Why does this EPROM have comb-like structures around the wire bonding pads?
At this writing, there are two "answers" that are total guesses - and wrong at that too.

These comb structures are as you might expect to see when you want to induce breakdown at a precise location and into controlled structures rather than else where in the chip.  These are in the TOP metal layer, the combs are there to give lots of sharp edges to promote an excessively high ESD event to conduct at that location.

The diode and ESD clamping structures are by necessity in the Silicon.

These are very very far from being the transistor structures which are in the Si at least 3 - 7 metal layers down.

Look at lightning arrestors in the larger world.  You will see these exact same things there.

Call it a belt and suspenders approach.  Or rather a last chance, the actually ESD structures are rated for much lower voltage events.