwealth's First Set of Interrogatories to Boston Edision l
l Co. Relative to Emergency Planning, that "[t]he frequency o f 4
hurricanes, earthquakes and tornados put them beyond the bounds i of any reasonable 'a dverse case ' definition." What, in the opinion of BECo, is the frequency of each of these events at
)
the Pilgrim site?
RESPONSE #5_
4 A. The PSAR (see Section 2.5) deals extensively with the subject of seisimic activity as related to Pilgrim Unit 2.
- A conclusion at page 2.5-59 states:
"C onclus i on.
! The seismic history of New England indicates that there are restricted areas of significant earthquake activity .
throughout the historical and instrumental record. These 7
areas are the Ossipe'e, New Hampshire and the Cape Ann, Massachusetts region. The rest of New England is i
characterized by very in' frequent, low intensity earthquakes. A region defined by Vermont, portions of southern Quebec, and western and central Massachusetts, is
'- nearly a seismic. The record for New England is the most complete for the United States, and because of the low l
I attenuation characteristics for the earthquakes, it is low intensity reasonably complete even for low magnitude, events." ,
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! From page 2.5-60a:
"The site region is within the area of the longest continuous record of settlement and population for the northeastern United States. During this 350-year period no earthquakes of design significance have been located in I
the site area."
PSAR Section 2.3 contains data on hurricanes and tornadoes.
From page 2.3-4:
2 "For the period of record 1886-1970, coastal Massachusetts has experienced 18 tropical cyclones (sustained wind speeds greater than or equal to 40 mph). Of these, 6 are classified as hurricanes (sustained wind speed greater than 74 mph) and one as a great hurricane (sustained wind i speed exceeding 125 mph). A tropical cyclone could be expected then along the Massachusetts coast about once every 4 years, a hurricane once every 14 years, and a great hurricane once every 85 years."
i From pa ge 2. 3-5:
1
" Severe tornado activity in eastern Massachusetts is not common. Records from the National Severe Storm Forecast Center for the period 1951-1971 show a total of 85 tornadoes occurring in the entire State of Massachusetts, but only five occurring in Plymouth County in which the Pilgrim site is located. In a 1 0 square containing the site (42-43N,70-71W), Thom shows a total of 7 tornadoes having occurred in the period 1953-1962. Applying Thom's analyses, the probabilty of a tornado striking .any given point in a given year in this 10 square is approximately
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0.'00055. This implies a recurrence interval for a tornado at the Rocky Point site equal to the reciprocal of this
probability , or a bout 1800 years. The tornadoes that did occur in the Plymouth area did not inflict major damage.
The proximity to the ocean, and the terrain in the vicinity of the site, are unfavorable to severe tornado activity."
- 8. Pilgrim Unit 2 PSAR, Sections 2.3 and 2.5.
C. None.
D. Applicants' Direct Panel.
- ~
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INTERROGATORY #6 BECo explains, in its answer to Interrogatory No. 41 o f 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 Generr' Emergency, Site Emer,ency, 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 dose rate which is not identical to that included in the applicable list 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.
RESPONSE #6 A. The Protective Action Guides presented in Section 13.3.5.3 of the PSAR are consistent with the guidance of NUREG 0654 published in January 1980 for interim use and comment, to the extent that the Example Initiating Conditions of that document provided guidance on the subject of offsite dose rates.
The information presented in Section 13.3.5.3 also includes projected of fsite dose levels that are not specifically listed in NUREG 0654, but were included in response to Section II.J.7 of that document.
The projected doses and dose rates presented in Section
- 13. 3. 5.3, a nd in f a ct in NUREG 0654, are not necessarily consistent in all respects with each of the other initiating conditions specified in NUREG 0654 since many initiating conditions have no direct or immediate consequence in terms o f actual'or projected release of radioactive material.
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The information presented in Section 13.3.5.3 appropriately represents BECo's plans including consideration of the guidance available at the time o f publication of the PSAR.
NUREG 0654 was revised and published as Revision 1 in November 1980 and now makes specific reference to EPA Protective Action Guides under Example Initiating Conditions:
l Site Area Emergency.
l At the time of the Operating License, Pilgrim Unit 2 Emergenev Procedures will incorporate appropriate existing guidance on Emergency Classifications and Protective Actions as that guidance pertains to PNPS-2.
B. NUREG-0654.
4 C. None.
D. Applicants' Direct Panel.
TNTERROGATORY #7 Please provide, for each individual whom BECo 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 and the subject matter of his testimony on each such occasion.
RESPONSE #7 R. J. Merlino
- 1. Before the Vermont Public Service Board on matters relating to releases of radioactivity and radioactive waste treatment system design and performance for Vermont Yankee Nuclear Power Station.
- 2. Before the Atomic Safety and Licensing Board in nperating license hearings for Vermont Yankee Nuclear Power Station. Subject matter included population, meteorology, releases of radioactivity during normal operations and accidents and resulting radiation exposures, and performance of engineered safety systems.
- 3. Before the Atomic Safety and Licensing Board in operating license hearings for Maine Yankee Atomic Power Station. Subject matter included radiological sa fety.
- 4. Be fore the Atomic Sa fety and Licensing Board in construction permit hearings for Pilgrim Unit 2.
Subject matter included airplane crash probability at the Pilgrim site.
- 5. Before the Atomic Sa fety and Licensing Board in construction permit hearings for Seabrook Nuclear Power Sta tion. Subject matter included population and land use, meteorology and atmospheric dispersion, and loss of coolant accident consequences.
Robert H. Cunningham, Thomas Sowdon and Scott T.
McCandless have not previously testified as expert witnesses.
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INTERROGATORV #8 Please provide, for each individual whom BECo 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 planing and prepared, 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.
RESPONSE #8 Documents prepared in whole or in part by R. H. Cunningham:
Emergency Plan for Pilgrim Station.
Amendments 40 and 41, Pilgrim Unit 2 PSAR.
Documents prepared in whole or in part by T. Sowdon:
Emergency Plan for Pilgrim Station.
Documents prepared in wh' o le or in part by R. J. Merlino (partial list):
An Evacuation Analysis for the Pilgrim Site, ERT Document No. P-1543-1, Au gust 1975.
Study to estimate evacuation time for Charlestown Nuclear Project, incorporated into PSAR.
Final Sa fety Analysis Report for Yankee A.tomic Electric Company, material dealing with definition of low population zone and radiation exposures from postulated accidents.
Final Sa fety Analysis Report for Vermont Ya nkee Nuclear Power Station, content similar to 3.
Final Sa fety Analysis Report for Maine Yankee Atomic Power Station, content similar to 3.
Preliminary Safety Analysis Report for Seabrook Project, content similar to 3.
Emergency Plan and Implementing Procedures for St.
Lucie Nuclear Power Plant.
Emergency Plan and Implementing Procedures for Turkey Point fluclear Power Plant.
l Emergency Plan for Pilgrim Station.
Amendments 40 and 41 Pilgrim Unit 2 PSAR.
Radiological , Contingency Plan for Nuclear Fuel Services Facility in Erwin, Tennessee.
An Update of the Population Distribution Around the Pilgrim Site, July 31, 1981.
Documents prepared in whole or in part by S. T. McCandless (partial list):
Evacuation Times Estimates for Areas Near Pilgrim Station, original draft report dated January 1980 and most current version incorporated into Pilgrim Uni t 2 PS AR.
Evacuation Traf fic Management Plan for Sagamore / Buzzard's Bay (Draft), August 1981.
Evacuation Time Estimates for Arkansas Nuclear 1.
l
Major Roadcay improvements in the Vicinity of the Pilgrim Nuclear Generating Station. July 31, 1981.
Other Studies by HMM Associates (partial list):
Evacuation Time Estimates for Areas Near the Allens Creek PIvject.
J Evacuation Clear Time Estimates for Areas Near the Midland Michigan Nuclear Power Plant.
Farley Nuclear Site EPZ Evacuation Time Estimate Study.
At the request of HMM Associates, Boston Edision Company objects and moves for protective order regarding the production and identification of reports prepared or studies performed by HMM Associates for persons not a party to this proceeding, and in particular those which were not intended for public distribution or which were not publicly distributed.
The documents enumerated above are those reports that either have previously been made putilicly available, or which the clients for whom they were prepared have, of HMM's request, agreed to their production in this proceeding.
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1 SIGNATURES The foregoing answers are true to the best of my knowledge, information and belief, except insofar as they are based on infor-mation available to Boston Edison Company but not within my perLonal
! knowledge, as to which I, based on such iniormation, believe them to be true.
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Robert H. Cunningham j
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As to objections and motion for protective order:
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Thomas G. Dignan, Jr.
R. K. Gad, III s Ropes & Gray 225 Franklin Street Boston, MA 02110 Telephone: 423-6100 1
( {t-William S. Stowe Boston Edison Company 800 Boylston Street Boston, MA 02199 Telephone: 424-2544 l
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UMITED STATES OF AMERICA - /
NUCLEAR REGULATORY COMMISSION b ,_ , _
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) 'N In the Matt.er of ) N BOSTON EDISON COMPANY, et al. ) Docket No. 50-471
)
(Pilgrim Nuclear Generating )
Station, Unit 2) )
)
CERTIFICATE OF SERVICE I hereby certify that the Response Of Boston Edison, et al.
To Commonwealth Of Massachusetts' Second Set Of Interrogatories To Boston Edison Company Relative To Emergency Planning (Including Motion For Protective Order) filed in the above-captioned matter has been served on the following by deposit of a copy thereof in the United States mail, first class, postage prepaid:
Andrew C. Goodhope, 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, Ma ryland 20906 One Ashburton Place, 19th Floor Boston, MA 02108 Dr. A. Dixon Callinan Union Carbide Corporation Francis S. Wright, Esquire P. O. Box Y Berman & Berman Oak Ridge, Tennessee 211 Congress Street Boston, MA 02110 Dr. Richard F. Cole Atomic Safety and Licensing Board Henry Herrmann, Esquire U.S. Nuclear Regulatory Commission Room 1045 Washington, D.C. 20555 50 Congress Street Boston, MA 02110 Atomic Safety and Licensing Board Panel Mr. and Mrs. Alan R. Clecto".
U.S. Nuclear Regulatory Commission 22 Mackintosh Street Washington, D.C. Franklin, MA 02038 Atomic Safety and Licensing Uilliam S. Abbott, Esquire Appeal Panel Suite 925 U.S. Nuclear Regulatory Commission 50 Congress Street Washington, D.C. 20555 Boston, MA 02109 -
Michael B. Blume, Esquire Patrick J. Kenny, Esquire Jack R. Goldberg, Esquire Edward L. Selgrade, Esquire
- Stephen H. Lewis, Esquire Mass. Of fice of Einergy Resources Office of the Executive Legal 73 Tremont Street
, Director Boston, MA 02110 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Office of the Secretary Docketing and Service Section Chief Librarian U.S. Nuclear Regulatory Commission Plymouth Public Library Washington, D.C. 20555 North Street Plymouth, MA 02360 Thomas S, Moore, Chairman Dr. John H. Buck Atomic Safety and Licensing Atomic Safety and Licensing
' Appeal Board Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Christine N. Kohl, Esquire Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulutory Commission Washington, D.C. 20555
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l Dated: August 17, 1981 4
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