ML071440332

Pilgrim - Declaration of Thomas L. Sowdon in Support of Entergy'S Motion for Summary Disposition of Pilgrim Watch Contention 3

ML071440332
Person / Time
Site:	Pilgrim
Issue date:	05/15/2007
From:	Sowdon T Entergy Nuclear Generation Co, Entergy Nuclear Operations
To:	Office of Nuclear Reactor Regulation
SECY RAS
Shared Package
ML071440314	List: ML071440321 ML071440325 ML071440332 ML071440333 ML071440354
References
50-293-LR, ASLBP 06-848-02-LR, RAS 13684
Download: ML071440332 (58)

Text

May 15, 2007 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of Entergy Nuclear Generation Company and Docket No. 50-293-LR Entergy Nuclear Operations, Inc. ASLBP No. 06-848-02-LR*

(Pilgrim Nuclear Power Station)

DECLARATION OF THOMAS L. SOWDON IN SUPPORT OF ENTERGY'S MOTION FOR

SUMMARY

DISPOSITION OF PILGRIM WATCH CONTENTION 3 Thomas L. Sowdon states as follows under penalties of perjury:

I. INTRODUCTION

1. I am the Manager of Emergency Preparedness with Entergy Nuclear Generation Company and Entergy Nuclear Operations (hereinafter and collectively, "Entergy") for the Pil-grim Nuclear Power Station ("PNPS"). In that capacity I am responsible for onsite and offsite emergency response planning

2. My professional and educational experience is summarized in the curriculum vi-tae attached as Exhibit 1 to this affidavit. I have 35 years of experience in the nuclear industry in

• variouspositions related primarily to Radiation Protection, Health Physics and Emergency Plan-ning responsibilities. I hold a Bachelor's Degree in Nuclear Engineering from the University of Lowell, a Master's Degree in Radiation Health Physics from the Massachusetts Institute of Technology, and a Doctor of Science Degree in Occupation and Environmental Epidemiology from the Harvard School of Public Health.

3. In my capacity as PNPS Manager of Emergency Preparedness, I am knowledge-able of the PNPS Emergency Plan, and the evacuation time estimates for the emergency plan.

These areas are one of the responsibilities of the Emergency Preparedness Staff at Pilgrim Sta-tion. I am also knowledgeable of the Severe Accident Mitigation Alternative ("SAMA") analy-ses prepared by Entergy for the Environmental Report that is part of the PNPS license renewal application. I have reviewed the analysis and provided advice and input on its preparation.

4. I am familiar with Contention Pilgrim Watch 3, which was raised by Pilgrim Watch in the NRC licensing proceeding for the PNPS license renewal. As admitted into the pro-ceeding by the Atomic Safety and Licensing Board, Pilgrim Watch Contention 3 asserts that "Applicant's SAMA analysis for the Pilgrim plant is deficient in that the input data concerning (1) evacuation times, (2) economic consequences, and (3) meteorological patterns are incorrect, resulting in incorrect conclusions about the costs versus benefits of possible mitigation alterna-tives, such that further analysis is called for."

5. My declaration addresses claims raised by Pilgrim Watch in Pilgrim Watch Con-tention 3 concerning the adequacy of the evacuation time estimates used in the PNPS SAMA analyses. 1will demonstrate that the PNPS SAMA analysis performed in support of license re-newal used the correct, up-to-date input data concerning evacuation time estimates, specifically the evacuation delay time and. the evacuation speeds.

II. BACKGROUND

6. Entergy uses the MELCOR Accident Consequences Code System ("MACCS2")

to perform the SAMA analyses contained in the PNPS environmental report. The MACCS2 model requires inputs from the PNPS Emergency Plan. One such input is the evacuation delay time, which is the elapsed time between the siren alert and the beginning of the evacuation. An-2

other such input is the speed at which the evacuation is accomplished, or evacuation speed, which was derived from evacuation time estimates "(ETEs") developed for the PNPS Emergency Plan. The evacuation delay time and evacuation speed used for the PNPS SAMA analysis were based on the ETEs developed in a study prepared by KLD Associates, which is entitled "Pilgrim Station Evacuation Time Estimates and Traffic Management Plan Update, KLD Report TR-203A-5, Rev. 5 (Nov. 1998)" ("1998 Study").r

7. The SAMA analysis for PNPS was prepared in 2002 and relied upon the informa-tion in the 1998 Study as the most recent information available. Subsequently, Entergy had KLD Associates prepare a study similar to the 1998 Study, entitled the "Pilgrim Nuclear Power Station Development of Evacuation Time Estimates, KLD TR-382, Rev. 6 (Oct. 2004)" ("2004 Study").2 Like the 1998 Study, the 2004 Study also developed ETEs for the PNPS Emergency Planning Zone ("EPZ").

8. Both the 1998 and the 2004 studies were undertaken to evaluate the results of an order that would be given to evacuate all or a portion of the EPZ as a protective action in re-sponse to a postulated accident event at PNPS. Both were performed in accordance with federal guidance for the preparation of such studies and followed the same general methodology. State and local officials provided demographic data and other necessary information was obtained from field studies and telephone surveys. Computer analyses were performed based on this in-formation and a representation of the evacuation network to calculate the ETEs for permanent residents and the transient population (tourists and employees) under varying scenarios which The 19.98 Study is also identified as Appendix 5 to the PNPS Emergency Plan. Pages from the 1998 Study referenced herein are attached to this Declaration at Exhibit 2.

2 The 2004 Study is also identified as Appendix 6 to the PNPS Emergency Plan. Pages from the 2004 Study referenced herein are attached to this Declaration at Exhibit 3.

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reflected "variation in demand, trip generation distribution and in highway capacity, associated with different seasons, day of week, time of day and weather conditions." 1998 Study at 1-3, Table 9-1; see also 2004 Study at 2-3.

III. RESPONSE TO EVACUATION TIME ESTIMATE CLAIMS IN PILGRIM WATCH CONTENTION 3

9. This portion of my declaration addresses the many issues raised by Pilgrim Watch in Contention 3 concerning the adequacy of the ETEs and the inputs used in the PNPS SAMA analysis. As I address below, there is no factual basis for the many claims raised by Pilgrim Watch in Contention 3 concerning the adequacy of the :ETEs and the SAMA analysis. Further-more, the analysis performed by Dr. Kevin O'Kula 3 shows that even if Pilgrim Watch's claims were accepted as true, no new potentially cost-beneficial SAMAs would be identified.

10. Pilgrim Watch claimsthat the MACCS2 model for the PNPS SAMA analysis (1) improperly limits the evacuation zone to 10 miles, (2) improperly assumes that the population is out of danger upon crossing the 10-mile Emergency Planning Zone boundary; and (3) fails to consider those who cannot evacuate and must shelter. Pilgrim Watch Pet. at 39, 42. Pilgrim Watch is wrong in all three respects.

11. The IvIACCS2 emergency response modeling for the PNPS SAMA analyses as-sumes that the entire 10-mile EPZ zone around the plant would be evacuated in accordance with the PNPS Emergency Plan as provided for by the Plan in appropriate circumstances when war-ranted based on actual orprojected releases of radioactive material from the plant. Environ-mental Report at E. 1-64. The MACCS2 analysis does not assume an evacuation zone of greater

3. Washington Safety Management Solutions, "Radiological Dispersion andConsequence Analysis Sup-porting Pilgrim Nuclear Power Station Severe Accident Mitigation Alternative Analysis," Revision I (May 2007) ("O'Kula Report").

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than 10 miles because to do so would not be realistic - the PNPS Emergency Plan only provides for evacuation within 10 miles of the plant, as required by the NRC. 1,0 C.F.R. § 50.33(g). Ac-cordingly, the assumption made by the SAMA analysis that evacuation is limited to the 10 EPZ is in accordance with the established PNPS Emergency Plan and NRC requirements.

12. Further, contrary to the suggestion made in the contention, dose consequences are"'

modeled for individuals beyond the 10-mile EPZ boundary. The SAMA analysis models the dose to members of the public not only within the 10-mile EPZ but also out to 50 miles and, thus, accounts for potential doses beyond 10 miles from the plant. See Environmental Report, Appendix E at E.1-61 (Table E.1-13). MACCS2 modeling of dose to the members of the public out,to 50 miles from the plant is fully explained in the O'Kula Report.

13. In addition, the MACCS2 modeling considers individuals who cannot evacuate upon being notified of an emergency. The PNPS emergency plans provide that state and local governments will provide assistance for those who cannot evacuate on their ownto evacuate.

PNPS Emergency Plan, § J ("Protective Response" at preamble and §J. 10.d), which is provided at Exhibit 4; Commonwealth of Massachusetts Radiological Emergency Response Plan at § 8.4, pp. 8-9 to 8-10, which is provided at Exhibit 5. Thus, the PNPS SAMA analysis properly as-sumes that persons who could not evacuate on their own would be provided assistance to evacu-ate.

14. Pilgrim Watch claims that the SAMA analysis did not use the most recent evacua-tion time estimates. Pilgrim Watch Pet. at 39. Pilgrim Watch's claim is without merit. The SAMA analysis relied on input from the 1998 Study because that was the most recent estimate at the time the SAMA analysis was prepared in 2002.

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15. Further, the evacuation delays times developed in the 1998 and 2004 studies are identical. The 1998 Study assumed that (1) 100% of "persons off the beach" would be notified of an accident within 40 minutes; (2) 100% of "persons on the beach" would be notified within 15 minutes; and (3) 100% of "persons on boats" would be notified within 60 minutes. 1998 Study at 4-6 to 4-7. (The PNPS SAMA analysis used the 40 minute notification time for 100%

of persons off the beach as the delay time for the analysis which would be a conservative as-sumption since many persons would have notification in less than 40 minutes. The slightly longer time for notification of any small subset of the total population, such as for boaters, is well within the sensitivity analyses performed for the evacuation delay time discussed below.)

The 2004 Study also assumed an evacuation delay time estimate of 40 minutes for persons off the beach; 15 minutes for persons on the beach, and 60 minutes for boaters, 2004 Study at 5-4 to 5-5, identical to the evacuation delay estimates for the 1998 Study. Thus, there is no basis to Pilgrim Watch's claim that data from the 2004 Study would somehow be better.

16. The ETEs used to derive the evacuation speed estimate inputs for the MACCS2 analysis are also virtually identical for the 1998 and 2004 studies. The evacuation speed esti-mates used as input for MACCS2 in the SAMA analysis are derived from the ETEs by subtract-ing the evacuation delay time of 40 minutes from the evacuation time estimate and dividing the resulting time by 10 miles. Therefore, because the ETEs for the 1998 and the 2004 studies are virtually identical, so are the evacuation speed estimates.

17. Both studies show estimated ETEs (including the evacuation notification or delay time) of greater than four hours .and less than seven hours to evacuate the general population within the entire EPZ (represented by evacuation region 22, or "R22" in the tables showing the 6

evacuation time estimates for the two studies). The longest ETEs for the two studies are as fol-lows:

For the 1998 Study the longest ETE for the general population was 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 50 minutes (for winter midday with snow). 1998 Study at Table 9-1OD. The corre-sponding evacuation speed estimate is 1.62 mph.

For the 2004 Study, the longest ETE for the general population was 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> -and 45 minutes (for off-season, midweek, midday, and snow conditions). 2004 Study at Ta-ble 7-ID. The corresponding evacuation speed estimate is 1.64 mph.

The shortest ETEs for the two studies were as follows:

• The shortest ETE in the 1998 Study for the general population was 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 25 min-utes (for winter evening without rain). 1998 Study at Table 9-10E. The correspond-ing evacuation speed estimate is 2.67 mph.

• The shortest ETE in the 2004 Study for the general population was 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 30 min-utes (for off-season, midweek/evening or weekend/all-day with good weather). 2004 Study at Table 7-ID. The corresponding evacuation speed estimate is 2.61 mph.

Thus, the ETEs and the derived evacuation speed estimates for the 1998 and 2004 studies are yirtually identical.and no change in the results of the SAMA analysis would result from using the evacuation speed estimates developed for the 2004 Study's ETEs rather than the 1998 Study's ETEs.

18. Pilgrim Watch asserts that evacuation time estimates were performed only for good weather scenarios and did not take into account commuter rush hour, summer weekend traffic, bad weather, or special events, such as the July 4 th celebration. Pilgrim Watch Pet. at 40, 42-43. Pilgrim Watch's assertions are demonstrably false. The 1998 Study developed ETEs for a wide range of scenarios. See 1998 Study at Table 9-1. The varying scenarios evaluated by the 1998 Study reflect a wide rangeof weather conditions, such as "Good," "Rain," and "Snow." Id.

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The 1998 Study also considered weather conditions in conjunction with other pertinent factors, such as "[sludden rain... with tourist and beach population at capacity concurrent with accident at Pilgrim Station." Id. (emphasis added). In addition, the 1998 Study considered conditions during both "Summer" and "Off-season" periods in the year, during both "Weekend" and "Mid-week" days, at a range of times during the day, including "Midday" and "Evening," and includ-ing periods of "Heavy Traffic." Id. (emphasis added). For example, the 1998 Study looked at an evacuation scenario -during the summer with rain. The summer with rain ETE was 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 30 minutes., including the evacuation delay time of 40 minutes. 1998 Study at 9-30, Table 9-1OA. The longest winter ETE was 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 50 minutes, which includes an evacuation delay time of 40 minutes. 1998 Study~at 9-33, Table 9-10D. Thus, this claim made by Pilgrim Watch-.

that an insufficient variety of scenarios was considered - is simply wrong.

19. Likewise the 2004 study considered the same broad range of scenarios, including the "Summer", on a "Weekend" or during "Midweek," during the "Midday" and "Evening," both with "Good Weather" and "Rain." See, S 2004 Study at Table 7-1D. The 2004 Study also

-examined "Off-Season" scenarios, during "Midweek" in the "Midday." with "Good Weather,"

"Rain," or "Snow", as well as during the "Midweek, Evening" or "Weekend, All Day," with

."Good Weather," "Rain," or "Snow." See,.g 2004 Study at Table 7-1D. Again, there simply is no basis for Pilgrim Watch to conclude that the data in the 2004 Study is better than the data in the 1998 Study.

20. Pilgrim Watch's assertions that the PNPS SAMA analysis used faulty evacuation time estimate assumptions for voluntary evacuations and shadow evacuation is also mistaken.

Pilgrim Watch claims that voluntary evacuation from within the EPZ was estimated to be 50%

within a 2-5 mile ring around the reactor, excluding the "key-hole;" and 25% in the annular ring 8

between the 5-mile boundary of the circle and the 10-mile EPZ boundary. Pilgrim Watch Pet. at

40. This is erroneous. The SAMA analysis was based on an assumed directed evacuation of the entire 10 mile EPZ in accordance with the Emergency Plan providing for such evacuation in ap-propriate circumstances. (For certain postulated events, the Emergency Plan does provide for evacuation of only certain regions of the EPZ, but those were not the basis of the SAMA analy-sis; the SAMA analysis assumed that everyone within the 10 mile EPZ would evacuate as di-rected.)

21. Likewise contrary to Pilgrim Watch's claims (Pet. at 40, 42-43), the SAMA analysis does take into account shadow evacuation via the provisions of the PNPS Emergency Plan, which underlies the development of the ETEs. As described in the Chapter 8 of the 1998 Study, various measures are taken to control access to the EPZ. The PNPS Emergency Plan pro-vides for keeping traffic from entering the EPZ, which will ensure that traffic to and from Cape Cod will not clog the roads in or near the EPZ. This provision. will also inhibit the effect of shadow evacuation by preventing the populace from towns not in the EPZ from feeding onto Route 3 and hindering the evacuation of the EPZ. The purpose is to both restrict entry into, and divert traffic away from, the EPZ in order to expedite the movement of evacuating vehicles.

1998 Study at 8-1. The major diversion routes are shown in Figure 8-1 at page 8-2 of the 1998 Study.4 Thus, shadow evacuation is accounted and mitigated for in the Traffic Management 4 For example, the ETE utilizes Route 3 to radially distribute traffic, outbound relative to the location of PNPS. Additionally, "traffic from Cape Cod will be diverted from the Sagamore Bridge to the Bourne Bridge. Thus, use of the Sagamore Rotary and westbound Route 6 north of the canal. will be reserved for evacuating vehicles. At the option of state officials, traffic exiting Cape Cod across the Bourne Bridge will be routed onto Route 25. Evacuating traffic will enter Route 25 farther west, in Wareham.

After the completion of evacuation from within the EPZ, the Sagamore Bridge would be reopened to traffic from Cape Cod, at the discretion of state officials." 1998 Study at 8-3.

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Plan, which serves as the basis for developing the ETEs, to ensure that shadow evacuation does not impede evacuation of the EPZ.

22. Pilgrim Watch claims that the evacuation delay time estimates of 40 minutes used for the base case and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> used in one of the sensitivity analyses in the SAMA analysis are inappropriate because it could take much longer to notify the population of an accident for sev-eral reasons, including (1) warning sirens cannot be heard by residents inside some buildings and houses under various circumstances (e.g., when windows are closed, air conditioners are on, bad weather, or buildings set back from road.) or inside vehicles; (2) word of mouth is the most likely method by which news of the emergency would spread, and if a severe accident occurred at 1:00 AM, the delay time could be 5-6 hours before community was awakened and the word spread; and (3) the delay time will vary from one person to another depending on where the per-son is (e.g., at home or sailing) and what the person is doing (e.g., person outside the EPZ may return to join other house hold members to evacuate).. Pilgrim Watch Pet. at 41.

23. There is no factual basis for Pilgrim Watch's many assertions. As previously ex-plained, the ETEs considered evacuation delay time estimates for persons off the beach, on the beach, or on boats. 1998 Study at 4-6 to 4-7. Indeed, the 1998 Study explicitly considers vari-ances in elapsed times: "The amount of elapsed time will vary from one individual to the next depending where thatpersonis, what that person is doing and related factors." 1998 Study at 4-2.

Further, "the estimated elapsed times for the receipt of notification can be expressed as a distri-bution reflecting the different notification times for different peoplewithin, and outside, the EPZ." Id. The evacuation notification or delay times provided above are the maximum times for notifying the different population categories based on the information developed for the 1998 and 2004 studies.

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24. Further, as discussed in the NRC's April 1, 2005 response to the 10 C.F.R. 2.206 petition filed by Ms. Mary Elizabeth Lampert ("Lampert Response"), which is provided at Ex-hibit 6, the NRC has found that, "[b]ased on evaluations by the Federal Emergency Management Agency (FEMA) and the NRC's quarterly evaluations of siren reliability, the NRC finds reason-able assurance that the PNPS public notification system has the capability to essentially complete, the initial notification of the public within the plume exposure planning zone within about. 15 minutes." Lampert Response at 1. As further explained in the NRC Staff enclosure to the Lampert Response, The public alerting system for PNPS uses 112 radio-controlled sirens that provide coverage of the 10-mile EPZ around the plant. Each siren is tested at least once a month to prove they are operable. They provide adequate sound levels to meet the design criteria for the emergency alert-ing system. They can be quickly activated by local officials when needed to alert citizens to listen to an emergency broadcast station for further instructions. The NRC staff has concluded that the siren system at PNPS fulfills NRC and FEMA requirements for anemergency alerting system.

NRC Staff Enclosure to Lampert Response at 2. Pilgrim Watch offers no basis to conclude that the siren system is inadequate when evaluated against applicable federal regulations and guid-ance.

25. Furthermore, PNPS performed a sensitivity case analysis, which assumed an evacuation delay time of two hours - triple the 40-minute base case. Environmental Report at El 1-64. Comparison of the consequences shows that there is less than a 2 %/odeviation between the base case and the sensitivity case. Environimental Report at E. 1-68. In addition, as discussed inthe O'Kula Report, PNPS has performed another sensitivity analysis that assumed a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> evacuation delay time from the EPZ, the delay time asserted by Pilgrim Watch if an accident were to occur during the middle of the night. O'Kula Report at Appendix F, p. F-1. That sensi-11

tivity case resulted in only a 5% increase in public dose risk. Id. As explained in Section 5 of the O'Kula report, the effects of these increases are negligible and no new potentially cost-effective SAMAs would be identified.

26. Pilgrim Watch claims that the evacuation speed estimates used in the SAMA analysis are inappropriate because the traffic estimates ignored both summer week-end traffic and special events and shadow evacuation. Pilgrim Watch Pet. at 42-43. However, as discussed above, the traffic estimates expressly account for wide range of traffic conditions, including a

"'sudden summer rain with tourist and beach population at capacity concurrent with accident at Pilgrim Station." 1998 Study at Table 9-1 (emphasis added). As also discussed above, the PNPS Emergency Plan does consider and take mitigating steps to ensure that shadow evacuation does not impede evacuation of the EPZ.

27. Also, the SAMA analysis ran sensitivity cases changing the evacuation speed with again only negligible impacts on the public dose risk. The base case used an evacuation speed of 2.17 mph5 which is the approximate average of the longest and the shortest evacuation time es-timates in the 1998 Study set forth above (of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 50 minutes for winter midday with snow and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 25 minutes for winter evening, without rain) after subtracting 40 minutes from these estimates for the evacuation delay time. A sensitivity case was run assuming an evacuation speed of 1.54 mph - a 30% decrease from the base case. Again, comparison of the consequences shows that there is less than a 2% deviation between the base case and the sensitivity case. Envi-ronmental Report at E. 1-68. Additionally, the O'Kula report ran a sensitivity case with the ex-tremely slow evacuation speed of 0.76 mph, approximately one-third the speed of the base case 5 The precise average is 2.15 mph. The evacuation speed of 2.17 mph used in the base case differs be-cause of an inconsequential calculational error in the Environmental Report.

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and less than one-half of the speed of the initial sensitivity case. This extremely slow evacuation speed showed only an increase of 3% in the public dose risk. O'Kula Report at Appendix F, p.

F-2. Finally, the O'Kula report also ran a sensitivity case where no evacuation from the EPZ oc-curred. This analysis resulted in an increase of 6% in public dose risk. O'Kula Report at Ap-pendix E. Again, the effects of.these increases are negligible and no new potentially cost-effective SAMAs would be identified as explained in Section 5 of the O'Kula report.

28. In short the results from the SAMA analyses are insensitive to large variations in evacuation delay time and evacuation speed inputs.

.29. Finally, Pilgrim Watch challenges the evacuation time estimate undertaken under winter conditions because Entergy's assumption that snow removal-will only add an hour and a half to the evacuation time is allegedly too optimistic. Pilgrim Watch Pet. at 42. However, a sound factual basis underlies this assumption. To develop the evacuation time estimates, a tele-phone survey was conducted to augment census data and to elicit specific information regarding estimates-of response times to defined-events-and to more accuratel-y-represent-anticipated behav-ior-characteristics of the evacuating-population. A telephone surveywas -conducted which asked EPZ residents how long would it take for them to clear 6 to 8 inches of snow to move a car from the driveway or curb to begin the evacuation trip. 1998 Study at 4-23 to 4-24; 2004 Study at 5-12 to 5-13. The responses from the survey indicate that approximately 85 percent of driveways would be passable within about .1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, and the the last driveway would not be cleared until about 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after thestart of this activity. 1998 Study at 4-24; 2004 Study at 5-13. The snow removal time estimate distributions are accounted for in the ETEs. 1998 Study at 4-23; 2004 Study at 5-12. In addition, to develop the evacuation time estimates for winter snow conditions, information was obtained from local officials on their capability to remove snow from the road-13

ways and sensitivity analyses were performed based on the rate of snowfall. 1998 Study at 4-23; 2004 Study at 5-12. Furthermore, even assuming all driveways could not be cleared within 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and evacuation would take longer than estimated, this case would still be bounded by the sensitivity analyses described in the O'Kula Report, which alternatively assumed no evacuation, an evacuation delay time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and an evacuation speed of less than one half of that esti-mated in the 1998 Study for winter snow conditions. As explained in Section 5 of the O'Kula report, these analyses resulted in negligible increases in results such that no new potentially cost-beneficial SAMA's would be identified.

IV. CONCLUSION AND

SUMMARY

25. My testimony in this declaration demonstrates that the PNPS SAMA analysis per-formed in support of license renewal used the correct input data concerning evacuation time es-timates, specifically the evacuation delay time and the evacuation speeds. There is no factual basis for the many claims raised by Pilgrim Watch in Contention 3 concerning the adequacy of the ETEs.

I declare under penalty of perjury that the foregoing is true and correct.

Thomas L. Sowdon 14

EXHIBIT 1 RESUME THOMAS L. SOWDON 15 Alison Circle, Plymouth, MA 02360 508-747-3024 (Home); 508-830-8834 (Work)

EDUCATION Lowell Technological Institute Bachelor of Science Degree in Nuclear Engineering, June 1972 Massachusetts Institute of Technology Master of Science Degree in Nuclear Engineering with a Specialty in Radiological Health Physics, February 1988 Harvard School of Public Health Doctoral of Science in Environmental and Occupational Epidemiology, June 1999 SPECIALIZED QUALIFICATIONS

• Certified by the American Board of Health Physics in the Specialty of Power Reactor Health Physics - October 1983

• Appointed Adjunct Professor in the Nuclear Engineering Department at Worcester Polytechnic Institute, 1991 through 1994

• Member Massachusetts Department of Public Health, Nuclear Incident Advisory Team (NIAT)

EXPERIENCE January 2000 to Present - Manager of Emergency Preparedness - Entergy - Pilgrim Station Responsibilities/Experience:

- Responsible for the Emergency Preparedness Program and Emergency Response Organization at Pilgrim Station including procedures, equipment, staffing, drills and

• exercises.

- Responsible for interface with Federal, State and local government agencies including MEMA, FEMA, RIEMA, MDPH and local CD Directors.

- Responsible for budget administration and control and budget contingencies for special projects.

September 1977 to January 2000 - Boston Edison Company/Entergy - Pilgrim Station June 1987 to January 2000 - Chief Radiological Scientist Pilgrim Nuclear Power Station Plymouth, Massachusetts Responsibilities/Experience:

- Manager for environmental epidemiology studies including review and evaluation of state and private studies and direction and oversight of consultant efforts.

- Technical representative for issues involving the biological effects of ionizing radiation as they -apply to the occupational radiation worker and members of the general public.

- Primary interface with the Commonwealth of Massachusetts and the general public for issues involving the health concerns associated with ionizing radiation resulting from both normal plant operation and accidents.

August 1985 to June 1987 Radiological Section Manager Pilgrim Nuclear Power Station Plymouth, Massachusetts Responsibilities/Experience:

- Fulfill the function of Radiation Protection Manager as specified in USNRC Regulatory Guide 1.8.

Overall responsibility for administrative and technical performance of the Radiation Protection Program including:

- Procedure development and modification

- Internal and external exposure control

- Internal and external dosimetry

- Respiratory protection equipment

- In-vivo and In-vitro bioassay

- Radiation detection instruments

- ALARA requirements

- Plant design change review and approval

- Radiological occurrences

- Routine surveillance

- High radiation area control

- Air sampling

- Radioactive source inventory and control

- Radiation work permits

- Shielding analyses

- Accident analyses

- Radiological environmental monitoring program

- Offsite dose calculations

- Meteorological monitoring program January 1981 to August 1985 - Environmental and Radiological Health and Safety Group Leader Nuclear Operations Support Department Braintree, Massachusetts.

Responsibilities/Experience:

2

- OVerall responsibility for administrative and technical performance of the corporate Health Physics staff including:

- Procedure development and modification

- ALARA requirements for plant modifications

- Shielding specification and design

- Accident analyses

- Radiological environmental monitoring program

- Offsite dose calculations-

- Health Physics support for the Emergency Plan September 1977 to January 1981 Ssenior Radiological Engineer Nuclear Engineering Department Braintree, Massachusetts Responsibilities/Experience:

- Management of the Radiological Environmental Monitoring Program including all required reports

- Evaluation of sample analysis results

- Offsite dose assessment

- Issue and maintenance of the Offsite Dose Calculation Manual (ODCM)

- Meteorological monitoring program management

- Supervision of equipment maintenance, calibration and data reduction

- Calculation of atmospheric dispersion factors for offsite dose assessment May 1972 to September 1977 - Stone and Webster Engineering Corporation - Power Enaineer Responsibilities/Experience:

- Radiation shield design including:

- Determination of radiation source strengths and distributions

- Establishment of anticipated radiation zones throughout the plant

- Specification of the thickness and material for shielding

-Specification preparation for process and effluent radiation monitoring systems for both analog and digital systems

- Calculation of offsite doses due to routine and accidental releases

- Establishment of restricted area, exclusion area and low population zone boundary distances

- Evaluation of population doses due to effluents, direct and scattered radiation from the plant 3

EXHIBIT 2

/ssoiate II,,

Ass o ci ate s, I nc.

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Pilgrim Station Evacuation Time Estimates And Traffic Management Plan Update Prepared By Prepared For KLD Associates, Inc. Boston Edison Company 300 Broadway Emergency Preparedness Division Huntington Station, NY 11746 Rocky Hill Road TEL: (516) 549-9803 RFD #I FAX: (516) 351-7190 Plymouth, MA 02360 November 1998 Rev. 5 WCT Fb PoID.,,t TD )n-2 Ar

1. INTRODUCTION This report describes the analyses undertaken, and the results obtained, in a study to update the existing Evacuation Plan for Pilgrim Station, located in Plymouth, Massachusetts. This plan is--.

designed to protect the health and safety of the public in the event an evacuation is ordered as a protective action in response to an accident at Pilgrim Station.

The Evacuation Time Estimate and Traffic Management Plan presented herein is not based on the use of any specific number of reception centers. It should be understood that the number of reception centers does not affect evacuation time estimates as long as the reception centers are located a sufficient distance from the Emergency Planning Zone (EPZ) boundary. The reception centers cited in this document are located more than ten miles from the EPZ boundary.

In the performance of this effort, all available prior documentation relevant to evacuation planning issues was reviewed.

In addition, work products developed by other consultants were incorporated, where appropriate. Finally, local and State public officials, as well as private citizens, were interviewed. In particular, we wish to express our appreciation to all the Police Chiefs of the communities within the Pilgrim Station Emergency Planning Zone (EPZ) who provided valued guidance in the development of this plan.

Other guidance is-provided by documents published by Federal Government agencies. Most important of these are:

Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, NUREG 0654/FEMA-REP-l, Rev. 1, November 1980.

Analysis of Techniques for Estimating Evacuation Times for Emergency Planning Zones, NUREG/CR-1745, November.1980.

1.1 Overview of the Plan Update Process The following outline presents a brief description of the work effort in chronological sequence:

1. The initial effort consisted of gathering information:

o Review of existing reports describing past evacuation studies.

o Conducted several field surveys of the EPZ highway system and of beach-area traffic conditions.

1-i Rev. 5

o Developed a survey instrument to solicit data describing the travel patterns, car ownership and household size of the population within the Pilgrim EPZ. This survey also obtained data' on the public's projected responses to an emergency at Pilgrim_-.

-Station.

o Retained a subcontractor to conduct a stratified random-sample telephone survey of the populace within.,

the Pilgrim EPZ.

o Obtained demographic data from State Planning offices.

o Received, and analyzed, aerial photographs of the.

coastal areas within the Pilgrim EPZ. These photographs were taken on weekends during the Summer, of 1986. Additional Aerial photography was performed during ideal weather conditions on July 5, 1987.

I

2. After reviewing and analyzing this information, the task of preparing the preliminary input stream for the IDYNEV model was undertaken. Individual activities included:

o Estimating the traffic demand based on the available information derived from Census data, from prior studies, data provided by local and State agencies and from the telephone survey.

o Employing the procedures specified in the 1994 Highway Capacity Manual (HCM) and the data acquired during the field survey, to estimate the capacities of all highway segments comprising the evacuation routes.

o Developing __the link- node. representation of the evacuation network, which is used as the basis for the computer analyses which calculate the Evacuation Time Estimates (ETE). The IDYNEV System, developed by KLD for FEMA, was used to perform these calculations.

o Preparing the input stream *for the IDYNEV System.

o Executing IDYNEV to provide the initial estimates of evacuation routing and Evacuation Time Estimates (ETE) for a single scenario.

3. Based primarily on the survey results, the distributions of Trip Generation times were estimated for the various population segments: permanent residents and transients (i.e. tourists and employees).

1-2 Rev. 5

4. A total of ten evacuation scenarios were defined. These-scenarios reflect the variation in demand, trip generation distribution and in highway capacity, associated with different seasons, day of week, time of day and weather conditions. .. ..

5. Updated the demand estimation of employees who work within the EPZ, based on more recent information obtained from State Labor agencies.

6. Defined a preliminary set of traffic management tactics to be applied at specif~ied Traffic Control Posts (TCP),

for subsequent review by local and State police personnel.

7. Partitioned the EPZ into Emergency Response Planning Areas (Subareas), then defined a total of 22 "Regions",

where each region consists of a grouping of not necessarily contiguous Subareas. Each region either approximates a circular area or a "keyhole" quadrant within the EPZ, as required by NUREG 0654.

8. Identified Host Communities associated with each community within the EPZ and developed traffic routing patterns for evacuating vehicles.

9. Conducted a survey of police chiefs within the EPZ to solicit their opinions and recommendations on traffic routing, control and management. The preliminary design (items 6 and 8, above) was used as the basis for discussion. All local law enforcement officers contributed valuable recommendations and all recommendations were integrated into the plan.

10. Using the traffic management policies derived in step 9, a complete set of ETE was computed. This set consists of over 220 distinct cases; each case corresponds to the evacuation of a specified reQion for a specified evacuation scenario. A total of 22 regions and 10 scenarios (see step 4) were considered.

1i. Documented the results of these studies in formats responsive to NUREG 0654.

12. Identified Access Control Posts (ACP) at locations along the periphery of the EPZ and developed traffic management control to be applied there. Discussed the need for highway signing at these locations.

13. Identified a diversion route circumventing the EPZ.

1-3 Rev. 5

o Identify temporal points of reference for the purpose of uniquely defining "Clear Time" and Evacuation Time Estimates (ETE).

It is more likely that a longer time will elapse between the various classes of an emergency at Pilgrim. For example, suppose two hours elapse from the declaration of a General Emergency to the Directive to Evacuate. In this case, it is reasonable to expect some degree of spontaneous evacuation during this two-hour period".

As a result, the population within the EPZ will be lower when the Directive to Evacuate is announced, than at the time of the General Emergency. Thus, the time needed to evacuate the EPZ, after the Directive to Evacuate may be significantly less than the estimates presented in this report.

On the other hand, there is a low probability that an "immediate" General Emergency can arise, with the Directive to Evacuate given almost simultaneously. In this case, the' evacuation time estimates (ETE) will be somewhat longer than the figures presented herein.

The planning basis adopted here approximates the "worst case" conditions, and is within 25 minutes of the most extreme condition.

The notification process consists of two events:

o Transmitting information (e.g. using sirens,.tone alerts, EBS broadcasts, loudspeakers).

o Receiving and correctly interpreting the information that is transmitted.

The resident population within the EPZ exceeds 80,000 persons who are deployed over an area of approximately 150 square miles, and engaged in a wide variety of activities. During the summer, more than 30,000 additional persons could be within the EPZ. It must be anticipated that some time will elapse between the transmission and receipt of the information.

The amount of elapsed time will vary from one individual to the next depending where that person is, what that person is doing, and related factors. Furthermore, persons who will be directly involved with the evacuation process may be outside the EPZ at the time that the emergency is declared. These people may be commuters, shoppers and other travelers who reside within the EPZ andwho will return to join the other members in the household upon receiving notification of an emergency.

As indicated in Appendix 4 of NUREG 0654, the estimated elapsed times for the receipt of notification can be expressed as a distribution reflecting the different notification times for different people within, and outside, the EPZ. By using time 4-2 Rev. 5

The population within the EPZ includes 76.8 percent of all residents, as computed above, and 100 percent of all tourists and employees, by definition.

It is reasonable to expect that 90 percent of those within thei EPZ will be aware of. the accident within 15 minutes with the!

remainder notified within the following 15 minutes. The commuters.

outside the EPZ will be notified somewhat later, say uniformly between 10 and 40 minutes, while the entire beach area population will be notified within 15 minutes. The primary'means of notifying boaters off shore is through EBS and Coast Guard broadcasts.

However, mariners who do not have radios, or whose radios are not tuned to EBS or emergency frequencies will take longer to notify.

It is assumed that 50 percent of boaters are noti :ted j4a minutes, *with the balance notified by 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after th Site Area-Emergency has been declared. The resulting distribution this-notification activity are given below:

Distribution No. 1, Notification Time: Activity 1 -'> 2 Persons off the Beach: Distribution 1A Elapsed Cum. Pct.

Time (min.) Notified 5 15 10 46 15 79 20 85 25 90 30 95 35 98 40 100 Persons on the Beach: Distribution lB Elapsed Cum. Pct.

Time (min.) Notified 5 20 10 60 15 100 Persons on Boats: Distribution 1C Elapsed Cum. Pct.

Time (min.) Notified 5 5 10 10 15 15 20 20 4-6* Rev. 5

Elapsed Cum. Pct.

Time (min.) Notified 25 25 30 30 35 40 40 50 45 60 50 75 55 90 60 100 It is reasonable to expect that the vast majority of business enterprises within the EPZ will elect to shut down following notification. Most employees would take action to leave work quickly. Commuters who work outside the EPZ could,- in 'all probability, also leave quickly since -facilities outside the EPZ would remain openand other personnel would remain. Personnel responsible for equipment would require additional timb to secure the facility. The distribution of Activity 2 -- > 3 reflects data obtained by the telephone survey. This distribution is plotted in Figure 2-1 and listed below as Distribution 2.

Distribution No. 2, Time to PreDare to Leave Work:

Activity 2 -- > 3 Elapsed Cum. Pct.

Time (min.) Leaving Work 5 56 10 72 15 81 20 84 25 85 30 92 35 93 40 94 45 95 50 96 55 96 60 98 65 98 70 98 75 98 80 98 85 99 90 99 95 99 100 99 105 99 110 100 4-7 Rev. 5

Snow Clearance Time Distribution Inclement weather scenarios involving snowfall. must address the time. lags associated with snow clearance. Discussions with local officials indicate that snow plowing equipment is mobilized and deployed during the snowfall to maintain passable roads. The general consensus is that their efforts are generally successful for all but the most extreme blizzards when the rate of snow accumulation exceeds that of snow clearance over a period of many hours.

Consequently, it is reasonable to assume that the highway system will remain passable -- alpeit at a lower capacity -- under the vast majority of snow conditions. Nevertheless, for the vehicles to.gain access to the highway system, it is necessary for

.driveways and employee parking lots to be cleared to the extent needed to make them passable. These clearance activities take time, and this time lag must be incorporated into the trip generation time distributions. Thus,..we must postulate;a separate distribution for the driveway snow clearance. activity and then introduce this distribution into the procedure. used to calculate.

the trip generation time distribution.

The time needed to clear a driveway depends on the depth of snow, the available equipment and the number of able-bodied personnel to perform the task. Since this area is accustomed to heavy recurring snowfalls (see Table 1-1), it is r~easonable to expect that virtually all households have made provision for snow clearance by either owning some form of equipment or by contracting

.for such service to be performed by others. The snow clearance distribution shown in Table 4-5 was obtained from the telephone.

survey.

It is recognized that the snow clearing activity can take

-place-. in parallel with other activities, e.g. preparing for evacuation. Nevertheless, we will adopt the conservative point of view that this activity follows the preparation activity, rather than proceeding in parallel with it. This posture will lengthen the temporal extent of the trip generation process.

The event "Driveways cleared of snow" will be identified as Event No. 5 and the event "Leave to Evacuate" is Event No. 6 for scenarios involving snow conditions.

The following additional operations are needed to compute the

.trip generation distributions for the inclement weather, snow scenarios:

4 -23 Rev. 5

Table 4-5: Distribution of Snow Clearance Time:

IDistribution 5

Elapsed Time Cum. Percent of (rin.) Driveways Cleared 5 8 10 17 15 2.8 20 37 25 45 30 50 53' 35 40 56 45 59 50 63 55 66 60 70 65 73 70 76 75 79 80 81 85 83 90 84 95 85 100 86 105 86 110 87 115 88 120 88 125 89 130 90 135 91 140 91 145 91 150 92 155 92 160 92 165 92 170 ý92 175 93 180 94 185 95 190 97 195 100.

Note: The survey data was normalized to distribute the "Don't Know" response 4-24 Rev. 5

8. ACCESS CONTROL WITHIN, AND AT THE PERIPHERY OF, THE EMERGENCY PLANN!ING ZONE (EPZ) AND DIVERSION ROUTES-The purpose of peripheral access control is to restrict entry to the Emnergency Planning Zone (EPZ) and to expedite the traffic movement of evacuating vehicles. Entry should be permitted for the following groups:

o Commuters returning to the EPZ, to gather members of their household for the purpose of evacuation.

o Transit vehicles (buses, vans, ambulances) dispatched to the EPZ to participate in lany evacuation.

o All vehicles transporting emergency response personnel.

All other travelers seeking to gain entry to the EPZ should be denied access and provided with local diversion routes. These local diversion routes will enable those denied entry to reverse their paths and seek other routes outside the EPZ.

Figure 8-1 indicates the major diversion route and the cordon line around the EPZ. The intersections of this cordon with highways demark the locations of Access Control Posts (ACP) .

Appendix I presents maps, summary tables, and sketches detailing the traffic management at each identified location. Appendix L presents a list of access control points to be activated for each evacuation region.

The diversion route was developed to satisfy the following objectives:

1. The route should be sufficiently removed from the EPZ so as to minimize (to the extent possible) the extent that diverted traffic will mingle with, and thereby impede, the evacuating vehicles traveling toward their respective host relocation centers. Any such mingling, and consequent impedance should take place well outside the EPZ.

2. To the extent possible, the diversion route should consist of high-capacity highways.

A comparison of the diversion route in Figure 8-1, with the evacuation routes shown in Appendix K and described in Appendix J, will indicate that the first objective is satisfied.

Specifically, the diversion routes chosen (i.e. 1-93/Route 128, 1-95, 1495/Route 25, US Route 6) offers travelers a path around the Pilgrim EPZ along major, limited-access routes.

8-i1 Rev. 5

.7.1 U

OW B

,Vi y Falls,

'AlFiur 8 D s Onto Ra t,.,,,, , s* A s t C . n Soncn Buzzafiiq U77AC Tiye .Riov-  ;.jedf pPilgrim Figure 8-1. Diversion Route and Access Control Cordon For Station Emergency Pl anning Zone 8-2 Rev. 5

Discussions with the Massachusetts State Police have indicated the importance of maintaining traffic flow through the 1-93, Route 3, Route 128 interchange. Consequently, it is proposed to inform southbound vehicles of the closure of Route 3 southbound at Route 18 and suggest the use of -the diversion route. Drivers will be informed of these conditions through the. use of temporary road signs, erected along southbound 1-93 prior to . the Route 3 interchange.. Traffic proceeding south on Route' 3 will also be informed via road signs of the closure of Route 3 at.the Route 18, interchange.

An advisory sign will also be placed along southbound 1-93 at Furnace Brook Parkway to recommehnd that drivers use southbound Route 37 (Willard St.) as an alternative path to Route 128. Drivers who divert using this path will relieve, traffic on the 1-93 connector to Route 128 when the Braintree Reception Center is active.

In the event of an accident at Pilgrim Station, traffic from Cape Cod will be diverted from the Sagamore Bridge to the Bourne Bridge. Thus, use of the Sagamore Rotary and westbound Route 6 north of the canal will be reserved for evacuating vehicles. At the option of state officials, traffic exiting Cape Cod across the Bourne Bridge will be routed onto Route 25. Evacuating traffic will enter Route 25 farther west, in Wareham. After the completion of evacuation .from within the EPZ, the Sagamore Bridge would be reopened- to traffic from Cape Cod, at the discretion of state officials.

Sketches of specific traffic control plans are presented in Appendix I.

The second objective has been satisfied by the choice of routes. All diversion routes are multilane highways. Routes 1-93, 1-95, 1-495 and 25 are limited access highways.

The northern end of the diversion route connects with 1-93 at the Route 3 interchange, south of Boston, while the southern end of the diversion route connects with Routes 6 and 28, the primary access roads to Cape Cod.

The cordon line and the ACP locations were developed to satisfy the following objectives:

1. Control all open.roads crossing each Region boundary.

.2. Select ACP locations

- as close to the EPZ boundary as possible so as to minimize the number. of people who could originate a trip into the EPZ from points between the ACP and the EPZ 8-3 IRev. S

Table 9-1. Description of Evacuation Scenarios 1-10 Scenario Season Day Time Weather Comments Summer Weekend Midday Good Tourist and beach area population at. capacity.

Employees are at 70'. of midweek along the coastal azea, 40% -in remaining areas; Tourists fill all available seasonal and overnight facilities.

'A Summer Weekend Evening Good As above. Heavy traffic on Route 3 northbound.

2 Summer Weekend Midday Rain As above. Sudden rain occurs with tourist and beach population at capacity concurrent with accident at Pilgrim Station.

-A Summer Weekend Midday Rain As above. Heavy traffic on Rou:e 3 northbound.

Summer Midweek Midday Good Beach area and tourist population at 75% of capacity.

Employees are at 100% of midweek work force.

Summer Midweek Midday Rain As above. Sudden rain occurs.

5 Off-season Midweek Midday . Good Tourist population at 25% of capacity for open facilities.

No beach area transients.

Employees at 100%.

Off-season Midweek Midday Rain As above, but for inclement (rain) weather.

7 Off-season Midweek Midday Snow As above, *but for inclement (snow) weather. Evacuees must clear driveways.

2 Off-season Midweek Evening Good Tourist population at 25% of W;eekend All day capa.city. No beach area zransients.--Employees at 25% of midweek, midday work force.

I Off-season Midweek Evening Rain As above, but for inclement Weekend All day 'rain) weather.

0 Off-season Midweek Evening Snow As above, but for inclement W.eekend All day ncw weather. Evacuees-must c.ear driveways.

2 Rev. 5

-ALIM U

Table 9-10A: Summary of Results of Evacuation Time Analysis Scenarios 1 and 2 I Relative To Siren Aleflt Permanent Response*

{Transient Reporse From Dlrectivelo Evacuate General Pop.

Evacuation IEvacuation Speia Population j

Tim Prmanent Transient Evacuation Noiy Prep. Tim Time~ Tie Tmie I Tie Cnim Tm Aes Pp Vehs. POP:.- ehs. Caacity-Tm Time Clear TIm Adv. ie ie Tme ie Coir Tme ie Clear Adv. Clear Adv.- 'Time Clear Adv.

LpMh* J--.... g i.p

!!p.. c t L~

fe9 !1 50 J 13:3068 61 9

_____~~~

1 00:40 311 3:30 1 3:31

. .4 .

.1:00

~~..~

.~~n~Ml 3 6:30 6:45 Region 2 112 . 43 284 1123 12843 00:40 3:15 3:30 _3:30 3:30 *.3:30 3:35 4:35 *1:15 6:30 6:45 Region 3 23636 9092 802 314 21123 00:40. 3:15 j 3:30 3:30 _3:30 3:30 .3:35 4:35 1:15 6:30 6:45

!Ig!on 4 17115 _6583 6728 2638 17690.0 :40. 315 3:30 3:30 3:30 _. 3:30 j 3:35.. 4:35 1:15 6:30 J 6:45 Meglon 5 17140 6593 8194 3213 22895 00:40 3:15 3:30 3:306 3:30' 3:30 3:35 4:35 1:56:30 6:45 fteglon 6 5027 1934 3034 1190 9522 00:40 3:15 3:30 3:30 3:30 3:30 3:35 4:35 1:15 6:30 _ 6:45 2 23661

...... 9102 9490 3721 20163 00:40 3:15 ...3:30 3:30._.._3:30 3:30 3:35_L 4:35 1:15 6:30 6:45.

________ ____Within Ten Miles . . ____ - &4 ._____ ____

!4gion 7 17908 6889 11464 . 16390 3:15 3:30 3:30. " 3:30

• 3:30 4:05 5:00 1:15 6:30 6:45 9g9on q 30021 .18777 7363 00:40 3:30 3:30 3:30 4:.20 5:25 1:15 7:05 7:20 f!lg!on 9 46i14 8065 28332 00:40 3:15 3:30 3:30. 3:30 4:30 5:35 1:15 7:05 7:20 S 28332 I. RN!on 10 42329 16282 11967 00:40 3:15 3:30 3:30 3:30 3:30 4:40 5:35 1*15 7:05 7:20,_

4692 Region 11 50283 19342 11967 29524 00:40 3:15 3:30 3:30 3:30 3:30 4:30 5:40 1:15 7:05 7:20__

C 3:30 Region 12 54997 21155 1:407 5257 29524 00:40 3:15. 3:30 3:30 3:30 4:55 6:05 1:15 .7:05 7:20 I" 37415 3:30.

Region 13 69765 26835 17408 6826 00:40. 3:15 3:30 3:30 3:30 5:.00 6:25 1:15 7:05 7:20 3:30 fiq!on 14 63354, 24369 15365 6124 374 15 00:40 t00:40 -3:15 3:30 ,3-:30 4:55 6:30.S 6:25 .. 115S. 7:05 7:20 3:30

.510?2 19645 5280 00:40 3:15 3:30-1 3:30 3:30 4:55 6:05 1LI15 7:05 7:20 Region 15 5855 33202 00:40 3:15 3:30 3:30 3:30. 3130 4:45 6:0.5 1:15 7:05 7:20

• 51097 19655 .14931 Region 17 52954 20370 19263 7554 33202 00:40 3:15 3:30 3:30 3:30 3:30 5:00 6:05 1:15 7:05 7:20 Region 1o 45000 17310 .1982H 7383 33202 00:40 3:15 3:30 3:30 3:30 3:30 4:35 .5:35 1:15 7:05 3:30 21652 8.329 11367 4458 21519 00:40 3:15 3:30 *3:30 3:30 4:00 5:20 I15 5:50 6:05 Re!on 219 3:30 9ýg!on 20 *6884 7366 2889 21519 00:40 3:15 3:30 3:30 3:30 4:00 4:45 1:15 5.50 6:05 3:30 9ýg!qq 22 84553 33102 29042 00:40 3:15 3:30 3:30 3:30 -5:05 _1:15_ 7:05 7:20 3252.5 Rev. 5 ID

(.0

U14P Table 9-10B: Summary of Results of Evacuation Time Analysis Scenarios 3 and 4 Relative To Siren Alert From Directive o Evacuate A Permanent

-Pop-

-V-ehs.

P Transient "Pop. Vehs.

Evacuation Capaclty I I Notify Time IPermanent Prep.

Time

Response

Time Clear Tine Adv.

Transient

.. Response.

Time Clear .

Time Adv.

General Pop.

Evacuation Time Clear Time Adv.

Confirm Time Special Population Evacuation Time Clear TIme Adv.

Areas 11755 4621924 6921 00:40 3:15 4:10 4:10 3:30 3:30 4:30 1 4:35 06:0 I 1 6:45

________ 4.;.......~ .. .'..... flit___ :a Y l.- ______ ..

11523 4433 .. 2148 843 12843 00:40 3:15 410 .4:10 3:30 3:30 4:30 4:35 1:15 6:30 6:45 Regn 3 ,23636 9092 6022 2362 . 21123 00:40 3:15 4:10 4:10 3:30 3:30 4:30 4:35 0:15 6:30 6:45 Region 4 17115 6583 5049 1981 17690 00:40 3:15 4:10 4:10 3:30 . 3:30 . . 4:30 4:35. 1:15 6:30 6:45 Region 5 17140 6593 _ 6150 2413 22895 00:40 3:15 4:10 4:10. 3:30 3:30 . 4:30 4:35 1:15 6:30 6:45 Reg!9n 6 5027 1934 2276 894 9522 00:40 3:15 .4:10 4:10 3:30 3:30 4:30 4:35 115 6:30 6:45 Reglon 21 . 23661 9102 7123 2794 . 20.163 00:40 3:15 410 4:10 3:30 3:30 4:30 4:35 1:15 6:30 6:45

.: ~~~ ~ ~ ~ ~ ~ ~ ~

.Milo..s.:.,., Wti Tin '...  ;*...

.le.Ln 7 ....17908 6..

88-9 .... 860o-5 3375 16390 00:40 3:15 4:10 4:10 3:30 3:30 *4:35 5:05 1:15 6:30 6:45 3:15 4:10 3:30 3:30 4:35 :5:30 1:15 7:05 ;7:20 Reg*on 8 30021 .14096

§-L5 5528 28332* 00:40 to

_Lgn. 9 ..48 714 18738 15.443 6056 28332 00:40 3:15 4:10 4:10 __ 3:30 4:35 5:45 I:15

• 7:05 7:20 3:3.0 7:05 42329 . 16282 3524 28332 00:40 3:15 4:10 4:10 3:30. 4:35 5:45 1:15 7:20 L.J Bn!qn I2 8986 3:30 I-i RegIon 19 50283 19342 29524 00:40 3:15 4:10 4:10 3:30 3:30 4:35 5:55 1:15 7:05 7:20 Region 12o 54997 21155 10071 3950 29524 00:40 3:15 4:10 4:10 3:30 3:30 5:00 6:30 1:15 7:05 7:20

-69765 4:10 4:10 3:30 3:30 5:05 6:35 1:15 7:05 7:20 00:40 3:15 R!egiLon 1?

Region 16 63354 5 1072 26835 24369 19645 13079 11732 10115 5129 4601i 3967 37415 37415 33620 00:40 00:40 I3:15 3:15 4:10 4:0

- 4:10 410 3:30 3:30

.3:30 3:30 1 5:05 5:00 1 6:30 6:20 1:15 1:15 .

7:05 7:05 7:20 7:20 51097 19655 112t6 4399 33202 00:40 I 3:15 4:10 1 4:10 3:30 S3:30 5:00 .6:25 1-115 7:05 7:20.

Region 15 3:15 4:10 3:30 3:30 5:05 1':15 - 7:05 7:20 52954 5674 33202 00:40 3:15 4:10 6:30 14141 33202 00:40 3:15 4:10 4:10 3:30 3:30 4:35 6:00 1:15 7:05 7:20 4L5000 1310 5546 _

4:10 4:10 3:30 3:30 4:35 .4:55 5:50 6:05 Region 19 .21652 8329 8536 3348 21519 00:40 3:15 1:15 Region 20 6884 2649 5528 2169 21519 ,00:40 3:15 1 4:10 4:10 3:30 3:30 4:35 5:00 1:15 5:50 6:05 Region 22 84553 32525 24862 9749 020:40 3:IJ :1+I4:10 3:130- 3:30 7:05 7:20 Rev. 5 m

1 0 U

Table 9-10C: Summary of Results of EvacuationTime Anlysis

-Scenarios 5 and 6 Areas Permanent POD.. Vehs.

" Transient Poo. I Vehs.

Evacuation Canacltv 1 Notify

. Tme Time Relative To Siren Alert Prep.

Permanent VResponse Time Clear Time Adv Transient.

Respo1se Time Clnnr Time

£du Time General Pop.

Evacuation-

- Time Confirm g

&flr Evcuate Time Special PopUlation Evacuation Time 1Is~of~j 4:1 4:10F 3:30 3:3092 4:25 4:25 1:00 6:30 6:45

,~ ~~ ~~ . .* . .

• . ~~

. . ... . Wl:n ............... +.+* ** .- +.

Regon!2 Region 3

+;9Ok;...;*;+I:-_*+

1523 23636 71153 4

4433 4

9092 531 1485 14

!?gjo 208

+

52 5.

88 12843

_;;l 21123 176§90 00:40

.7+;-"

00:40 00:40

. _' I_

-3:15_

315 3:15 !

4:10 4:10 4:10

--*----+3:30 4:10 3:30

-I 330 3:30

'- 4:25 4:25 4:25 425 i.t

-I'--;+-_+;'I';' 1:15 630 6:30) .

,645 6:45

_4:10 4:tO 3:30 3:30 4:25 4I25 -1:15 6:30 _6:45-Ftegion 710 69 3 151 594 22895 00:40 3:15 4:10 4:10 3:30. 3:30 4:25 4:25 __1:15 6:30 .6:45 Region Re" Ion 216 5027 23661 9102 1934 562 17511 680 220 20163 9522 00:40 00:40 3 3:15 4:10 4:10 3:30

_.3:30 3:30 :2 -_

. 4:25 425 4:25 , :15

.1:15 . :30 6:30 6:5 6:45

....;..._.:._,W _ _,, __thin ... i Ton Miles:________

u. .. ,.: 6.. 1 ______, .

R-e9!.°..

Region

?

7 17908 6889 .2122 _ 832 . 16390 00:40 . 3:15 _ 4....4:10-. 4:107 3:30_ .3:30 4:25 4:35 6:30 6:45 Region 8 30021 11548 3474 1362 28332 00:40. 3:15 4:10 4:10 3:30 3:30 '1:15 4:30 5:20 7:05 _, 7:20

.Reg!qn P. 48714 1.8738 3803 1491 283.32 .00:40 3:15 4:10 3:30 3:30 _4:45 5:45 1:15 7:05 .__

42329J 4:10 I.3:30 I., I Reg!n. 10 16282 2212 867 28i32 00:40 .3:15 . 4:10 3:30 4:45 5§:45- 7:05__ 7:20 I) Region 11

• 19342 2212 667 29524 00:40 3:15 4:10 4:10 3:30 7:05 50283 3:30 4:45 5:50 1:15 7:20 Region 12 54997 21155 ?614 1025 29524 00:40 3:15 4:10 4:10 3:30 .3:30 5:15 6:20 1:15 7:20

.Regpo 13 697651 00:40 4:10 3:30 7:05 26835 2950 -3:15.- 3:30 6:20o 7:05 7:20

• 33541 6 4:10 4:10

_Region 1.5 24369 2621 10.27 374 15 .00:40 3:15 4:10 3-30 5:05 6:20 1:15 7:05 7:20 3:30

.Reg!_o9 I 51072 19645 2223 00:40 3:15 4:10 3:30-- 4:50_ 6:10 1:15 7:05 7:20 Reg!on 16 51097 2494 977 33202 00:40 3:15 _4:10-__

4:10

- 3:30 3:30 4:50 6:10 1:15 7:20 33202 4:10 3:30 7:05 52954 20370 1175 00:40 3:15 4:10 .3:30 3:30 4:50 6:15 7:20.

Reg!pn 18 2919 33202 7:05 45000 173 10 1143 00:40* 3:15 _ 4:10 4:10 3:30 4:45 5:50 1:15 7:0_5 _

3:30 21852 1403 549 .21519 00:40. 3:15 4:10. 4:30 4:35 1:15 .. 5.-50 _ .6:05 4:10 3:30 Reg!oqn 20 68841 32649 1067 418 2 1519 00:40 3:15 4:10 3:30 *3:30 4:30 4:35 1:15 5:50 _ 6:65 845531 32525 5557 2178 3:15 4:10 4:10 .- 3:309 5:15 6+:20 7:05 7:20 Reg!on 22 39042 00:40 1:15 Rev. 5 (0

(Dl Ln

Table 9-10G: Summary of Results of Evacuation Time Anhriysis Scenarios 5 and 7 Relative To Siren Alert -- From DIrectIv4 To Evacuate Permanent Transient General Pop. Special Population reine Response _ Evacuation Evacuation Permanent To Siren Alert Relative Transient Evacuation Notify Prep. Time Time Time Time Time Time Confirm Time Time I

52

.... * -r-1

.o-141

,+/-,,

6921, 00:40 1 3:15 ]

J *,

4:10 I MUv.

5:30 Clear 3:300 Aov. Clear 4:25 1 Adv.

50 L 4 Time 1 :00 1 Clear 6:30 1 Adv.

645 Reglon 2 11523 4433

_________~~

531

~~~~~

208 12843 00:40 3:15

..~-

4:10 "

Ulf~-

5:30 3:30 . 5:30 4:25 55 550 -

l~u 1:15 1 63 6:30 6:45 23636 9092 1485 582 21123 00:40 3:15 4:10 5:30 3:30 5:30 4:25 5:50 _ 1:15 6:30 6:45 Reg 4 7115 6583 1245 488 17690 00:40 3:15 4:10 5:30 3:30 .5:30 4:25 5:50 1:15 6:30 6:45 Rein 17140 6593 1516 594 22895 00:40 3:15 4:10 &530. 3:30 . 5:30 4:25 5150 1:15 6:30 6:45

. 562 220 . 9522 00:40 3:15 _ 4:10

. 5:30 3:30 _

_5:30 4: _25_ . 50 1 15 . 6 30 . 6 45 Reg ... 5027 1934 Rego .21

_23661 .. 9102 1756 688 20163 0:40 3:15 . 4:10 5:30 _ 3:30 5:30 4:25. 60O_ . 1:. S 6:30 6:45 I17908 6889 2122 832 16390 00:40 3:15 4:10 5:30 3:30 5:30 4:25 5:50 6:30 6:45 11548 '3474 T705 Regionl8 30021 1362 28332 00:40 3:15 1....... 4:10 5:30 3:30 5:30 4:30 7:20

-6:00 1:15 4871.1 18738 3803 1491 4:10 I. 28332 00:40 3:15 5:30 3:30 5:30 4:45 6:20 7:05 7:20 42329 16282 2212 28332 00:40 3:15 4:10- 1:15 f!!!g!-i 10. 867 5:30 3:30 5:30 4:45 6:20 1:15 7:05 7:20 50283 19342 2212 867 29524 00:40 3:15 4:10 5:30 3:30 5:30 4:45 6:20 1:15 7:05 7:20 Re Ion 12 2614 1025 54997 *21155 29524 00:40 3:15 4:10 5:30 3:30 5:30 5:15 6:50 _ 7:05 7:20 Region! 1? 69765 26835 M950 00:40 3:15 4:10 3:30 5:30 5:15 6:50 .11:15 1156 37415 5:30 7:05 7:20 Region! 15 63354 (0:40 3:15 4:10 24369 2621 1027 -3*I SO 3:30 51-1 5:05 6:50 1:15 7:05 7:20

, 00:40 Reglon 14 51072 19645 2223 871 332021 00:40 1 3:15 4:10 5:30 3:30 5:30 4:50 6:50 1 1:15 7:05 7:20 51097 33202 00:40 3:15 4:10 5:30 3:30 5:30 4:50 6:50 - 1:15 7:05 _ 7:20 Region I8 52954 20370 2999 1175 33202 00:40 3:15 4:10 5:30 3:30 5:30 .4:50 6:50 1:15 7:05 7:20 Region 17 45000 17310 2919 1143 33202 00:40 3:15 4:10 -5:30, 3:30. 5:30 4:45-- 6:20 -1:15 7:05 7:20 Region 20 21652 8329! 1403 549 21519 00:40 3:15 4:10 5:30 3:30 5:30 4:30 6:05 .1:15 5:50 6:05 Region 22 6884 2649 1067 21519 I-00:40 3:15 4:10 5:30 3:30 5:30._ 4:30 6:05 *1!I1 5:50 6:05 2178 4:10 5:30 84553 32525 5557 39042 nn-4n l; 3-15 3*30 .5:30 5:15 6:50 .1ý:15 7:05 7:20

, 00:40 1. 3:15 Rev. 5 U1

• U Table 9-1OE: Summary of Results of Evacuation Time A alysis

. ,Scenarios8 and 9 IRelative To Siren Alert From Dlrecti aTo Evacuate IPermanent Transient General Pop. Special Popuilaion IR o .- *Response _o "_esponse Evacuation Evacuation

• Permanent Transient Evacuation Notify Prep. Time Time Time lime Time Time Confirm Time Time j

Areas 1 Pop.Y-ehs. Po. Vehs. capac!itL -Time I Time Clear I Ad. clear Adv. Clear Adv.- Time Clear Adv.

"** 9.1.

.- **114. 211 00:40 1 3:S

+315_ 3:30 3:.3:30.1 3:30 1.50 3:30-. 3:63-64 " 100 I 630"645 R.egon 2 11523 .208 4433 531 1243 00:40 3:15 3:30 3:30 3:30 3:30

.3:50 3:50 1:15 6:30 6:45 Reg!!n Region S Region 6 Region21 ?I

? 3636 17140 5027 236§12 9092

• . ._*.3..6.6,I*9_o-2 171 -e~o 653

§P§ 6593 1934

_1516 1485 14 562 5

582 488 594 220 88

_21123 17690 22895 9522 20 00:40 00:40

• 00:40 00:40 3 63 00:40 3:15 315 3:15 3:15 315ý.

. 3:30 Wit1...n lieL 3:30 3:0 3:30_

3:30

~.--3:3 3:30 3:30 Mi.iw_.,'

3:30 33 3:30 3:0 33 3:30

-:5:0.

3:3

_3:30

0

.. [

i5

0 3:30 33 3:30 3:30

0 1:50

.~. .h 35 3:50

0 3:50 3:50

0 3:50 35 3:50 3:50 11

. ___________l_

1:15

-t.11 1:15

0 6:30 63 6:3:0 6:30 64 64 6:45 6:45 64 6:45

• .. . . .. W~ithin Ton Miles . ... . ,~~ ~ .~ ~ .4Ah4~P.4

,!9l*o, 17908 68899 2122 832 16390 00:40 3:15 3:30 3:30 3:30 :30 3:50 3:55 ;1:15 6:30 6:45 Reg.on 89 Reg 30021 48714 *0 18738 3474 7577 136_

2971 28332 28332 00:40 00:40 3:15 315 3:30 3:30 3:30 3-- 3:30 3 3:30 30 ""5:15 4:15 45 5015 1:15 7:05 77: 7:20 RegIon 10 423219 16282 5986 2347 28332 00:40 3:15 3:30 3:30 3:30 3:30 4:20 5:30 1:15 7:05 7:20 U Reg2on 11 50283 19342. 5986 2347 29524 00:40 3:15 3:30 3:30" 3:30 330 4:20 530 115 705 7:20 lq!2115 Reg 508 94 638 250547 29524 00:40 3:15 3:30 3:30 330

-330 4:25 3 1 -05 7:20 Reg!qn 13 69765 26835 6724 2636_ 37415. 00:40 3:15 3:30 3:30 3:30 -3:30, 4:25 5:25 11:5 7:05 7:20

!on 14 63354 " 24369 2621 . 1027 37415 00:40 3:15 3:30 3:30 3:30 .3:30 . 4:20 5:15 1:15 7:05 7:20 Region 15 . 51072 . 19645 .2223 871 33202 00:40 3:15 3:30 . 3:30 3:30 - 1 3:30 4:10 . 500 115. 705 7:20 Regon 1 . _1097 19655 2494 977 33202 00:40 3:15 3:30 3:30 3:30 3:30 4:10 _ 510 115 7:05 7:20 Region 17 52954 20370 2999 1175 33202 00:40 3:15 3:30 3:30

• 3:30 3:30 4:10 5:05 1:15 7:05 7:20 Reg!oqn 18 45000 17310 2919 1143 33202 00:40 3:15 3:30 3:30 3:30. 3:30 _ 3:55 4:45 1:15 7:05 7:20 8329 1403 549 21519 00:40 3:15 3:30 3:30 3:30 3:30 3:55 3:55 1:15 5:50 6:05 Reglon 19 21652 Region. 20 , 884_ 2649 1067 418 321519 00:40 3:15 3:30 3:0 _ _3:30 -3030 4:55 35 1150 6:05 84553 32525 9331 3658 3042 00:40 3:15 3:30 30 3:30 30 45 5:30 15 7:05 7:20 Rev. 5 LI

'U U Table 9-1OF: Summary of*Results of Evacuation Time Analysis

-Scenarios 8 and 10 Relative To Siren Alert From Directival, Evacuate Permanent Transient. General Pop. - Special Population Response . Response . - Evacuation Evacuation Permanent ____ Transient - _Evacuation Notify I Prep. Time Time Time Time Time Time Contirm Time Time Areas , eh.

.117 Pop. 1 Vh. Ca act~ Time " T Time mr .Clear Adav Momear Advw trler / Afv* ITflm / CMoar .I Atlv

___________~ ~~~~l. ~~~~~~~~~~ ...

..~

.'~

Re n 1 5002 '19241 29ij 114 6921 00:40 3:5 I3:30 I 5:30 3:30 5:30 3:0 5:45 11:00 6:30 6:45 Region 2 11523 4433 531. 208 12843 00:40 " 3:15 3:30 5:30 3:30. 5:30 3:50 5:45 115 6:30 6:45 e 23636 9092 1485

_ 582 21123 00:40 3:15 3:30 5:30 3:30 5:30 3:50 5:45 1:15 . 6:30 6:45 Reg on 4 17115 6583 1245 488 17690 00:40 3:15 3:30 5:30 3:30 5:30 3:50 5:45 . .1:15 6:30 6:45 Regon 17140 65934 1516 594 ,.622,895 00:40 3:15 3:30 5:30 3:30 5:30 3:50 5:45 __j:15 6:30 6:45 Region 5027 1934 562 220 95225 00:40 3:15 3:30 5:30 3:30 5:30 3:50 5:45 1:15 - 6:30 . 6:45 Region 21 23661 9102 , 1756. 688 20163 00:40 3:15 3:30 :30 .5:30 3:50 5:45 11:15 6:30 6:45

, ,,hin.. -r-.. . Wl mhT.:  :." , . , '.r ... '.-. ... " ... ....

.. 7908 6889 .... _212+2 8

32 16390 00

40 3:15 3:30 §:310 3:30 5:30 3:50 1:15. 6:30 6:45 Region 5:50 30021 11548 3474 1362 28332 00:40 3:15 3:30 5:30 3:30 5:30 4:15 5:50 1:15 7:05 RegIon a 75 7 00:40 3:15 3:30 5:30 3:30 5:30 4:15 6:15 :115 7:20 48714 18738 2971 28332 7:05 7:20 16282 2347 28332 00:40 3:15 3:30 5:30 3:30 5:30 4:20 6:15 1:15 42329 5986 7:05 7:20 Regio!1 2347 29524 00:40 3:15 3:30 5:30 3:30 5:30 4:20 6:15 1:15 50283 19342 7:05 7:20 Region 13 54997 21155 63988 29524 00:40 3:15 3:30 5:30 3:30 5:30 4:25 6:15 1:15 7:05 7:20 2505 3:30

.6724 . 2636 37415 , 00:40 3:15 5:30 3:30 5:30 4:25 6:10 1:15 Re-Ion 12 69765 26835 63354 24369 2621 1027 37415 00:40 1 3:15 1 3:30 5:30 1 3:30 5:30 4:20 5:50 :1:15 7:05 7:20 Re-gion 13 2223 871 33202 , 00:40 I3:15 3:30 5:30 13:30 1:"05:30 4:10 5:50 1:15; 7:05 7:20 Region 16 51072 19645 Region 17 51097 19655 2494 977 33202 00:40 [ 3:15 1 3:30 ._5:0 3:30 1 5:30 4:10 5:50 . 1 i115 . 7:05 7:20

'33202 00:40 1 3:15 1 3:30 ._5:30 1 3:30 5:30 4:10 5:50 .1:15 7:05 7:20 Re Ion 16 52954 20370 2999 1175 45000 17310 3m3 5:30 3:55 5:50 1:15 7:05 7:20 Region 19- 21652 8329 2919 1403

_1143 5A9 21519 21519 00:40 00:40 3:15 3:15 3:30 3:30 5:30 5:30

[ 3:30 3:30 5:30 3:55 5:50 .1:15 5:50 6:05 Region 20 6884 2649 1067 418 5:30 3:55 5:50 1:15 5:50 6:05 FReolon 2 84553 32525 9331 3658 10fld9 39042, 00:40 3:15 3:30 5:30 2330

'413n 5:30 4:25 6:15 1:15 7:05 7:20 Rev. 5 (D

t-

EXHIBIT 3 KLI~i~ASS INNOVATION IN TRANSPORTATION CIA TES INC.

PilgrimNuclearPowerStation DeveloDment of Evacuation Time Estimates preparedfor.

Entergy Nuclear Northeast Emergency Preparedness Division Rocky Hill Rd, RFD #1 Plymouth, MA 02360 by.

KLD Associates, Inc.

47 Mall Drive, Suite 8 Commack, NY 11725 mailto:rgoldblatta~kldassociates.com December, 2004 KLD TR-382 4

6. A total of 12 "Scenarios" representing different seasons, time of day, day of week and weather are considered. These Scenarios are tabulated below:

Scenarios Season Day of Week Time of Day Weather 1 Summer Weekend Midday Good 1A Summer Weekend Evening Good 2 Summer Weekend Midday Rain 2A Summer Weekend Evening Rain 3 Summer Midweek Midday Good 4 Summer Midweek Midday Rain 5 Off-Season Midweek Midday. Good 6 Off-Season Midweek Midday Rain 7 Off-Season Midweek Midday Snow 8 Off-Season Midweek Weekend Evening, All day Good 9 Off-Season Midweek, 9 Off-Season Weekend Evening, All day. Rain 10 Off-Season Midweek, Weekend Evening, All day Snow

7. The models of the IDYNEV System represent the state of the art, and have been recognized as such by Atomic Safety Licensing Boards (ASLB) in past hearings.

(Sources: Atomic Safety & Licensing Board Hearings on Seabrook and Shoreham; Urbanik 2).

2.3 Study Assumptions

1. The Planning Basis Assumption for the calculation of ETE is a rapidly escalating accident that requires evacuation, and includes the following:

a. A Site Area Emergency is assumed to precede the General Emergency by 25 minutes. Bus mobilization and precautionary beach closures occur at this time.

b. Advisory to Evacuate is announced coincident with the siren notification for a General Emergency.

b. Mobilization of the general population will commence after siren notification of a General Emergency. Note that some mobilization activities occur before a General Emergency is announced.

c. ETE are measured relative to Advisory to Evacuate.

2 Urbanik, T., et. al. Benchmark Study of the I-DYNEV Evacuation Time Estimate Computer Code, NUREG/CR-4873, Nuclear Regulatory Commission, June, 1988 Pilgrim 2-3 KLD Associates, Inc.

Evacuation Time Estimate Rev. 6

household, members would be able to evacuate sooner than if such trip preparation were deferred until all household members had returned home. For this study, we. adopt the conservative posture that all activities will occur in sequence.

It. is seen from Figure 5-1, that the Trip Generation time (i.e. the total elapsed time from Event 1I to Event 5) depends on the scenario and will vary from one household to the next. Furthermore, Event 5 depends, in a complicated way, on the time distributions of all activities preceding that event. That is, to estimate the time distribution of Event 5, we must obtain estimates of the time distributions of all preceding events.

Estimated Time Distributions of Activities Preceding Event 5 The time distribution of an event is obtained by "summing" the time distributions of all prior contributing activities. (This "summing" process is quite different than an algebraic sum since we are operating on distributions - not scalar numbers).

Time Distribution No. 1, Notification Process: Activity 1 -- 2 It is reasonable to expect that 90 percent of those within the EPZ will be aware of the accident within 15 minutes with the remainder notified within the following 15 minutes. The commuters outside the EPZ will be notified somewhat later, say uniformly between 10 and 40 minutes, while those at recreational facilities will be notified within 15 minutes. The primary means of notifying boaters off shore is through EBS and Coast Guard broadcasts. However, mariners who do not have radios, or whose radios are not tuned to EBS or emergency frequencies will take longer to notify. It is assumed that 50 percent of boaters are notified by 40 minutes, with the balance notified 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the Site Area Emergency has been declared. The resulting distributions for this notification activity are given below:

Persons off the Beach: Distribution IA Elapsed Time Percent of Population (Minuxtes)Y ---Notified 0 0 5 15 10 46 15 79 20 85

.25 90 30 95 35 98 40 100 KED Associates, Inc.

Pilgrim T 5-4 KLD Associates, Inc.

Evacuation Time Estimate Rev. 6

Persons on the Beach: Distribution 1B Elapsed Time Percent of Population (Minutes) Notified 0 0 5 20 10 60 15 100 Persons on Boats: Distribution 1C Elapsed Time Percent of Population (Minutes) Notified 0 0 5 5 10 10 15 15 20 20 25 25 30 30 35 40 40 50 45 60 50 75 55 90 60 100 Pilgrim 5-5 KLD Associates, Inc.

Evacuation Time Estimate Rev. 6

Distribution 4D: Boaters Prepare to Evacuate Distribution 4D describes the time required to load a boat trailer once a boat is at the launch ramp.

The data for this distribution was obtained from interviews with boaters.

Elapsed Time Cumulative Percent Ready (Minutes) to Evacuate 0 n 15 73 10 07l 15 i*n 07 97

3. 097 40 97 45 A7 s1" Ioni Snow Clearance Time Distribution Inclement weather scenarios involving snowfall must address the time lags associated with snow clearance. Discussions with local officials indicate that snow plow equipment is mobilized and deployed during the snowfall to maintain passable roads. The general consensus is that their efforts are generally successful for all but the most extreme blizzards when the rate of snow

..accumulation exceeds that of snow clearance over a period of many hours.

Consequently, it is reasonable to assume that the highway system will remain passable -- albeit at a lower capacity -- under the vast majority of snow conditions. Nevertheless, for the vehicles to gain access to the highway system, it may be necessary for driveways and employee parking lots to be cleared to the extent needed to permit vehicles to gain access to the roadways.

These clearance activities take time, which must be incorporated into the trip generation time distributions. These data are provided directly by the telephone survey. This distribution is plotted in Figure 5-2 and listed below.

Pilgrim 5-12 KLD Associates, Inc.

Evacuation Time Estimate Rev. 6

Distribution No. 5, Time to Clear Driveway of Snow Elapsed Time Cumulative Percent (Min) Driveways Cleared 00 in 17 15 28 20 37 95 45

____30____50

.45 1.53 40 5I 45 5A 55 66 6fl 70 65 73 7n 76 75 79 An RI 9n R5 861 3

go 84 95 85 100 RR 105 66

.110 A7 115 66 120 66 1)5 R9 130 90 115 91 141 91 145 91 150 92 155 92 1IO 92 170 9 175 93 160 9

!65 95 ign 97 195 inn Pilgrim 5-13 KLD Associates, Inc.

Evacuation Time Estimate Rev. 6

Table 7-4D, Estimates Time (Hrs:Min) to Evacuate 100 Percent of the Indicated Region After The Evacuation Advisory Summer Off-Season Weekend Midweek Midweek Midweek, Evening Evac. Evac.

Regions Midday Evenin Midday Evening Midday Regions Midday Weekend, All Day Good Good Good Good Weather Rain Weather Rain Rain snow Rain Snow Weather Weather Entire Two Mile, Entire Five Mile, and Entire EPZ Regions RO1 3:30 3:30 3:30 3:30 4:05 4:05 [ R01 *4:10 4:20.] 5:25 3:35 3:35 5:20 R21 4:05 1 4:00 4:35 4:30 4:20 4:35 R21 4:15 4:30 1 5:30 3:50 4:05 1 5:30 R22 5:35 5:30 6:20 6:10 5:40 6:30 R22 5:05. 5:55 1 6:45 4:30A 5:00 5:50 Two Mile Ring and Evacuation to Five Miles R02 4:05 4:00 4:35 4:30 4:20 4:35 R02 4:10 4:30 5:25 3:35 4:05 5:15 R03 4:05 4:00 4:35 4:30 4:20 4:35 R03 4:15 4:30 5:30 3:35 " 4:05 5:20 R04 3:35 3:30 4:00 3:40' 4:15 . 4:15 R04 4:15 *4:15 5:25 3:30 3:30- 5:20 R05 3:35 3:35 4:00 3:40 4:15 4:15. R05 4:15 4:25 5:30 3:40 3:40 5:25 ROB 3:35 3:35 3:35 3:35 4:10 4:110 R06 4:15 4:25 5:30 3:40 3:40 5:25 Two Mile Ring and Evacuation to EPZ Boundary R07 5:25 5:05 6:15 5:55 5:40 6:30 R07 5:05 5:55 6:35 4:30 5:00 5:35 ROB 5:15 5:00 6:05 5:40 5:40 6:30 ROB 5:05 5:55 6:30. 4:30 5:00 5:35 R09 5:20 5:05 6:05 5:55 5:40 6:30 R09 5:05 5:55 6:45 4:30 5:00 5:50 R10 5:15 *5:00 5:55 5:50 5:30 6:05 R10 5:05 5:50. 6:45 4:30 5:00 5:50 Rl1 5:15 5:05 6:00 5:50 5:30 6:10 R1 5:05 5:50 6:45. 4:30 5:00 5:50 R12 5:30 5:30 6:20 6:05. 5:30 6:05 R12 5:00 5:40 6:45 4:25 4:55 5:50 R13 5:35 5:30 6:20 6:10 5:30 6:15 R13 5:00 5:40 6:45 4:25 4:55 5:50 R14 5:05 5:00 5:55 5:30 5:15 6:00 . R14 4:50 5:25. 6:20 4:05 4:35 5:30 R15 5:05 4:55 5:35 5:30 5:05 5:55 R15 4:35 5:20 6:00 4:05 4:35 5:30 R16 5:05 4:55 5:35 5:30 5:05 5:55 P16 4:35 5:20 . 6:00 .4:05 4:35 5:30 R17 5:25 5:20 6:00 5:55 5:05 6:00 R17 4:35 5:25 6:00 4:05 4:35 5:30 RIB 5:25. 5:20 5:55 5:55 5:00 5:30 R R 4:30 5:00 " 5:35 4:00 4:25 5:30 R19 5:30 5:25 6:00 6:00 4:40 5:15 R19 4:20 4:30 5:35 3:45 3:50 5:30 20 *3:40. 33:40 :40. 3:40 4:15 4:15 R20 4:20 4:30 5:35 3:45 3:45 5:30 Pilgrim 7-12 KLD Associates, Inc.

Evacuation Time Estimates Rev. 6

Table 7-ID (Concluded).

Estimates Time (Hrs:Min) to Evacuate 100 Percent of the Indicated Region After The Evacuation Advisory Summer Off-Season Evac. Weekend Midweek

___________-Evac. -________________ Midweek Midweek, Evening Regions Midday I Evenin Midday Evening Midday Regions Midday Weekend, All Day r Good Good Good Good Weathe Rain Weather RainWahrWahrWeather Weather Rain Snow Ran Rain So Snow Five Mile Ring and Evacuation to EPZ Boundary R23 5:25 5:05 6:15 5:55 5:40 6:30 R23 5:05 5:55 6:35 4:30 5:00 5:35 R24 5:15 5:00 6:05 5:40 5:40 6:30 R24 5:05 5:55 6:30 4:30 5:00 5:35 R25 5:20 5:05 6:05 5:55 5:40 6:30 R25 5:05 5:55 6:45 4:30 5:00 5:50 R26 5:15 5:00 5:55 5:50 5:30 6:05 R26 5:05 5:50 6:45 4:30 5:00 5:50 R27 5:15 5:05 6:00 5:50 5:30 6:10:. R27 5:05 5:50 6:45 4:30 5:00 5:50 R28 5:30 5:30 6:20 6:05 5:30 6:05 R26 5:00 5:40 6:45 4:25 -4:55 5:50 R29 5:35 5:30 6:20 6:10 5:30 6:1.5 R29 5:00 5:40 6:45 4:25 4:55 5:50 R30 5:05 5:00 5:55 5:30 5:15 6:00 R30 4:50 5:25 6:20 4:05 4:35 5:30 R31 5:05 4:55 5:35 5:30 5:05 5:55 R31 4:35 5:20 6:00 4:05 4:35 5:30 R32 5:25 5:20 6:00 5:55 5:05 6:00 R32 4:35 5:25 6:00 4:05 4:35 5:30 R33 5:25 5:20 5:55 5:55 5:00 5:30 R33 4:30 .5:00 5:35 4:00 4:25 5:30 R34 5:30 5:25 6:00 6:00 4:40 5:15 P34 4:20 . 4:30 5:35 3:45 3:50 5:30 R35 3:40 3:40. 3:40 3:40 4:15 1 4:15 1 R35 4:20 4:30 5:35 3:45 3:45. 5:30 Pilgrim 7-13 KLD Associates, Inc.

Evacuation Time Estimates Rev. 6

EXHIBIT 4 PNPS EMERGENCY PLAN RType H8.22 FOREWORD As required in the conditions set forth by the Nuclear Regulatory Commission for the operating license for the. Pilgrim Nuclear Power Station, the management of Entergy Nuclear Operations, Inc., ("Entergy") recognizes its responsibility and authority to operate and maintain the Pilgrim Nuclear Power Station in such a manner as to provide for the safety of the general public.

This .Emergency Plan has been prepared to establish- the procedures. and. practices for*

management control over unplanned or emergency events that may occur at the Pilgrim Nuclear Power Station.

The issuance and control of this Emergency Plan and the Activities associated with emergency preparedness at the Pilgrim Nuclear Power Station. shall be the responsibility of the Senior Nuclear Executive. The Emergency Plan ahd its implementing procedures meet the requirements for quality assurance as set forth.in the Entergy Quality Assurance Program Manual.

The Nuclear Assessment Director is assigned the responsibility for the maintenance of the Emergency Preparedness Programs. associated with the operation of Pilgrim Nuclear Power Station as outlined in this document.

Date: 5 11 I&P OSRC hairman j Date: / 2"- cq16l Nuclear sss e Dctor Date:

General Manager, Plant Operations

___ ___ ___ ___ ___Date: 5,1167 C Site Vice President (Senior Nucle6 xecutive)

Conformance to the practices described in this Emergency Plan and the procedures, which implement it, are required as of the effective date.

Effective Date: 2oo i Revision 32

PNPS EMERGENCY PLAN Section J: Protective Response Protective response consists of emergency actions, taken during or after an emergency situation, which are intended to minimize or eliminate hazards to the health and safety of the public and/or Station personnel. A range of protective actions has been developed for emergency workers and the general public in the plume exposure pathway Emergency Planning Zone (EPZ). Additionally, guidelines have been established to aid in choosing protective actions during an emergency that are consistent with federal guidance. PNPS is responsible for onsite actions, while the responsibility for offsite actions rests with the Co6Mrh--jalth of Mas'sachijsetts, local authorities and other offsite response agencies.

1. Notification of Onsite Personnel: For all emergency classifications, all personnel within the Protected Area are notified of the declaration, escalation or termination of an emergency by alarms and verbal announcements over the Station Public Address System (Gai-tronics).

Announcements include the emergency classification and response actions to be taken by site personnel.

Upon declaration of an Alert or higher classification, if open, public access areas are closed and persons advised, by dispatching a security officer(s) to evacuate those areas.

2. Evacuation Locations: If Protected Area evacuation is required, personnel are directed to evacuate to an assembly area. The Support Building cafeteria is designated as the primary assembly area. Should conditions warrant, personnel may be directed to evacuate via personal automobiles to the alternate assembly area, the Chiltonville Training Center. The assembly area is chosen on the basis of wind direction. Visitors to the station assemble with their escorts.

3. Radio ogical Monitoring: In the event of Protected Area evacuation, radiation protection personnel are dispatched to the designated assembly area, to provide radiological monitoring and, if necessary, decontamination of evacuees.

4. Evacuation: Evacuation is the primary protective action anticipated for onsite personnel not having emergency response assignments. Contractors who do not have emergency.

responsibilities, visitors, and handicapped personnel are evacuated immediately at the Alert or higher classification.

Evacuation of non-essential PNPS personnel is initiated upon declaration of either a Site Area Emergency or General Emergency. The shorefront recreation area is closed at the declaration of an Alert or higher classification, and visitors asked to leave.

5. Accountability: At the declaration of Site Area Emergency, all non-essential personnel are evacuated. All individuals onsite are accounted for and the names of missing individuals are ascertained within 30 minutes of the initiation of accountability. Once established, accountability within the Protected Area is maintained throughout the course of the event.

Should missing personnel be identified, search and rescue operations are initiated.

Accountability is coordinated by the Emergency Security Supervisor and the results forwarded to the Emergency Plant Manager.

J-1 Revision 32

PNPS EMERGENCY PLAN In event of a short duration emergency radioactive release (i.e., <1 hour for the entire event), then sheltering instead of evacuation for the affected, land-based EPZ sub-areas will be recommended.

In addition to the plant-condition PARs,*off-site dose projections will be used to determine whether plant-condition PARs are adequate. This will include evaluating the off-site dose projection results in accordance with the threshold for dose-based evacuation PARs. Table J-1 summarizes the PNPS PARs for the general public based on projected dose to the p...1opUla~tion-at- risk.. .... . . .

In all of the above cases, a reminder is provided that state and local authorities should consider the administration of potassium iodide (KI) for the general public in accordance with their plans and procedures.

8. Evacuation Time Estimates: An independent evacuation time study has been performed to provide estimates, by subarea, of the time required to evacuate resident and transient populations surrounding Pilgrim Station under favorable and adverse conditions (see Appendix 5). These evacuation time estimates are used to determine an exposure period for the calculation of dose projections.

9. Protective Measure Implementation: The responsibility for implementing protective measures based on protective action guides rests with Commonwealth and local agencies.

10. Factors Affecting Protective Measure Implementation The PNPS, Commonwealth, and local- emergency plans used to implement the protective measures for the plume exposure pathway take numerous factors into consideration. Among these considerations are:

a. Most of the evacuating population will travel in their own vehicles, leaving the EPZ via designated evacuation routes. Figures J-1 through J-5 are maps showing the evacuation routes, evacuation subareas, reception centers in host areas, and mass care shelters'. Pre-selected sampling and monitoring points are presented in Table J-2.

b. The population distribution around Pilgrim Nuclear Power Station is presented in the Evacuation Time Estimate, Appendix 5.

_c. As indicated in Section E,.offsite agencies are notified in the event the Emergency Plan is activated. Commonwealth and local agencies have the capability to notify all members of the transient and resident population within the plume exposure EPZ.

d. Means for protecting those persons whose mobility may be impaired due to such factors as institutional or other confinement are described in Commonwealth and local plans and procedures.

e. Provisions for the use of radioprotective drugs, particularly for emergency workers and institutionalized persons within the plume exposure EPZ whose immediate evacuation may be infeasible or very difficult, including quantities, storage, and means of distribution are described in Commonwealth and local plans and procedures.

f. Commonwealth and local plans include the method by which decisions are made by the Massachusetts Department of Public Health for administering radioprotective drugs to emergency workers and the general public.

J-3 Revision 32

EXHIBIT 5 COMMONWEALTH OF MASSACHUSETTS RADIOLOGICAL EMERGENCY RESPONSE PLAN Reviewed by:. D\ate 1os Date P1lnner/

k, X. **ciNicolaý,

Approved by:

Date I IEANuclear, M* Preparedness Department aNursso, Managers/ Dprmn I

MARERP . i Rev. 24 December 2005

p 8.3.1.5Massachusetts Department of Environmental Management, Division of Forest and Parks The Massachusetts Department of Environmental Management, Division of Forest and Parks is responsible for the following roles for implementing shelter-in-place:

Assisting in notification of the public in State parks and other recreational' facilities to leave, if these areas have not already been cleared as a precautionary action.

8.3.1.6 Massachusetts Department of Fish and Game S. The Massachusetts Department of Fish and Game (DFG) is responsible for the following roles for implementing shelter-in-place:

At the request of MEMA, notify the public on the upper reaches of the Connecticut River to leave, if this area has not already been cleared as a precautionary action (Vermont Yankee EPZ only).

8.3.1.7 Massachusetts National Guard

_-The Massachusetts National Guard is responsible. ,for. the following roles for implementing shelter-in-place:

• Provide personnel and equipment, as requested and as resources permit, to assist in access and traffic control and transportation support.

8.4 EVACUATION The protective action entails the implementation of actions and procedures for actual movement of the public out of the affected area. Evacuation, like sheltering, will be implemented on a MARERP 8-9 Rev.14 December 2005

community-by-community or sub-area basis as appropriate. MEMA Regional plans show maps of communities and, where applicable, sub-areas within the 10-mile EPZs.

Local communities and the State have designated evacuation routes to be used in each of the plume EPZs. Various documents, including the local or MEMA Regional plans and/or Exhibits 2, 3, or 4, contain evacuation time estimates and maps with evacuation routes, population distribution and traffic capacities of routes. The evacuation of populations in hospitals, nursing homes, schools, correctional and other institutions is addressed in each local plan and/or in separate plans for the specific facility. The primary means of transportation for evacuation will be privately owned vehicles. Residents of most dwellings within the plume exposure EPZs have access to private vehicles. Additionally, buses will be available through local emergency response organizations to evacuate those who do not have access to a privately-owned vehicle.

Details concerning predetermined routes and bus stops are detailed in local plans and in news releases.

Local emergency response organizations have responsibility for providing supplementary transportation resources. Each community has plans for evacuating residents, including the handicapped; the institutionalized, and those who have special transportation needs (see local plans). Confidential surveys will be conducted in each EPZ to identify residents who have

.special notification or evacuation needs. Upon request, the State is prepared to assist communities with the notification and evacuation of special-needs residents and will coordinate provision of wheelchair. vans and ambulances as needed. The State will also assist local organizationsin i--providing for the mobility-impaired at reception centers and shelters.

If an evacuation is initiated during school hours, children will be bused to a host facility or reception center. (see section. 8.2.3). The provision of additional buses, if necessary to complete this task, will be coordinated by the State. Children will remain under the supervision of either school department personnel or the host facility/reception center organization until they -are released to a parent or guardian. See Exhibits 2, 3, and 4 for details.

MARERP 8-10 Rev.14 December 2005

EXHIBIT 6 April 1, 2005 Ms. Mary Elizabeth Lampert 148 Washington Street Duxbury, MA 02332

Dear Ms. Lampert:

Your petition dated January 18, 2005, to the Chairman of the Nuclear Regulatory Commission (NRC), has been referred to the Office of Nuclear Reactor Regulation (NRR) for response, pursuant to the NRC's regulations in Section 2.206 of Title 10 of the Code of Federal Regulations (10 CFR 2.20.6). In your letter, you asked that the Chairman require the Pilgrim Nuclear Power Station (PNPS) "to cease operations until proper notification equipment is installed throughout the Emergency Planning Zone to enable residents and transients to be notified within the required approximate 15 minutes " Your letter stated that the-PNPS public warning system does not provide reasonable assurance that the residents and transients within the emergency planning zone will receive timely warning in the event of an accident resulting in a large release of radiation.

Our petition. review board (PRB) met with you by teleconference on February 9, 2005. A transcript of that teleconference is enclosed. The PRB has reviewed your request and concluded that the issues you raise are not appropriately addressed under the 10 CFR 2.206 process, since no violations of NRC regulations could be substantiated and the information you provided is not sufficient to warrant further inquiry. Based on evaluations by the Federal Emergency Management Agency (FEMA) and the NRC's quarterly evaluations of siren .

reliability, the NRC finds reasonable assurance that the PNPS public notification system has the capability to essentially complete the initial notification of the public within the plume exposure planning zone within about 15 minutes. An enclosure to this letter provides the NRC staff responses to the specific concerns in your petition.

i hope this information is responsive to your concerns about the PNPS emergency notification systems. Thank you for bringing these concerns to.the attention of the NRC.

Sincerely, IRA!

J. E. Dyer, Director Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosures:

As stated cc: See next page

April 1, 2005 Ms. Mary Elizabeth Lampert 148 Washington Street Duxbury, MA 02332

Dear Ms. Lampert:

Your petition dated January 18, 2005, to the Chairman of the Nuclear Regulatory Commission (NRC), has been referred to the Office of Nuclear Reactor Regulation (NRR) for response, pursuant to the NRC's regulations in Section 2.206 of Title 10 of the Code of Federal Regulations (10 CFR 2.206). In your letter, you asked that the Chairman require the Pilgrim Nuclear Power Station (PNPS) "to cease operations until proper notification equipment is installed throughout the Emergency Planning Zone to enable residents and transients to be notified within the required approximate 15 minutes." Your letter stated that the PNPS public warning system does not provide reasonable assurance that the residents and transients within the emergency planning zone will receive timely warning in the event of an accident resulting in a large release of radiation.

Our petition review board (PRB) met with you by teleconference on February 9, 2005. A transcript of that teleconference is enclosed. The PRB has reviewed your request and concluded that the issues you raise are not appropriately addressed under the 10 CFR 2.206 process since no violations of NRC regulations could be substantiated and the information you provided is not sufficient to warrant further inquiry. Based on evaluations by the Federal Emergency Management Agency (FEMA) and the NRC's own quarterly evaluations of siren reliability, the NRC finds reasonable assurance that the PNPS public notification. system has the capability to essentially complete the initial notification of the public within the plume exposure planning zone within about 15 minutes. An enclosure to this letter provides the NRC staff responses to the specific concerns in your petition.

I hope this information is responsive to your concerns about the PNPS emergency notification systems. Thank you for bringing these concerns to the attention of the NRC.

Sincerely, IRA!

J. E. Dyer, Director Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosures:

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Pilgrim Nuclear Power Station cc:

Mr. Michael Kansler" Director, Massachusetts Emergency President Management Agency.

Entergy Nuclear Operations, Inc. Attn: James Muckerheide 440 Hamilton Avenue 400 Worcester Road White Plains, NY 10601 Framingham, MA 01702-5399 Regional Administrator, Region I Mr. William D. Meinert U. S. Nuclear Regulatory Commission Nuclear Engineer 475 Allendale Road Massachusetts Municipal Wholesale King of Prussia, PA 19406-1415 Electric Company P.O. Box 426 Senior Resident Inspector Ludlow, MA 01056-0426' U. S. Nuclear Regulatory Commission.

Pilgrim Nuclear Power Station Mr. Michael A. Balduzzi Post Office Box 867 Site Vice President Plymouth, MA 02360 Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Chairman, Board of Selectmen 600 Rocky. Hill Road 11 Lincoln Street Plymouth, MA 02360-5508 Plymouth, MA 02360 Mr. Stephen J. Bethay Chairman Director, Nuclear Assessment Nuclear Matters Committee Entergy Nuclear Operations, Inc.

Town Hall . Pilgrim Nuclear. Power Station 11 Lincoln Street 600 Rocky Hill Road Plymouth, MA 02360 Plymouth, MA 02360-5508 Chairman, Duxbury Board of Selectmen Mr. Bryan S. Ford Town Hall Manager, Licensing 878 Tremont Street Entergy Nuclear Operations, Inc.

Duxbury, MA 02332 Pilgrim Nuclear Power Station 600 Rocky Hill. Road Office of the Commissioner Plymouth, MA 02360-5508 Massachusetts Department of Environmental Protection One Winter Street Boston, MA 02108 Office of the Attorney General One Ashburton Place 20th Floor Boston, MA 02108 Director, Radiation Control Program Commonwealth of Massachusetts Executive Offices of Health and Human Services 174 Portland Street Boston, MA 02114 Secretary of Public Safety Executive Office of Public Safety One Ashburton Place Boston, MA 02108

Pilgrim Nuclear Power Station cc:

Mr. David F. Tarantino Ms. Stacey Lousteau Nuclear Information Manager Treasury Department Pilgrim. Nuclear Power Station Entergy Services, Inc.

600 Rocky Hill Road 639 Loyola Avenue Plymouth, MA 02360-5508 New Orleans, LA 70113 Mr. Gary J. Taylor Mr. James Sniezek Chief Executive Officer 5486 Nithsdale Drive Entergy Operations Salisbury, MD 21801 1340 Echelon Parkway Jackson, MS 39213 Mr. Kenneth L. Graesser 38832 N. Ashley Drive Mr. John .T. Herron Llake Villa, IL 60046 Sr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc. Mr. Ronald Toole 440 Hamilton. Avenue 1282 Valley of Lakes White Plains, NY 10601 Box R-10 Hazelton, PA 18202 Mr. Oscar Limpias Vice President, Engineering Ms. Deb Katz, Executive Director Entergy Nuclear Operations, Inc. Nuclear Security Coalition 440 Hamilton Avenue c/o Citizens Awareness Network White.Plains, NY 10601 Box 83 Shelburne Falls, MA 01370 Mr. Brian O'Grady Vice President, Operations Support Mr. W. Craig Conklin, Chief Entergy Nuclear Operations, Inc. .Nuclear and Chemical Hazards Branch 440 Hamilton Avenue Department of Homeland Security /

White Plains, NY 10601 Federal Emergency Management Agency 500 C St., SW Mr. John F. McCann Washington, DC 20472 Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc. Ms. Deborah Bell 440 Hamilton Avenue Regional Assistance Committee Chair White'Plains, NY 10601 Federal Emergency Management Agency Region I.

Ms. Charlene D. Faison 99 High St. 6th Floor Manager, Licensing Boston, MA 02110 Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. John M. Fulton Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

NUCLEAR REGULATORY COMMISSION (NRC) STAFF RESPONSE TO LETTER DATED JANUARY 18, 2005 FROM MS. MARY ELIZABETH LAMPERT In your petition filed under Title 10 of the Code of FederalRegulations (10 CFR) Section 2.206, you stated that the emergency warning system at the. Pilgrim Nuclear Power Station (PNPS) does not provide reasonable assurance that the residents within the 10-mile emergency.

planning zone (EPZ) will receive timely warning in the event of an accident. The Nuclear Regulatory Commission (NRC) staff s comments on your petition. are as follows:

1. You stated that the PNPS public warning system cannot pass minimum standards of.

operability under 10 CFR 50, Appendix E, § (D), (E), and other applicable regulations.

Your concern is that the warning sirens. in the EPZ cannot be heard indoors and cannot be heard by citizens traveling in cars in the EPZ.

Response

As discussed in 10 CFR 50.54(q), nuclear power plant licensees shall follow and..

maintain in effect emergency plans which meet the standards in 10 CFR 50.47(b) and the requirements in 10 CFR 50, Appendix E. In accordance with 10 CFR 50.47(b)(5),

the emergency response plan must establish "meansto provide early notification and clear instruction to the populace within the plumeexposure pathway Emergency ". I Planning Zone". (i.e., 10-mile EPZ). In 10 CFR Part 50, Appendix E, details are provided on the content of emergency plans needed to demonstrate compliance with the standards described in 10 CFR 50.47(b). With regard to prompt public.notification,:

Section IV.D.3 of Appendix E provides a design objective of having "the capability to essentially complete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes."; In the Statements of Consideration for the. final emergency planning regulations (45 FR 55402; August 19, 1980) the Commission' recognized that not every individual would necessarily be reached by actual operation of such a system under all conditions of system use, but that the provision of such systems would.significantly improve the capability for taking protective actions in the event of an emergency.

Federal oversight of radiological emergency planning and preparedness associated with commercial nuclear facilities involves both the Federal Emergency Management Agency (FEMA) and the NRC. Consistent with President Carters directive in December 1979 and the longstanding memorandum of understanding between FEMA and the NRC, FEMA takes the lead in reviewing and assessing offsite planning and response-(including public notification) and in assisting State and local governments, while the NRC reviews and assesses the onsite planning and response. Using FEMA's input, the NRC then makes a determination on the overall state of emergency preparedness.

Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors," Revision 4, July 2003, states that the criteria and recommendations in Revision 1 of NUREG-0654/FEMA-REP-1 , "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980, are methods acceptable to the NRC staff for complying with the standards in 10 CFR 50.47. NUREG-0654/FEMA-REP-1 is a joint publication of the NRC and FEMA. NUREG-0654/FEMA-REP-1, Appendix 3, Section C.3, provides the following standards for siren systems:

a) An acceptable criteria at most locations would be a sound level from the siren system of 10 decibels (db) above average daytime ambient background.

b) The maximum sound levels received by any member of the public should be lower than 123 db, the level which may cause discomfort to individuals.

c) The 10 db differential above daytime ambient is meant to provide a distinguishable signal inside of average residential construction under average conditions. Where special individual cases require a higher alerting signal, it should be provided by other means than a generally distributed acoustic signal.

The PNPS Emergency Plan states: "Development of this plan was based on NRC Regulatory Guide 1.101 ... and NUREG-0654/FEMA-REP-1...." The NRC has previously reviewed the PNPS Emergency Plan and FEMA's findings regarding the State and local plans (including the capability for prompt public notification) and concluded that the plans meet all regulatory ýequirements.

The public alerting system for PNPS uses 112 radio-controlled sirens that provide coverage of the 10-mile EPZ around the plant. Each siren is tested at least once a month to prove they are operable. They provide adequate sound levels to meet the design criteria for the emergency alerting system. They can bequickly activated by local officials when needed to alert citizens to listen to an emergency broadcast station for further instructions. The NRC staff has concluded that the siren system at PNPS fulfills the NRC and FEMA requirements for an emergency alerting system. Your petition did not identify any special individual cases that require a higher alerting signal.

The monthly tests are performed as "silent tests", which actuate the sirens at a frequency inaudible to the human ear. The sirens contain performance-monitoring circuitry, which allows an evaluation of each siren's performance during the monthly tests. Full-volume tests of the sirens are conducted annually, and the public is notified prior to the test. The last full-volume test was conducted in November 2004.

2. You stated that Pilgrim's sirens have been unreliable, failing 12 times from January 2000 to January 2004.

Response

The NRC's reactor oversight program has a performance indicator specifically for siren failures during the planned monthly test. This performance indicator is updated each calendar quarter and is publicly available on the NRC's Web site. For the fourth quarter of 2004, the pass rate for siren tests at PNPS was 99 percent. The NRC's reactor oversight program considers a siren test pass rate above 94 percent to be performance that lies in the licensee response band and requires no additional NRC inspection beyond the agency's baseline inspection. A siren amplifier problem was discovered during a maintenance test at PNPS in January 2004. Although the design criteria specified the sirens must remain operable in the temperature range of -22 OF to 149 OF, some siren amplifiers were not actuating at temperatures below about 20 OF. Each siren may have from two to five amplifiers. During a maintenance test in January 2004, with temperatures lower than 20 °F, 85 of the 112 sirens had a malfunction of at least one amplifier. Testing indicated that the amplifiers functioned correctly above 20 OF.

The licensee identified the problem and took corrective action by replacing those amplifier circuit boards which had temperature-sensitive components due to improper manufacturing. As the maintenance test was not the planned monthly test, the failures did not count toward the NRC's performance indicator. The NRC.is satisfied that the performance indicator data for siren testing was collected as required by the NRC and that the sirens at PNPS are now operating reliably. The NRC will continue to monitor their performance through the reactor oversight program.

3. You stated that route notification, whereby police or other public workers alert citizens in areas where sirens failed to actuate by the use of public address systems or bullhorns, may not accomplish the task effectively or in a timely manner.

Response

Your assessment of the deficiencies of the route alerting process assumed failure of most, if not all, of the 112 sirens in the EPZ. The NRC and FEMA consider this to be an unlikely assumption. The PNPS sirens have batteries which permit full-volume

• activation even ifthere is an electrical blackout. A more realistic assumption would be the failure of three or four sirens. FEMA monitors periodic exercises of the route alerting system and FEMA's latest assessments for PNPS indicate the system meets its design objectives.

In summary, based on FEMA's evaluations and the NRC's quarterly evaluations of siren reliability, the NRC finds reasonable assurance that the PNPS public notification system has the capability to essentially complete the initial notification of the public within the plume exposure planning zone within about 15 minutes. If you believe the Federal requirements for sound levels or for the design of emergency alerting systems need to be revised, please submit a petition*for rulemaking to the NRC as described in 10 CFR 2.802, or to FEMA as described in 44 CFR 1.18. Additional information on submitting a petition for rulemaking is available on the NRC's Web site, www.nrc.gov.