ML12335A658
| ML12335A658 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/28/2012 |
| From: | Bessette P, Dennis W, Glew W, O'Kula K, O'Neill M, Potts L, Riggs J, Sutton K, Teagarden G Enercon Services, Entergy Nuclear Operations, ERIN Engineering & Research, Morgan, Morgan, Lewis & Bockius, LLP, URS Safety Management Solutions |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 22092, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 | |
| Download: ML12335A658 (55) | |
Text
United States Nuclear Regulatory Commission Official Hearing Exhibit Entergy Nuclear Operations, Inc.
In the Matter of:
(Indian Point Nuclear Generating Units 2 and 3) ENT000003 ASLBP #: 07-858-03-LR-BD01 Submitted: March 28, 2012 Docket #: 05000247 l 05000286 Exhibit #: ENT000003-00-BD01 Identified: 10/15/2012 Admitted: 10/15/2012 Withdrawn:
Rejected: Stricken:
Other:
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-247-LR and
) 50-286-LR ENTERGY NUCLEAR OPERATIONS, INC. )
)
(Indian Point Nuclear Generating Units 2 and 3) )
) March 28, 2012 TESTIMONY OF ENTERGY WITNESSES LORI POTTS, KEVIN OKULA, GRANT TEAGARDEN, AND JERRY RIGGS ON CONSOLIDATED CONTENTION NYS-16B (SEVERE ACCIDENT MITIGATION ALTERNATIVES ANALYSIS)
William B. Glew, Jr., Esq. Kathryn M. Sutton, Esq.
William C. Dennis, Esq. Paul M. Bessette, Esq.
ENTERGY NUCLEAR OPERATIONS, INC. MORGAN, LEWIS & BOCKIUS LLP 440 Hamilton Avenue 1111 Pennsylvania Avenue, NW White Plains, NY 10601 Washington, DC 20004 Phone: (914) 272-3202 Phone: (202) 739-3000 Fax: (914) 272-3205 Fax: (202) 739-3001 E-mail: wglew@entergy.com E-mail: ksutton@morganlewis.com E-mail: wdennis@entergy.com E-mail: pbessette@morganlewis.com Martin J. ONeill, Esq.
MORGAN, LEWIS & BOCKIUS LLP 1000 Louisiana Street Suite 4000 Houston, TX 77002 Phone: (713) 890-5710 Fax: (713) 890-5001 E-mail: martin.oneill@morganlewis.com COUNSEL FOR ENTERGY NUCLEAR OPERATIONS, INC.
TABLE OF CONTENTS Page I. WITNESS BACKGROUND ............................................................................................. 1 A. Lori Ann Potts (LAP) ......................................................................................... 1 B. Dr. Kevin R. OKula (KRO) .............................................................................. 3 C. Grant A. Teagarden (GAT) ................................................................................ 6 D. Jerry L. Riggs (JLR) ........................................................................................... 8 II. OVERVIEW AND SCOPE OF CONSOLIDATED CONTENTION NYS-16B ........... 10 III.
SUMMARY
OF TESTIMONY AND CONCLUSIONS ................................................ 16 IV. REGULATORY AND TECHNICAL BACKGROUND ................................................ 20 A. Overview of SAMA Analysis .............................................................................. 20 B. Overview of the MACCS2 Code and Its Use of Population Data ...................... 23 V. OVERVIEW OF ENTERGYS YEAR 2035 POPULATION ESTIMATE .................. 31 VI. REBUTTAL TO NYSS AND DR. SHEPPARDS CLAIMS ....................................... 38 A. Census Undercount .............................................................................................. 38 B. Commuters from Outside the 50-Mile SAMA Analysis Region ........................ 43 VII. CONCLUSIONS.............................................................................................................. 50
List of Figures Figure 1. Generalized Process for Identifying and Evaluating Potential Severe Accident Mitigation Alternatives Figure 2. MACCS2 Polar Coordinate Grid, Centered Around Analyzed Facility List of Tables Table 1. MACCS2 Per Capita Economic Cost Input Parameters Table 2. Projected Total Population (2035) By County Table 3. 2035 Projected Total Population Within the IPEC 50-Mile Region Summarized By Wind Direction and Distance Table 4. Analysis of Net Projected Commuters Into the IPEC SAMA Analysis 50-mile Radial Region in 2035 by County
-ii-
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-247-LR and
) 50-286-LR ENTERGY NUCLEAR OPERATIONS, INC. )
)
(Indian Point Nuclear Generating Units 2 and 3) )
) March 28, 2012 TESTIMONY OF ENTERGY WITNESSES LORI POTTS, KEVIN OKULA, GRANT TEAGARDEN, AND JERRY RIGGS ON CONSOLIDATED CONTENTION NYS-16B (SEVERE ACCIDENT MITIGATION ALTERNATIVES ANALYSIS)
I. WITNESS BACKGROUND A. Lori Ann Potts (LAP)
Q1. Please state your full name.
A1. (LAP) My name is Lori Ann Potts.
Q2. By whom are you employed and what is your position?
A2. (LAP) I am a senior consulting engineer to Entergy Nuclear Operations, Inc.
(Entergy) in the areas of severe accident mitigation alternatives (SAMA) analysis and fire probabilistic risk assessment (PRA). PRA is sometimes referred to as probabilistic safety assessment (PSA). The terms PRA and PSA generally are used interchangeably within the nuclear industry. I am located at Entergys Arkansas Nuclear One (ANO) facility in Russellville, Arkansas.
1
Q3. Please summarize your professional qualifications.
A3. (LAP) My professional qualifications are provided in my curriculum vitae (ENT000004). In brief, I have over 30 years of experience as a technical professional in the nuclear industry in the areas of safety analysis, PRA, deterministic and probabilistic accident and consequence analysis, materials aging management, reactor engineering, and systems engineering.
My experience includes performing PRA and severe accident analysis of reactor, emergency system, and containment phenomena under accident conditions. This experience includes SAMA analysis performed using the MELCOR Accident Consequence Code System 2 (MACCS2) computer code. As described in more detail below, MACCS2 is a computer code used to evaluate the potential impacts of severe accidents at nuclear power plants on the surrounding public.
I have participated directly in the SAMA analyses for eight nuclear plants, including the SAMA analysis for Indian Point Units 2 and 3 (IP2 and IP3, also known jointly as Indian Point Energy Center or IPEC), and have peer reviewed the SAMA analyses for three additional nuclear plants. I am one of the authors of the Nuclear Energy Institutes (NEI) industry guidance document for performing SAMA analyses - NEI 05-01, Rev. A, Severe Accident Mitigation Alternatives (SAMA) Analysis Guidance Document (Nov. 2005) (NEI 05-01, Rev. A)
(NYS000287). NEI 05-01, Rev. A has been endorsed by the Nuclear Regulatory Commission (NRC). I have a Bachelor of Science degree in Nuclear Engineering from Pennsylvania State University.
Q4. Please describe the basis of your familiarity with the IPEC license renewal application, particularly the SAMA analysis challenged in NYS-16B.
A4. (LAP) In my position as senior consulting engineer to Entergy in the area of SAMA analysis, I have been involved with the IPEC SAMA analysis from its inception in 2005. I provided 2
advice to the Entergy Fuels and Analysis Department engineers during preparation of the original SAMA analysis and the December 2009 revised SAMA analysis. I reviewed the summaries of those analyses and provided suggestions for improvement before they were submitted to the NRC.
I, therefore, have personal knowledge of the MACCS2 modeling and assumptions used in the IPEC SAMA analysis.
I have also reviewed various materials in preparing this testimony, including those portions of the IPEC LRA relating to SAMAs. In preparing my testimony, I also reviewed New York States (NYS or the State) pleadings regarding the admission of NYS-16, amended NYS-16A, and amended NYS-16B; the Boards Orders admitting NYS-16, amended NYS-16A, and amended NYS-16B; the relevant regulations and guidance documents; relevant NRC Staff requests for additional information (RAIs) and Entergys responses; the exhibits submitted by the State that are relevant to my testimony; and the Entergy exhibits cited in my testimony. Finally, I also have reviewed the NRC Staffs evaluation of the IPEC SAMA analysis, as set forth in its December 2010 final supplemental environmental impact statement (FSEIS). See NUREG-1437, Supp. 38, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3 (Dec. 2010) (Dec. 2010 FSEIS) (NYS00133A-J).
B. Dr. Kevin R. OKula (KRO)
Q5. Please state your full name.
A5. (KRO) My name is Kevin R. OKula.
Q6. By whom are you employed and what is your position?
A6. (KRO) I am an Advisory Engineer with URS Safety Management Solutions (URS) LLC in Aiken, South Carolina.
3
Q7. Please summarize your professional qualifications.
A7. (KRO) My professional qualifications are provided in my curriculum vitae (ENT000005). In brief, I have over 29 years of experience as a technical professional and manager in the areas of safety analysis methods and guidance development, computer code validation and verification, PRA, deterministic and probabilistic accident and consequence analysis applications for reactor and non-reactor nuclear facilities, source term evaluation, risk management, software quality assurance (SQA), and shielding. I obtained my B.S. in Applied and Engineering Physics from Cornell University in 1975, and my M.S. and Ph.D. in Nuclear Engineering from the University of Wisconsin in 1977 and 1984, respectively.
In addition, I have over 20 years of experience using and applying the MACCS2 code and its predecessor, the MACCS computer code. I co-chaired a U.S. Department of Energy (DOE)
Accident Phenomenology and Consequence evaluation program in the 1990s that evaluated applicable computer models for radiological dispersion and consequence analysis. More recently, I was the technical coordinator of an SQA evaluation of computer codes used for radiological and chemical dispersion in the DOE Complex.
With regard to MACCS2, I have taught MACCS2 training courses for DOE and its contractors at Lawrence Livermore National Laboratory, Los Alamos National Laboratory, Idaho National Laboratory, the Waste Isolation Pilot Plant and the DOE Safety Basis Academy. In addition, I was the lead author of a DOE guidance document on the use of MACCS and MACCS2 for DOE safety analysis applications. I was also a member of the State-of-the-Art Reactor Consequence Analysis (SOARCA) Project Peer Review Committee that provided critical review and comment to Sandia National Laboratories (Sandia) and the NRC on the use of integrated 4
modeling of accident progression and offsite consequences from postulated severe accidents using both state-of-the-art computational analysis tools and best modeling practices.
Q8. Dr. OKula, both you and Ms. Potts have mentioned the MACCS2 code. What is the MACCS2 code, and how is it used in SAMA analyses?
A8. (KRO) MACCS2 is a computer code developed by Sandia under the sponsorship of the NRC to evaluate the potential off-site radiological consequences from atmospheric releases of radioactivity from nuclear facilities. The MACCS2 code simulates the atmospheric release of radioactivity, the transport and dispersion of the plume based on site-specific meteorological inputs and, ultimately, calculates estimated radiological health and economic impacts. To my knowledge, MACCS2 is the only NRC-recognized computer code available in the United States that is capable of meeting all of the off-site consequence requirements of a SAMA analysis, including those of calculating population dose and economic cost consequences.
Q9. Please describe the basis of your familiarity with the IPEC license renewal application, particularly the SAMA analysis challenged in NYS-16B.
A9. (KRO) I have thoroughly reviewed the various inputs and assumptions used in Entergys SAMA analysis (as revised in December 2009) to calculate off-site consequences associated with a postulated severe accident at IPEC, including relevant supporting documentation.
As discussed below, I also participated in the development and execution of certain MACCS2 sensitivity cases discussed in this testimony. See G. Teagarden, MACCS2 IP2 Population Sensitivity Case (Jan. 2012) (MACCS2 Population Sensitivity Case) (ENT000006). I thus have personal knowledge of the MACCS2 modeling and assumptions used in the IPEC SAMA analysis.
In preparing my testimony, I reviewed the States pleadings regarding the admission of NYS-16, amended NYS-16A, and amended NYS-16B; the Boards Orders admitting NYS-16, 5
amended NYS-16A, and amended NYS-16B; the relevant regulations and guidance documents; relevant NRC Staff RAIs and Entergys responses; the exhibits submitted by the State that are relevant to my testimony; and the Entergy exhibits cited in my testimony. I also reviewed the NRC Staffs evaluation of the IPEC SAMA analysis, as set forth in its December 2010 FSEIS. In addition, I provided expert support for Entergys September 21, 2009, successful opposition to NYSs motion for summary disposition of consolidated contention NYS-16/16A earlier in this proceeding. Specifically, I prepared a joint declaration with Grant Teagarden (see below) to address the claims raised in NYSs August 28, 2009, motion for summary disposition and in the supporting declaration of NYSs then-consultant, Dr. Bruce Egan. See Joint Declaration of Kevin OKula and Grant Teagarden in Support of Entergys Answer Opposing New York States Motion for Summary Disposition on Contention NYS-16/16A (Sept. 18, 2009). The Board denied NYSs motion in November 2009. See Memorandum and Order (Ruling on Motions for Summary Disposition) (Nov. 3, 2009) (unpublished).
C. Grant A. Teagarden (GAT)
Q10. Please state your full name.
A10. (GAT) My name is Grant A. Teagarden.
Q11. By whom are you employed and what is your position?
A11. (GAT) I am Manager for Consequence Analysis for ERIN Engineering & Research, Inc. in Campbell, California.
Q12. Please summarize your professional qualifications.
A12. (GAT) My professional qualifications are provided in my curriculum vitae (ENT000007). In brief, I have 14 years of experience in the nuclear field, including 10 years as a manager and technical professional in the areas of PRA, source term analysis, consequence 6
analysis, and nuclear power plant security risk assessment. I obtained a Bachelor of Science degree in Mechanical Engineering from University of Miami in 1990 and completed the Bettis Reactor Engineering School at the Bettis Atomic Power Laboratory as part of my training in the U.S. Navy nuclear program. I am a member of the American Nuclear Society (ANS) and Vice Chair of the writing committee for ANS/ASME-58.25, Standard for Radiological Accident Offsite Consequence Analysis (Level 3 PRA) to Support Nuclear Installation Applications.
I have substantial experience using the MACCS2 computer code and preparing Level 3 PRA models for commercial nuclear power plants in the United States. I have performed or overseen the performance of MACCS2 modeling in support of SAMA analyses for ten nuclear power plant sites.
I also have developed similar analyses for three proposed new reactor sites and supported reactor vendor development of MACCS2 models for new plant designs.
Q13. Please describe the basis of your familiarity with the IPEC license renewal application, particularly the SAMA analysis challenged in NYS-16B.
A13. (GAT) I have thoroughly reviewed the various inputs and assumptions used in Entergys SAMA analysis (as revised in December 2009), including relevant supporting documentation, to calculate off-site consequences associated with a postulated severe accident at IPEC. In support of this testimony, I participated in the development and execution of the MACCS2 Population Sensitivity Case (ENT000006). I therefore have personal knowledge of the MACCS2 modeling and assumptions used in the IPEC SAMA analysis.
In preparing my testimony, I reviewed the States pleadings regarding the admission of NYS-16, amended NYS-16A, and amended NYS-16B; the Boards Orders admitting NYS-16, amended NYS-16A, and amended NYS-16B; the relevant regulations and guidance documents; relevant NRC Staff RAIs and Entergys responses; the exhibits submitted by the State that are 7
relevant to my testimony; and the Entergy exhibits cited in my testimony. I also reviewed the NRC Staffs evaluation of the IPEC SAMA analysis, as set forth in its December 2010 FSEIS. Finally, along with Dr. OKula, I provided expert support for Entergys September 21, 2009, successful opposition to NYSs motion for summary disposition of consolidated contention NYS-16/16A earlier in this proceeding.
D. Jerry L. Riggs (JLR)
Q14. Please state your full name.
A14. (JLR) My name is Jerry L. Riggs.
Q15. By whom are you employed and what is your position?
A15. (JLR) I am employed as a Geographic Information System (GIS) Specialist by Enercon Services, Inc.
Q16. Please summarize your professional qualifications.
A16. (JLR) My professional qualifications are summarized in my curriculum vitae (ENT000008). In brief, I have over six years of experience as a GIS Specialist at Enercon. I have assisted in the development of combined license applications, license renewal applications, research and development of GIS operating procedures, demographic analysis, environmental justice analysis, socioeconomic impact analysis, mapping and spatial analysis, GPS data mapping, and project coordination.
As part of these efforts, I have conducted extensive literature reviews on various socioeconomic subjects, including environmental justice, and have performed demographic analyses for a number of NRC license applications. Thus, based on my experience, I am very familiar with U.S. Census Bureau data and related literature, as discussed in the testimony below.
8
I hold a Master of Arts in Geography from the University of Oklahoma with an emphasis in Digital Geography, including GIS and Remote Sensing. I also have a Bachelor of Science degree from the University of Oklahoma with an emphasis in Biochemistry.
Q17. Please describe the basis for your familiarity with the IPEC license renewal application, particularly the SAMA analysis challenged in NYS-16B.
A17. (JLR) My firm, Enercon, assisted in the development of the year 2035 population projection used in the IPEC SAMA analysis. See Enercon Services, Inc., Site Specific MACCS2 Input for Indian Point Energy Center, Rev. 1 (Dec. 1, 2009) (Enercon Report) (NYS000211). I have reviewed the supporting documentation prepared by Enercon. I also have reviewed the relevant portions of the Environmental Report accompanying the IPEC LRA, as supplemented and amended by Entergy. This documentation includes Entergys December 2009 revised SAMA analysis and related Entergy responses to NRC Staff RAIs.
In preparing my testimony, I also reviewed the States pleadings regarding the admission of NYS-16, amended NYS-16A, and amended NYS-16B; the Boards Orders admitting NYS-16, amended NYS-16A, and amended NYS-16B; the relevant regulations and guidance documents; relevant NRC Staff RAIs and Entergys responses; the exhibits submitted by the State that are relevant to my testimony; and the Entergy exhibits cited in my testimony. Finally, I also reviewed the NRC Staffs evaluation of the IPEC SAMA analysis, as set forth in its December 2010 FSEIS.
9
II. OVERVIEW AND SCOPE OF CONSOLIDATED CONTENTION NYS-16B Q18. Are you familiar with NYS-16, as originally proposed by NYS?
A18. (LAP, KRO, GAT, JLR) Yes. We have reviewed the New York State Notice of Intention to Participate and Petition to Intervene (Petition), dated November 30, 2007, available at ADAMS Accession No. ML073400187; the associated Declaration of Bruce A. Egan (the States former expert witness for this contention), dated November 27, 2007, available at ADAMS Accession No. ML092610911; and the New York Reply in Support of Petition to Intervene, dated February 22, 2008, available at ADAMS Accession No. ML080600444. The contention states:
Entergys assertion, in its SAMA analysis for IP2 and IP3, that it conservatively estimated the population dose of radiation in a severe accident, is unsupported because Entergys air dispersion model will not accurately predict the geographic dispersion of radionuclides released in a severe accident and Entergys SAMA will not present an accurate estimate of the costs of human exposure.
Petition at 163.
NYS proffered ten supporting bases that focused primarily on the accuracy of ATMOS, the atmospheric transport and dispersion model in the MACCS2 code that Entergy used to simulate the atmospheric transport and dispersion of radionuclides released by a postulated severe accident at Indian Point. See Petition, at 163-66. In a footnote, NYS also asserted that Entergys projection of the 2035 population residing within 50 miles of IPEC underestimates the potential exposed population. Id. at 164 n.37. Specifically, NYS challenged Entergys projections for the population of New York County (i.e., Manhattan). NYS cited 2006 U.S. Census Bureau data and New York City Department of City Planning population data related to Manhattan and the other four New York City boroughs as support for its contention. See id.
10
Q19. Since its initial submission of the contention, has NYS indicated that it will not pursue certain portions of its original contention at hearing?
A19. (LAP, KRO, GAT, JLR) Yes. In its Statement of Position on this contention, which it submitted on December 16, 2011, NYS indicated that it had chosen not to pursue the part of Contention 16 challenging Entergys air dispersion model at hearing. State of New York Initial Statement of Position [on] Contention NYS-16/16A/16B (NYS-16B) at 1 n.1 (Dec. 16, 2011)
(NYS-16B Position Statement) (NYS000206). On January 23, 2012, NYS, Entergy, and the NRC Staff filed a Joint Stipulation with the Licensing Board memorializing the States decision not to pursue its original challenges to the MACCS2 air dispersion model See State of New York, Entergy Nuclear Operations, Inc., and NRC Staff Joint Stipulation at 2 (Jan. 23, 2012) ([T]he State has chosen not to pursue the claim that Entergys air dispersion model is being used beyond its range of validity and does not accurately predict the geographic dispersion of radionuclides released in a severe accident, and, therefore, it is no longer at issue in this contention.). Consequently, our testimony addresses the only remaining issue for hearing; i.e., the adequacy of the year 2035 population projection used by Entergy in the IPEC SAMA analysis.
Q20. Are you familiar with the Boards July 31, 2008, ruling admitting NYS-16?
A20. (LAP, KRO, GAT, JLR) Yes. As relevant here, the Board admitted NYS-16 to the extent that it challenges whether the population projections used by Entergy are underestimated, noting that population is one input to the MACCS2-based SAMA analysis. Entergy Nuclear Operations, Inc. (Indian Point, Units 2 & 3), LBP-08-13, 68 NRC 43, 112 (2008).
11
Q21. Are you familiar with amended Contention NYS-16A, as it relates specifically to the 2035 population projection used in the IPEC SAMA analysis?
A21. (LAP, KRO, GAT, JLR) Yes. NYS submitted NYS-16A in response to the NRC Staffs December 2008 draft supplemental environmental impact statement (DSEIS). State of New York Contentions Concerning NRC Staffs Draft Supplemental Environmental Impact Statement (Feb. 27, 2009) (Amended Contention NYS-16A), available at ADAMS Accession No. ML090690303. With respect to the population issue, the amended contention offered no information that was materially new or different from the original contention. NYS referenced 2007 U.S. Census Bureau data related to Manhattan in support of its claim. See id. at 10 n.4.
Q22. Are you familiar with the Boards June 16, 2009, ruling admitting NYS-16A?
A22. (LAP, KRO, GAT, JLR) Yes. The Board admitted NYS-16A to the degree that the Draft SEIS fails to address the issues raised by New York in NYS-16. Order (Ruling on New York States New and Amended Contentions) at 6 (June 16, 2009) (unpublished). The Board reiterated that NYS-16A alleges that the population projections used by Entergy are underestimated, but did not elaborate further on this aspect of the contention. Id.
Q23. Are you familiar with amended Contention NYS-16B, as it relates specifically to the 2035 population projection used in the IPEC SAMA analysis?
A23. (LAP, KRO, GAT, JLR) Yes. On March 11, 2010, NYS filed NYS-16B in response to Entergys December 2009 revised SAMA analysis. See State of New Yorks Motion for Leave to File New and Amended Contentions Concerning the December 2009 Reanalysis of Severe Accident Mitigation Alternatives (Mar. 11, 2010) (Amended Contention NYS-16B), available at ADAMS Accession No. ML100780366. Specifically, NYS-16B asserted for the first time that Entergy did not adequately account for tourists and daily commuters entering the 50-mile radius SAMA analysis 12
region surrounding IPEC, particularly New York City. See id. at 8 n.3. NYS cited 2008 U.S.
Census Bureau data and New York City tourism data in support of its amended contention. Id.
Q24. Are you familiar with the Boards June 30, 2010, ruling admitting NYS-16B?
A24. (LAP, KRO, GAT, JLR) Yes. The Board admitted NYS-16B in part and consolidated it with NYS-16/16A, inasmuch as it repeated the allegations in those contentions and deals with the additional aspect of tourist and commuter populations. Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3), LBP-10-13, 71 NRC 673, 687 (2010).
Q25. Did the NRC Staff issue an FSEIS for the IPEC LRA in December 2010, after the Board admitted NYS-16B?
A25. (LAP, KRO, GAT, JLR) Yes. The NRC Staff issued the FSEIS in December 2010.
See Dec. 2010 FSEIS (NYS00133A-J). Section 5.2 (Vol. 1) and Appendix G (Vol. 3) of the FSEIS document the Staffs review and evaluation of the IPEC SAMA analysis.
Q26. Does the December 2010 FSEIS contain any new discussion relevant to NYS-16B relative to that contained in the DSEIS?
A26. (LAP, KRO, GAT, JLR) Yes. FSEIS Section G.2.3 summarizes additional technical analysis performed by the Staff and Sandia that directly addresses the specific allegations made in NYS-16B. See Dec. 2010 FSEIS Vol. 3, App. G at G-24 to G-25 (NYS000133I). Relevant here, the Staff/Sandia reviewed Entergys baseline and projected population values and its population projection methodology, and developed independent estimates of the baseline and projected population for the year 2035. See id. As documented in the FSEIS, the Staff/Sandia concluded that Entergys population data and projected population growth analysis provide reasonable (and slightly conservative) population values for the SAMA analysis. Id. at G-25.
13
Q27. Did NYS amend NYS-16B in response to the new discussion contained in Section G.2.3 of the December 2010 FSEIS?
A27. (LAP, KRO, GAT, JLR) No, NYS did not amend NYS-16B.
Q28. In view of the above, please summarize your understanding of the scope of NYS-16B, as admitted by the Board.
A28. (LAP, KRO, GAT, JLR) Consistent with the pleadings and Board rulings described above, we understand NYS-16B to be limited in scope to the adequacy of the year 2035 population projection used in the IPEC SAMA analysis; i.e., whether that projection has underestimated the year 2035 population and adequately accounted for tourist and commuter populations in the 50-mile SAMA analysis region.
Q29. Have you reviewed the States initial written statement of position, prefiled direct testimony, and supporting exhibits concerning NYS-16B, which were filed on December 16, 2011?
A29. (LAP, KRO, GAT, JLR) Yes. We have reviewed the following documents filed by NYS on December 16, 2011: NYS-16B Position Statement (NYS000206); Pre-Filed Written Testimony of Dr. Stephen Sheppard, Ph.D. Regarding Contention NYS-16/16A/16B (Dec. 16, 2011) (Sheppard Testimony) (NYS000207); Curriculum Vitae of Stephen Charles Sheppard (NYS000208); Report of Dr. Stephen C. Sheppard, Ph.D. in Support of Contention NYS-16/16A/16B (Sheppard Report) (NYS000209); and Exhibits NYS00132A to D, NYS00133A to J, and NYS000210 through NYS000222.
Q30. Have you reviewed other materials in preparation for your testimony?
A30. (LAP, KRO, GAT, JLR) Yes, including Entergys 2009 revised SAMA analysis and its supporting documentation. See NL-09-165, Letter from Fred Dacimo, Entergy, to NRC, 14
License Renewal Application - SAMA Reanalysis Using Alternate Meteorological Tower Data, Indian Point Nuclear Generating Units Nos. 2 and 3, Attach. 1, at 6 (Dec. 11, 2009) (NL-09-165)
(ENT000009). We also reviewed relevant NRC regulations and guidance documents and the exhibits cited in our testimony.
Q31. What are the sources of those additional materials?
A31. (LAP, KRO, GAT, JLR) Many are documents prepared by government agencies, documents prepared by Entergy or the utility industry, and peer reviewed articles. These documents include, for example, NRC regulations and guidance documents, NEI guidance, the IPEC license renewal application, NRC Staffs DSEIS and December 2010 FSEIS, U.S. Census Bureau data, demographic data from various governmental sources, and relevant technical papers.
Q32. Please direct your attention to what has been marked as Exhibit ENT000001.
Do you recognize this document?
A32. (LAP, KRO, GAT, JLR) Yes. It is a list of Entergys exhibits and includes those documents which we referred to, used, or relied upon in preparing respective portions of our testimony, ENT000004 through ENT000011 and ENT000013 through ENT000027.
Q33. Please direct your attention to what has been marked as Exhibits ENT000004 through ENT000011 and ENT000013 through ENT000027. Do you recognize these documents?
A33. (LAP, KRO, GAT, JLR) Yes. These are true and accurate copies of the documents that we have referred to, used, and/or relied upon in preparing this testimony. Where we have attached only a document excerpt, that is noted on Entergys exhibit list.
15
Q34. How do these documents relate to the work that you do as an expert in forming opinions such as those contained in this testimony?
A34. (LAP, KRO, GAT, JLR) These documents represent the type of information that persons within our fields of expertise reasonably rely upon in forming opinions of the type offered in this testimony. We note at the outset that we cannot offer legal opinions on the language of the NRC regulations or adjudicatory decisions discussed in our testimony. However, reading those regulations and decisions as technical statements, and using our expertise, we can interpret what those regulations mean relative to a SAMA analysis.
III.
SUMMARY
OF TESTIMONY AND CONCLUSIONS Q35. What is the purpose of your testimony?
A35. (LAP, KRO, GAT, JLR) Our testimony will explain how Entergy developed the year 2035 population projection used in its SAMA analysis and why that projection is reasonable and appropriate for its intended purpose pursuant to the National Environmental Policy Act (NEPA) and industry and NRC guidance. In doing so, we explain why the issues raised by NYS in NYS-16B and its evidentiary submissions for that contention lack factual or technical merit.
Q36. Please summarize the principal claims made by NYS and its consultant, Dr.
Sheppard, in NYSs prefiled testimony on NYS-16B.
A36. (LAP, KRO, GAT, JLR) NYS and Dr. Sheppard allege that the 2035 population estimate used by Entergy in its SAMA analysis, and approved by the NRC Staff in the December 2010 FSEIS, is deficient in two respects. They first allege that Entergys 2035 population estimate, which is based on published 2000 census data, does not account for census undercount, which Dr.
Sheppard defines as the persistent undercount of portions of the population by the U.S. Census Bureau in the decennial census, particularly minorities and the poor. Sheppard Testimony at 10 16
(NYS000207). They further claim that Entergys population estimate does not include those who reside outside the 50 mile radius of IPEC, but commute to workplaces within [IPECs] 50 mile radius. Id. Dr. Sheppard opines that these alleged deficiencies cause the population to be materially underestimated. Id.
Q37. Does Dr. Sheppard provide any proposed population estimates of his own?
A37. (LAP, KRO, GAT, JLR) Yes, in purporting to account for both census undercount and additional commuters, Dr. Sheppard estimates that the 2035 population within a 50-mile radius of IPEC will be 20,456,285 persons - more than the 19,228,712 persons that Entergy had estimated.
Sheppard Testimony at 16 (NYS000207). Dr. Sheppards higher estimate results from his inclusion of an additional 995,778 commuters and 231,632 persons purportedly associated with census undercount. Id. at 13, 16. These two additional contributors cited by Dr. Sheppard represent a total increase of 6.38% of Entergys 50-mile population estimate, 5.18% associated with commuters, and 1.20% associated with census undercount. See id. at 16.
Q38. Does Dr. Sheppard establish that using his larger population estimate of 20,456,285 persons will result in the identification of additional cost-beneficial SAMAs, beyond the specific SAMAs already identified by Entergy as cost-beneficial?
A38. (LAP, KRO, GAT, JLR) No, Dr. Sheppard does not conduct any such analysis. Dr.
Sheppard states only that [a] lower population estimate could lead to an underestimation of the benefit obtained from implementing a SAMA, thus potentially excluding certain mitigation alternatives from full consideration. Sheppard Testimony at 3-4 (NYS000207). He makes no attempt to revise the IP2 and IP3 SAMA analyses using his population estimate, or otherwise quantitatively assess the effect of using his proposed population estimate on the actual number of SAMAs identified as cost-beneficial in the SAMA analysis for each unit.
17
Q39. Do NYS or Dr. Sheppard explain why they did not perform such analyses?
A39. (LAP, KRO, GAT, JLR) No.
Q40. Does NYS have access to the MACCS2 software to perform such analyses?
A40. (LAP, KRO, GAT, JLR) Yes. NYS obtained a copy of MACCS2 from the NRC sometime in early 2010. See NRC Staffs Answer to State of New Yorks Motion to Compel NRC Staff to Produce the MACCS2 Code Absent a Fee, and Motion for Dismissal of that Motion as Moot at 2 (Jan. 27, 2010), available at ADAMS Accession No. ML100280325. In addition, the States expert witness for contention NYS-12C (Dr. François Lemay) has access to the MACCS2 code. See Pre-filed Written Testimony of Dr. François J. Lemay Regarding Consolidated Contention NYS-12C at 23-24 (NYS000241).
Q41. Do you agree with NYSs and Dr. Sheppards contention that Entergy has potentially excluded certain mitigation alternatives from full consideration because it materially underestimated the 2035 population?
A41. (LAP, KRO, GAT, JLR) No. For the reasons discussed below, we disagree with Dr.
Sheppards analysis. Notwithstanding the shortcomings with his methodology and assumptions, our own quantitative MACCS2 sensitivity analysis shows that, even if we were to accept Dr.
Sheppards assumptions and adjust for census undercount and commuters as he suggests, such adjustments would have no material impact on the results of the IPEC SAMA analysis.
In any event, Entergys 2035 population projection is reasonable and appropriate for its intended purpose under NEPA. With regard to Dr. Sheppards census undercount argument, Entergy reasonably and appropriately relied upon published 2000 U.S. Census Bureau data.
Federal, state, and local agencies routinely rely upon such published data in assessments performed to comply with NEPA and other legal or regulatory obligations. In addition, the documents that Dr.
18
Sheppard relies upon contain conclusions regarding census undercount that have been superseded by more recent U.S. Census Bureau documentation that Dr. Sheppard fails to acknowledge in either his testimony or report. The more recent documentation actually indicates that the 2000 census data relied upon by Entergy slightly overcounted - not undercounted - the total population.
Second, contrary to Dr. Sheppards commuter argument, Entergy conservatively included appropriate transient populations for the entire 50-mile region within the SAMA analysis, including tourists and business travelers. The relevant SAMA industry guidance, NEI 05-01, Rev. A, suggests that the transient population assumed in the SAMA analysis should be consistent with the transient population included in the site emergency plan. As discussed further below, the relevant IPEC emergency planning document defines transients as shoppers and recreational visitors, which is consistent with the definition Entergy used in its SAMA analysis. Consistent with the NRCs emergency planning regulations, Entergy considered populations, including transients, within the 10-mile emergency planning zone (EPZ). Indeed, Entergy even went beyond the suggested 10-mile EPZ and included within its SAMA population projection estimated transient business travelers and tourists within the entire 50-mile region. Entergys methodology and basis for accounting for the transient population was independently reviewed by the NRC Staff, who concurred with Entergys characterization of the transient population.
Even assuming - for the sake of argument - that commuters should be included in the transient population, Dr. Sheppards commuter population calculations are flawed and significantly overstate the net commuter population into the 50-mile SAMA analysis region. In particular, we identified two major errors in Dr. Sheppards analysis: (1) his conceptualization of commuter is overbroad in that it considers individuals from all over the country who work within the 50-mile region to be commuters into the region, rather than business travelers, for which Entergy already 19
accounts; and (2) he fails to consider the countervailing effect of business travelers and commuters who travel or commute out of the 50-mile SAMA analysis region.
Based on the above, we disagree with the States contention that Entergy has materially underestimated the 2035 population, and we conclude that the States claims in NYS-16B lack factual and technical merit.
IV. REGULATORY AND TECHNICAL BACKGROUND A. Overview of SAMA Analysis Q42. What is a severe accident?
A42. (LAP, KRO, GAT) The NRC defines a severe accident as a beyond design-basis accident involving multiple failures of equipment or function, whose likelihood is generally lower than design-basis accidents but where consequences may be higher. NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants Vol. 1, at 5-1 (May 1996)
(GEIS) (NYS00131C). The GEIS provides an evaluation of severe accident impacts that applies to all U.S. nuclear power plants. See generally id. at 5-1 to 5-20. Based on the GEIS evaluation of severe accidents, 10 C.F.R. Part 51 concludes that the [t]he probability weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to ground water, and societal and economic impacts from severe accidents are small for all plants. 10 C.F.R. Pt. 51, Subpt. A, App.
B, Tbl. B-1 (Postulated Accidents; Severe accidents) (emphasis added). Thus, by definition, a SAMA analysis considers postulated events whose probability of occurrence is so low that they are excluded from the spectrum of design-basis accidents postulated for a plant by NRC regulations.
Q43. Please describe the purpose of a SAMA analysis.
A43. (LAP, KRO, GAT) The purpose of the analysis is to identify SAMA candidates that have the potential to reduce severe accident risk and to determine if implementation of each SAMA 20
candidate is potentially cost beneficial. See NEI 05-01, Rev. A, at 1 (NYS000287). Specifically, a SAMA analysis identifies potential changes to a nuclear power plant, or its operations, that could reduce the already-low risk (the likelihood and/or the impact) of a severe accident for which the benefit of implementing the change may outweigh the cost of implementation. Changes to the nuclear power plant that could reduce the risk of a severe accident include plant modifications or operational changes (e.g., improved procedures and augmented training of control room and plant personnel). These potential changes are referred to as SAMAs or SAMA candidates.
Q44. What is the purpose of NEI 05-01, Rev. A?
A44. (LAP, KRO, GAT) NEI 05-01, Rev. A was developed by several SAMA experts, including Ms. Potts, and was issued by NEI in November 2005. See NEI 05-01, Rev. A (title page and acknowledgements) (NYS000287). It provides guidance to reactor license renewal applicants for completing the SAMA analysis required by NRCs NEPA regulations found in 10 C.F.R. Part
- 51. It identifies the information that an applicant should include so that the SAMA analysis will be complete. See id. at i. NEI 05-01, Rev. As guidance relies upon regulatory analysis techniques presented in NUREG/BR-0184, Regulatory Analysis Technical Evaluation Handbook (Jan. 1997)
(NUREG/BR-0184) (ENT000010A-D), and draws from experience gained from previous SAMA analyses and NRC reviews thereof. Id.
Q45. Has the NRC endorsed the use of NEI 05-01, Rev. A to perform SAMA analyses?
A45. (LAP, KRO, GAT) Yes. The Staff has recommended that applicants for license renewal follow the guidance provided in NEI 05-01, Revision A when preparing their SAMA analyses. Notice of Availability of the Final License Renewal Interim Staff Guidance LR-ISG-2006-03: Staff Guidance for Preparing Severe Accident Mitigation Alternatives Analyses, 72 Fed.
21
Reg. 45,466, 45,467 (Aug. 14, 2007) (NEI 05-01, Revision A, describes existing NRC regulations, and facilitates complete preparation of SAMA analysis submittals.).
Q46. How is a SAMA analysis performed?
A46. (LAP, KRO, GAT) As summarized in Figure 1 below, a SAMA analysis involves four major sequential steps: (1) characterizing the overall plant severe accident risk and the leading contributors to the risk; (2) identifying potential plant improvements (i.e., SAMA candidates) that could reduce the risk of a severe accident; (3) quantifying the risk-reduction potential and the implementation cost for each SAMA candidate; and (4) determining whether implementation of the SAMA candidates may be cost-effective.
SAMA analysis is inherently probabilistic and, therefore, does not focus on a single event.
Instead, it evaluates a wide range of potential long-term severe accident consequence scenarios for the purpose of making reasonable cost-benefit evaluations under NEPA. Because it is concerned with mean annual consequences, a SAMA analysis is not designed to model a single radiological release event under specific meteorological conditions at a single moment in time. Instead, it models numerous accident release conditions that could, based on probabilistic analysis, occur at any time under varying weather conditions during a one-year period to develop the mean annual outcome of the potential impacts for the entire 50-mile radius area of interest.
NEI 05-01, Rev. A also recommends that applicants perform sensitivity analyses that evaluate how changes to certain assumptions and uncertainties in the SAMA analysis would affect the cost-benefit analysis outcome. NEI 05-01, Rev. A, at 30-32 (NYS000287).
22
Figure 1. Generalized Process for Identifying and Evaluating Potential Severe Accident Mitigation Alternatives.
(Source: NUREG-1850, Frequently Asked Questions on License Renewal of Nuclear Power Reactors at 4-33 (Mar. 2006) (ENT000011))
B. Overview of the MACCS2 Code and Its Use of Population Data Q47. How is the MACCS2 code used in SAMA analysis?
A47. (KRO, GAT) MACCS2 estimates the radiological doses, health effects, and economic consequences that could result from the postulated accidental release of radioactive materials to the atmosphere during a severe accident at a nuclear power plant.
23
Q48. Is the MACCS2 code generally accepted in the nuclear industry for performing the consequence determination in a SAMA analysis?
A48. (KRO, GAT) Yes. To our knowledge, all SAMA analyses for U.S. nuclear power plants seeking license renewal have used the MACCS2 code or one of its predecessors. As stated in Answer 8, the MACCS2 code is the only NRC-recognized computer code available in the United States that is capable of meeting all of the off-site consequence requirements of a SAMA analysis, including those of calculating population dose and economic cost consequences.
Q49. How are population data used in MACCS2 calculations?
A49. (KRO, GAT) MACCS2 executes three modules in sequence to calculate consequence values necessary for a SAMA analysis - the ATMOS, EARLY, and CHRONC modules. See NUREG/CR-6613, Code Manual for MACCS2, Vol. 1, Users Guide at 2-1 (May 1998) (MACCS2 Users Guide) (NYS000243). Population data are used as inputs to the EARLY and CHRONC modules. The EARLY module uses population data and other inputs to calculate radiation dose consequences due to radiation exposure in the emergency phase (i.e., the first seven days from the time of release). Id. at 2-2. The CHRONC module uses population data and other inputs to calculate: (1) the long-term radiation doses due to exposure after the emergency phase; and (2) the economic impacts from each accident sequence including the economic cost of short-term and long-term protective actions. See id. at 2-2.
Q50. In calculating severe accident consequences, does MACCS2 take into account variations in population density across the 50-mile SAMA analysis region?
A50. (KRO, GAT) Yes. As we noted previously, a SAMA analysis is inherently probabilistic. Therefore, to develop statistical distributions of consequence measures that meaningfully depict the range and probability of consequences for the reactor in question, severe 24
accident consequence assessments must examine numerous possible combinations of representative sets of radiological source terms, weather sequences, and exposed populations. To that end, MACCS2 uses a polar-coordinate spatial grid to correctly structure the transport downwind of a plume under conditions specified by the plant meteorological data onto grid elements with the appropriate population potentially exposed in the course of plume travel. Many weather sequences are evaluated, and the mean annual consequence is calculated for each representative source term over the 50-mile radius SAMA region surrounding the reactor facility. See, e.g., NEI 05-01, Rev. A at 15 (NYS000284).
Q51. Please explain how the polar coordinate grid system applies to the 50-mile radius region around IPEC.
A51. (KRO, GAT, LAP, JLR) The 50-mile radius region is divided into a polar coordinate grid with the plant at its center, similar to Figure 2 below, which depicts the 16 standard meteorological wind direction sectors that are used in MACCS2 applications (e.g., NW, SSE, etc.).
See MACCS2 Users Guide at 2-3 to 2-5 (NYS000243). For the IPEC site, this polar grid is comprised of a series of radial rings centered on the site with boundaries at radii of 0.2, 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 20, 30, 40, and 50 miles. As seen in Figure 2 (which shows only five radial rings at 10, 20, 30, 40, and 50 miles), each of the radial rings is transected by 16 wind direction sectors emanating from the plant. All of the MACCS2 calculations are stored on the basis of this polar coordinate grid system. See id. at 2-3.
25
INDIAN POINT Figure 2. MACCS2 Polar Coordinate Grid, Centered Around Analyzed Facility (Source: Figure based on Figure 2-1 of the MACCS2 Users Guide at 2-5)
Q52. How does MACCS2 use population data in a polar coordinate grid system to calculate offsite population dose and economic costs?
A52. (KRO, GAT) Using population data and other inputs, MACCS2 calculates the population dose and economic cost for each of the individual grid spatial elements affected by the simulated radiological release and then sums the results over all of the grid spatial elements. This process yields a distribution of population dose results and a distribution of off-site economic cost results for each postulated accident scenario. Each result is weighted by its probability of occurrence. See MACCS2 Users Guide at 2-19 (NYS000243).
26
Q53. How are the MACCS2 calculations for offsite population dose and offsite economic cost incorporated into the SAMA analysis?
A53. (KRO, GAT) As we explained above in Answer 46, step one of the SAMA analysis is to characterize the overall plant severe accident risk by developing a plant-specific PRA. Next, the off-site population dose and off-site economic cost consequence values are multiplied by the calculated severe accident frequency results obtained from the PRA models. See NL-09-165, Attach. 1, at 6 (ENT00009). This calculation results in the key risk values of interest for determining potentially cost-beneficial SAMAs: (1) population dose risk (PDR) in units of person-rem/year; and (2) the off-site economic cost risk (OECR) in units of dollars/year. See id.
The individual PDRs and OECRs for the different accident scenarios are summed to determine the overall PDR and overall OECR for the SAMA analysis. See id.
Q54. How are the overall OECR and PDR risk metrics described above used in the actual cost-benefit evaluation that is performed as the final step of the SAMA analysis?
A54. (KRO, GAT, LAP) To identify SAMAs that may be cost-beneficial, the net value or benefit of each mitigation alternative, or SAMA, is estimated in accordance with a methodology described in NRC guidance documents and compared with the estimated cost of implementing the proposed SAMA. See NUREG/BR-0184 (ENT000010A-D); NUREG/BR-0058, Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission, Rev. 4 (Sept. 2004)
(ENT000013). The results of the cost benefit analysis of IPEC SAMA candidates are documented in NL-09-165. See NL-09-165, Attach. 1 (ENT000009).
27
Q55. You mentioned population dose risk, or PDR. What types of populations did Entergy include within its population projection for IPEC SAMA analysis purposes?
A55. (LAP, JLR) Entergy included permanent residents and transients. Transients include business travelers and tourists who enter the 50-mile IPEC region.
Q56. Was the inclusion of those populations consistent with industry guidance?
A56. (LAP, JLR) Yes. The industry guidance on SAMA analyses, NEI 05-01, Rev. A, recommends the following:
Provide a predicted population within a 50-mile radius of the site. The predicted population distribution may be obtained by extrapolating publicly available census data. Transient population included in the site emergency plan should be added to the census data before extrapolation.
NEI 05-01, Rev. A at 13 (emphasis added) (NYS000278).
IPECs site emergency plan incorporates population assumptions from the Indian Point Energy Center Development of Evacuation Time Estimates (IPEC ETE). KLD Associates, Inc.,
Indian Point Energy Center Development of Evacuation Time Estimates, Rev. 2 (Oct. 2004)
(ENT000014). The IPEC ETE defines transients as shoppers and recreational visitors who enter the 10-mile EPZ surrounding IPEC who leave on the same day or stay overnight in hotels or camping facilities. Id. at 3-9. Accordingly, Entergys inclusion of business travelers and tourists within the transient population is consistent with NEI 05-01, Rev. A. Indeed, by including business travelers, Entergy actually exceeds this guidance.
Further, Entergys population projection significantly exceeds the NEI guidance, because Entergy included business travelers and tourists within the entire 50-mile region, which encompasses a far greater area than the 10-mile EPZ governed by the site emergency plan, as referenced in NEI 05-01, Rev. A. In addition, as discussed below in A68, Entergys methodology 28
and basis for accounting for the transient population was independently reviewed by the NRC Staff, who concurred with Entergys characterization of the transient population.
Q57. Would including commuters within the transient population have any material impact on the IPEC SAMA results?
A57. (LAP, JLR, KRO, GAT) No. Accurately accounting for commuters within the transient population requires an analysis of not only workers who commute into the 50-mile region, but also residents who commute out of the 50-mile region and residents who commute from one location to another within the 50-mile region. Such an analysis would add an unnecessary level of complexity, and as discussed below in Answer 89, would have no material impact on the SAMA analysis.
Q58. Please explain how MACCS2 treats transients and permanent residents.
A58. (KRO, GAT) In its calculations, MACCS2 does not make any distinction between permanent residents and other persons who may be considered transients. MACCS2 effectively treats all persons included in the population data as permanent residents.
Q59. What is the effect of that treatment?
A59. (KRO, GAT) For the SAMA MACCS2 metrics of interest - i.e., dose impacts (PDR) and cost impacts (OECR) - this approach results in conservative estimates of dose and cost impacts for those segments of the modeled population that are not permanent residents.
Q60. How does treating all persons in the 50-mile region as permanent residents in MACCS2 result in conservative estimates of dose impacts (PDR)?
A60. (KRO, GAT) MACCS2 assumes that each person included in the population data resides in the 50-mile region 100% of the time. This is a conservative assumption for transients who are only within the 50-mile region for a smaller percentage of the time. For instance, shoppers 29
and recreational visitors may only be in the 50-mile region for a few hours for a few days each year.
Therefore, the population dose calculated by MACCS2 may overestimate the dose for this component of the population. For the IPEC SAMA analysis, including transients in the population data thus results in a higher, or more conservative, estimate of population dose.
Q61. How does including all persons in the 50-mile region as permanent residents in MACCS2 result in conservative economic offsite cost estimates?
A61. (KRO, GAT) With respect to offsite cost impacts (i.e., OECR), considering all persons in the 50-mile region as permanent residents affects the MACCS2 calculation through a set of per capita (per person) input parameters in the CHRONC module of the MACCS2 code. Below, we discuss the specific per capita inputs - EVACST, POPCST, RELCST, CDNFRM, VALWNF, and VNFRM - and also summarize below in Table 1 how those inputs apply to transients as they are treated in the MACCS2 code.
- EVACST accounts for the daily cost (e.g., food, housing) for a person who is evacuated in the accident early phase (i.e., 7 days). These costs would not be applicable to transients who reside outside the 50-mile analysis region because they would not require temporary housing and food. Their residences outside the 50 mile region are assessed as not impacted by a severe accident.
- POPCST accounts for the one time relocation cost for a person who is relocated due to exceeding dose criteria. These relocation costs address moving costs and lost income associated with an assumed disruption period caused by interdiction (i.e., decontamination or condemned land). The moving costs are generally small compared to lost income. While transients would not incur moving costs, commuters could be impacted by lost income, because their job sites would be impacted by interdiction. These relocation costs are therefore applicable to commuters, but not applicable to other types of transients (e.g.,
tourists).
- RELCST accounts for the daily cost (e.g., food, housing) for a person who is relocated in the long-term phase. These costs are not applicable to transients who reside outside the 50-mile analysis region, because they would not require temporary housing and food. Their residences outside the 50-mile region are assessed as not impacted by a severe accident. For the IPEC SAMA analysis, including transients in the population data results in a conservative estimate of relocation costs.
30
- CDNFRM accounts for the cost of decontaminating non-farm property. These costs would not be applicable to transients who reside outside the 50 mile analysis region because their property is assessed as not impacted by a severe accident. For the IPEC SAMA analysis, including transients in the population data results in a conservative estimate of non-farm decontamination costs.
- VALWNF and VNFRM account for the value of non-farm wealth (e.g., land, buildings) lost due to condemned land. These costs would not be applicable to transients who reside outside the 50-mile analysis region because their property is assessed as not impacted by a severe accident. For the IPEC SAMA analysis, including transients in the population data results in a conservative estimate of non-farm wealth losses.
Table 1. MACCS2 Per Capita Economic Cost Input Parameters Variable Cost Description Applicability to Transients EVACST Daily cost (housing, food) for a person Costs not applicable.
who has been evacuated (within 7 days). Transients drive home (outside affected area)
POPCST One time population relocation cost Costs not applicable for transients associated with interdiction. who do not work in the region.
Addresses moving costs and lost income. Moving costs are small compared to lost income.
RELCST Daily cost (housing, food) for a person Costs not applicable.
who has been relocated.
Transients are at home (outside affected area)
CDNFRM Cost of non-farm decontamination Costs not applicable.
Transients personal property is not in the 50 mile region and does not require decontamination.
VALWNF / Value of non-farm wealth (land, Cost not applicable.
VNFRM buildings) lost Transients personal property is not in the 50 mile region and is not impacted.
V. OVERVIEW OF ENTERGYS YEAR 2035 POPULATION ESTIMATE Q62. Why did Entergy project the population out to 2035?
A62. (LAP, JLR) NEI 05-01, Rev. A provides the following guidance: Typically, with increasing population, the predicted population is estimated for a year within the second half of the 31
period of extended operation. Extrapolation to a later date, and therefore a larger population, adds conservatism to the analysis. NEI 05-01, Rev. A, at 13 (NYS000287). The year 2035 is the last year of the IP3 extended operating period and two years after the end of the IP2 extended operating period. See Indian Point Energy Center License Renewal Application, App, E, Applicants Environmental Report, Operating License Renewal Stage, Indian Point Energy Center at 1-1 (April 2007) (ER) (ENT000014-POP).
Q63. Please describe how Entergy estimated the year 2035 total population within a 50-mile radius of IPEC.
A63. (LAP, JLR) The details of Entergys population projections are presented in the Enercon Report (NYS000211). In brief, Entergy first determined the year 2000 permanent population within a 50-mile radius of IPEC, and then projected those populations out to the year 2035. Entergy estimated the total population by adjusting the resulting projection of permanent population upward to account for the presence of the transient population.
Q64. How did Entergy determine the year 2000 permanent population within a 50-mile radius of IPEC?
A64. (LAP, JLR) Entergy first determined which counties are, in whole or in part, within 50 miles of IPEC. See Enercon Report at 1-1 to 1-3 (NYS000211). For those counties that are not entirely within the 50-mile radius, Entergy determined the percentage of land area in the county that is within the 50-mile radius of IPEC. See id. at 1-3. Entergy then used population estimates from state and local governments, based on published 2000 U.S. Census data, to determine the population of each county. See id. at 2-1.
32
Q65. How did Entergy project the 2000 population estimate to the year 2035?
A65. (LAP, JLR) Entergy first obtained available county-level permanent population projection estimates from the New York Statistical Information System for the period 2000 to 2030, the New Jersey Department of Labor and Workforce Development for the period 2000 to 2025, the Connecticut State Data Center for the period 2000 to 2020, and the Pennsylvania State Data Center for the period 2000 to 2020. Enercon Report at 2-1 (NYS000211). For each county, Entergy used these state population projections using methods described in the Enercon Report to extrapolate the 2000 permanent population from the census data to 2035 permanent population values. See id. at 2-1 to 2-2.
Entergy then adjusted the county-level permanent population projection upward to account for the presence of the transient (business traveler and tourist) population. See id. at 2-2 to 2-5 (NYS000211). For each county, Entergy used state and local estimates of the transient population to estimate the ratio of the permanent-to-transient population in 2004. See id. The year 2035 transient population was assumed to be the 2004 transient-to-permanent population ratio multiplied by the extrapolated 2035 permanent population. Id. at 2-5. Table 2 below, excerpted from the Enercon Report, presents these data on a county basis. Id.
33
Table 2. Projected Total Population (2035) By County1 (Source: Table 2.3 of Enercon Report at 2-5) 2035 Projected Permanent 2035 Projected County Transient/Permanent Ratio Population Total Population Connecticut Fairfield 0.015 918,600 932,828 Litchfield 0.015 217,309 220,675 New Haven 0.015 896,364 910,248 New Jersey Bergen 0.023 1,089,428 1,114,876 Essex 0.023 868,715 889,007 Hudson 0.023 690,981 707,121 Middlesex 0.023 1,053,511 1,078,120 Morris 0.023 653,201 668,459 Passaic 0.023 553,404 566,330 Somerset 0.023 470,131 481,112 Sussex 0.023 217,947 223,038 Union 0.023 590,616 604,412 Warren 0.023 156,074 159,719 New York Bronx 0.014 1,634,750 1,657,680 Dutchess 0.024 319,391 327,050 Kings 0.014 2,618,418 2,655,145 Nassau 0.024 1,251,644 1,281,658 New York 0.014 1,570,657 1,592,688 Orange 0.024 445,234 455,910 Putnam 0.024 120,738 123,633 Queens 0.014 3,024,717 3,067,143 Richmond 0.014 662,838 672,135 Rockland 0.024 278,799 285,484 Suffolk 0.024 1,490,766 1,526,514 Sullivan 0.024 94,055 96,310 Ulster 0.024 222,655 227,994 Westchester 0.024 914,934 936,873 Pennsylvania Pike 0.15 103,437 120,669 1
County populations presented include portions of some counties that are outside of the 50-mile SAMA analysis region.
34
Q66. How are these data input into MACCS2?
A66. (KRO, GAT, LAP, JLR) As an initial matter, MACCS2 does not rely on the total 2035 population estimate. As discussed above in Answer 51, the sector grid for the IPEC SAMA analysis was divided into spatial elements by superimposing fifteen circles of increasing diameter over sixteen sectors, for a total of 240 spatial elements. Enercon Report at 1-1 (NYS000211).
Entergy used areal weighting to transfer the 2035 projected total population from the counties to the 240 MACCS2 grid spatial elements. Id. at 2-6. The end result is a fractional population for each grid spatial element within 50 miles of IPEC. See id. As reflected in Tables E.1-12 and E.3-12 of the IPEC ER (Indian Point Energy Center License Renewal Application, App. E, ER, Attach.
E at E.1-87, E.3-81 to E.3-83 (ENT000015B)) and Table 3 below, when these fractional populations are summed, the total 2035 population (projected permanent + projected transient) is 19,228,712 persons. Id.
35
Table 3. 2035 Projected Total Population Within the IPEC 50-Mile Region Summarized By Wind Direction and Distance (Source: Table 2.4 of Enercon Report at 2-6)
Sector 0-10 10-20 20-30 30-40 40-50 50-mile miles miles miles miles miles Total N 12,488 22,955 30,654 39,620 51,057 156,774 NNE 14,952 28,140 39,917 56,226 67,213 206,448 NE 23,377 29,419 53,692 62,559 41,261 210,308 ENE 40,386 74,856 119,073 152,175 176,338 562,828 E 41,290 118,335 156,720 200,581 208,394 725,320 ESE 37,861 121,515 144,267 54,180 34,361 392,184 SE 41,873 111,946 87,735 236,426 379,990 857,970 SSE 12,197 98,326 481,703 1,380,249 1,218,170 3,190,645 S 20,621 135,211 1,164,596 3,732,339 3,164,306 8,217,073 SSW 30,318 202,605 395,389 922,649 1,034,467 2,585,428 SW 30,796 183,372 276,902 197,362 246,076 934,508 WSW 27,723 64,428 209,197 109,102 85,849 496,299 W 16,925 32,026 50,974 61,380 57,384 218,689 WNW 14,036 32,528 54,577 57,977 29,719 188,837 NW 13,421 32,572 54,557 24,046 22,317 146,913 NNW 12,286 31,660 32,569 27,599 34,374 138,488 Total 390,550 1,319,894 3,352,522 7,314,470 6,851,276 19,228,712 Q67. Did the NRC review the methodology and assumptions Entergy used in projecting the 2035 permanent and transient population?
A67. (LAP, JLR) Yes. The NRC Staff performed an independent review of Entergys methodology and assumptions, and the results of that review are summarized in Appendix G of the December 2010 IPEC FSEIS.
36
Q68. What conclusion did the NRC Staff reach with respect to the year-2035 projected population used by Entergy in the IPEC SAMA analysis, and on what basis?
A68. (LAP, JLR) In its FSEIS, the Staff concluded that Entergys methods and assumptions for estimating population [are] reasonable and acceptable for the purposes of the SAMA evaluation. Dec. 2010 FSEIS Vol. 3, App. G at G-20 (NYS000133I). Section G.2.3 of the FSEIS discusses Entergys population projections at length, including Entergys methodology and basis for adjusting for transients - with which the Staff concurred. See id. at G-25. Section G.2.3 also summarizes the results of an independent assessment of the population data within a 50-mile radius of IPEC performed by Sandia using the SECPOP2000 computer program. SECPOP2000 calculates estimated population and economic data about any point (specified by longitude and latitude) that lies within the continental United States. The population data in SECPOP2000 are based on 2000 U.S. Census Bureau data. The year 2000 population estimated by SECPOP2000 is 16,800,272, which is comparable to Entergys year 2000 estimate of the total permanent population within the 50-mile radius (16,914,178). Id.
Sandia also performed two analyses of projected population growth to the year 2035, and determined that Entergys projected population growth was reasonable. Dec. 2010 FSEIS Vol. 3, App. G at G-25 (NYS000133I). These analyses are described in Section G.2.3 of the FSEIS. Id.
Based on these supplemental analyses, the Staff and Sandia confirmed that Entergys population data and projected population growth analysis provide reasonable (and slightly conservative) population values for its SAMA analysis. Id.
37
VI. REBUTTAL TO NYSS AND DR. SHEPPARDS CLAIMS A. Census Undercount Q69. Please summarize the stated bases for Dr. Sheppards claim that Entergy has underestimated the population likely to be living within 50 miles of IPEC in the year 2035 by not accounting for census undercount.
A69. (LAP, KRO, GAT, JLR) According to Dr. Sheppard, census undercount refers to the persistent undercount of portions of the population by the U.S. Census Bureau in the decennial census. In particular, minorities and the poor are undercounted at higher rates than other populations. Sheppard Testimony at 10-11 (NYS000207). Dr. Sheppard contends that census undercount causes the 2000 census data relied upon by Entergy in its SAMA analysis to give an artificially low count of the actual population within 50 miles of IPEC. Id. at 11-12. Dr. Sheppard calculates an overall estimated undercount of 1.2% in the 50-mile radial region for the year 2000, which equates to an underestimation of the 2035 population by 231,632 persons. See id. at 12-13.
Q70. Upon what documents does Dr. Sheppard rely in support of this claim?
A70. (JLR) Dr. Sheppard relies principally on Exhibit NYS000213, U.S. Census Monitoring Board Presidential Members, Final Report to Congress (Sept. 1, 2001) (Census 2001 Final Report to Congress), in support of his census undercount claim. See Sheppard Report at 7 (NYS000209). Exhibit NYS000213 relies in part on data from the Census Bureaus March 2001 Accuracy and Coverage Evaluation (A.C.E.), which discusses the results of the 2000 census. The methodology used in and the results of the March 2001 A.C.E. are summarized in the U.S. Census Bureau publications Technical Assessment of A.C.E. Revision II (Mar. 12, 2003) (A.C.E.
Revision II Technical Assessment) (ENT000016) and Accuracy and Coverage Evaluation of 38
Census 2000: Design and Methodology (Sept. 2004) (A.C.E. Design and Methodology)
(ENT000017).
In his report, Dr. Sheppard cites two additional documents to support his assertion that census undercount is a well-recognized problem: Exhibit NYS000212, J.G. Robinson, B. Ahmed, P.D. Gupta and K.A. Woodrow, Estimation of Population Coverage in the 1990 United States Census Based on Demographic Analysis, Journal of the American Statistical Association, Vol. 88, No. 423 (Sept. 1993); and Exhibit NYS000214, J.G. Robinson, ESCAP II: Demographic Analysis Results, Executive Steering Committee for A.C.E. Policy II, Report No. 1 (Oct. 13, 2001) (ESCAP Report). See Sheppard Report at 4-5.
Q71. Have you reviewed those documents?
A71. (JLR) Yes, I have reviewed Exhibits NYS000212, NYS000213, and NYS000214.
Q72. How does Dr. Sheppard use those documents to support his census undercount argument?
A72. (JLR) The data from the March 2001 A.C.E. indicated a 1.18% net undercount for Census 2000. A.C.E. Revision II Technical Assessment at iii (ENT000016). This 1.18%
undercount is cited in Dr. Sheppards testimony and is referenced in Exhibit NYS000213, upon which Dr. Sheppard relies. See Sheppard Testimony at 12 (NYS000207); Census 2001 Final Report to Congress at 31 (NYS000213).
Q73. In your professional opinion, do the documents Dr. Sheppard relies upon support his argument?
A73. (JLR) No. Exhibit NYS000212 was published in 1993 and pertains only to the 1990 decennial census conducted by the U.S. Census Bureau. As such, it does not address potential population undercount in the 2000 decennial census data used by Entergy in its SAMA analysis and 39
has no relevance here. The conclusions regarding census undercount contained in Exhibits NYS000213 and NYS000214, although germane to the 2000 census, have been superseded by more recent Census Bureau documentation that Dr. Sheppard fails to acknowledge in either his testimony or report. In this regard, the references cited by Dr. Sheppard contain obsolete information relative to the issue of census undercount and, therefore, offer no basis for Dr. Sheppards argument. In fact, as discussed below in Answers 75 and 76, subsequent Census Bureau publications identified significant errors in the March 2001 A.C.E. results and concluded that the 2000 census actually resulted in a population overcount - not an undercount as Dr. Sheppard asserts.
Q74. Please describe the March 2001 A.C.E. effort.
A74. (JLR) As a result of the acknowledged undercounting of the population in prior censuses, the U.S. Census Bureau conducted the March 2001 A.C.E. with the expectation that it could be used to adjust the Census 2000 results for all non-apportionment purposes if it improved the census data. A.C.E. Revision II Technical Assessment at i (ENT000016). The A.C.E. was designed to serve two purposes: (1) to measure the net coverage of the population, both in total and for major subgroups, and (2) to provide data that could serve as the basis for correcting the census counts for such uses as Congressional redistricting, state and local redistricting, funds allocation and governmental program administration. Foreword to A.C.E. Design and Methodology (ENT000017). As noted above, the March 2001 A.C.E. estimates indicated a 1.18% net undercount for Census 2000. A.C.E. Revision II Technical Assessment at iii.
Q75. Subsequent to the issuance of the March 2001 A.C.E. results, did the Census Bureau express any concerns about the quality or integrity of those results?
A75. (JLR) Yes. Indeed, the ESCAP report that Dr. Sheppard relies upon acknowledges that the Executive Steering Committee for A.C.E. Policy recommended against adjusting the 2000 40
census data based on the A.C.E. because of a broad overarching concern that A.C.E. estimates differ[ed] substantially with the estimates derived from Demographic Analysis, another type of population-estimation methodology. ESCAP Report at 1 (NYS000214). Consequently, the U.S.
Census Bureau conducted further research to produce a more complete revision of the estimates that possibly would be used to adjust the census base used in the intercensal (i.e., between decennial censuses) estimates.
Q76. What were the results of those Census Bureau research efforts?
A76. (JLR) The Census Bureau discovered substantial errors in the March 2001 A.C.E.
survey. Significantly, it concluded that [t]he March 2001 A.C.E. estimates of Census 2000 coverage were determined to be unacceptable because A.C.E. failed to measure a significant number of erroneous census enumerations. A.C.E. Revision II Technical Assessment at 1 (emphasis added) (ENT000016) .
Research efforts undertaken to correct those errors, referred to as A.C.E. Revision II, resulted in dramatically improved coverage estimates, compared with the March 2001 A.C.E.
estimates. U.S. Census Bureau, Decision on Intercensal Census 2000 Estimates at 2 (Mar. 12, 2003) (ENT000018). As reported by the Census Bureau, [t]he results of A.C.E. Revision II are substantially different from those of March 2001, changing the estimated net coverage of the total household population from a net undercount of 1.18 percent to a net overcount of 0.49 percent. Id.
(emphasis added).
Q77. Did the Census Bureau adjust the 2000 census data based on the A.C.E. Revision II results?
A77. (JLR) No. The U.S. Census Bureau decided not to change the base for its intercensal population estimates due to certain limitations in the A.C.E. Revision II methodology, but 41
nonetheless noted that the A.C.E. Revision II estimates are dramatically superior to the March 2001 A.C.E. estimates (relied on by Dr. Sheppard). A.C.E. Revision II Technical Assessment at ii (ENT000016).
Q78. In view of the above, is it your conclusion that Entergys use of the unadjusted 2000 census data is reasonable for purposes of the IPEC SAMA analysis?
A78. (JLR) Yes. In fact, it is conservative, because the U.S. Census Bureau did not adjust the estimated base 2000 population for the overcount identified by A.C.E. Revision II, and Dr.
Sheppard is wrong in arguing to the contrary.
Q79. Putting aside the issue of census overcount or undercount, do federal, state, and local governments routinely use population data as it is reported by the U.S. Census Bureau?
A79. (JLR) Yes. Federal, state, and local governments routinely use population data as it is reported by the U.S. Census Bureau for a variety of purposes. As noted above, those purposes include Congressional redistricting, state and local redistricting, funds allocation, and governmental program administration. Other examples include state and county population projections used for planning, and include emergency planning, zoning, infrastructure planning, economic analysis, and housing analysis. In addition, federal and state agencies routinely rely upon reported U.S. census data in assessments performed to comply with NEPA and other legal or regulatory obligations.
Q80. Please provide some specific examples of usage of reported census population data for NEPA or other similar administrative applications.
A80. (JLR) The following are representative examples of federal agencies consideration of such data in performing their assessments:
- The NRC recommends the utilization of the latest decennial census data to analyze the population distribution within the vicinity of a proposed nuclear power plant. See, e.g., NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants at 2.5.1-1 (Oct. 1999) (ENT000019);
42
NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Ch. 2, Rev. 3, at 2.1.3-1, 2.1.3-5 (Mar.
2007) (ENT000020); Regulatory Guide 1.206, Combined License Applications for Nuclear Power Plants at C.I.2-3 (June 2007) (ENT000021); Regulatory Guide 1.70, Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Rev. 3, at 2-3 (Nov. 1978) (ENT000022); Regulatory Guide 4.2, Preparation of Environmental Reports for Nuclear Power Stations, Rev. 2, at 2-1 (July 1976) (ENT000023).
- The U.S. Environmental Protection Agency (EPA) recommends the use of reported census data to prepare risk management plans required by the agencys Clean Air Act Chemical Accident Prevention regulations. See U.S. EPA, A Checklist for Submitting Your Risk Management Plan (RMP) for Chemical Accident Prevention at 3, 4, 6, 7 (Sept. 2009) (ENT000024); U.S. EPA, Guidance for Conducting Risk Management Program Inspections under Clean Air Act Section 112(r) at D-18 (Feb. 11, 2011) (ENT000025).
- The EPA also recommends the use of census data to determine the applicability of National Pollutant Discharge Elimination System permits required by the Clean Water Act to a municipality or county based on its population size. See U.S. EPA, Protocol for Conducting Environmental Compliance Audits Under the Stormwater Program at 3, 4, 39 (Jan. 2005) (ENT000026).
Significantly, none of the foregoing agency guidance documents indicate the need to adjust for any possible census undercount (or overcount). This further reinforces the conclusion that use of reported U.S. census data as is in a SAMA analysis - a NEPA-derived requirement - is entirely reasonable for that purpose.
B. Commuters from Outside the 50-Mile SAMA Analysis Region Q81. Please summarize the stated bases for Dr. Sheppards claim that Entergy has underestimated the population likely to be living within 50 miles of IPEC in the year 2035 by not accounting for certain commuters.
A81. (LAP, KRO, GAT, JLR) Dr. Sheppard claims that, in accounting for the transient population, Entergy counted only tourists and business travelers, not commuters who enter and remain within the 50-mile radius of IPEC on a daily basis, and who also are just as at risk in the event of a severe accident as are permanent residents. Sheppard Testimony at 14 (NYS000207).
43
He further claims that it is possible to estimate the number of commuters using U.S. Census Bureau data on county-to-county commuter flows from 2000. Id. Using the method described in his report and prefiled testimony, Dr. Sheppard estimates that 995,778 commuters will enter the 50-mile radius region on an average day in 2035, a purported 5.18% increase in Entergys projected 2035 population. Id. at 16.
Q82. Do you agree with Dr. Sheppard that commuters are just as at risk as permanent residents in the event of a severe accident, particularly in relation to the key risk metrics considered in the MACCS2-based SAMA analysis?
A82. (LAP, KRO, GAT, JLR) No. As discussed previously in Answers 60 and 61, commuters are not just as at risk as permanent residents for the following reasons:
- Unlike permanent residents, commuters are not always within the 50-mile region and thus may not be within the region at the time of a severe accident.
- Commuters evacuated or relocated from within the 50-mile region would be able to return to their home immediately and thus would not incur temporary housing, food or moving costs.
- Commuters do not have personal property within the 50-mile region that would be subject to decontamination or interdiction.
Q83. Assuming, for the sake of argument, that Entergy decided to include commuters in its population projections, has Dr. Sheppard provided an appropriate estimate of the daily commuter population?
A83. (LAP, JLR) No. We have carefully examined Dr. Sheppards report and methods and were able to duplicate the values in Table 1 of his report using the input data he cited and the methods he described. Essentially, Dr. Sheppard is attempting to change the SAMA analysis population distribution to reflect the work day. But, as explained below, his methods are flawed in two major respects, which caused him to significantly overstate the commuter population.
44
First, Dr. Sheppards analysis classifies and counts each person from outside the 50-mile region who works within the region as a commuter, regardless of the persons residence county. Dr.
Sheppard relies on data from the U.S. Census Bureau, County-to-County Worker Flow Files, which list the work county for each of the residents of every county in the country. Thus, for example, Dr.
Sheppards analysis counts 53 residents of San Diego County, California, as commuters into Fairfield County, Connecticut; 19 residents of Anchorage, Alaska, as commuters into Queens County, New York; and 16 residents of Honolulu County, Hawaii, as commuters into Essex County, New Jersey. Residence County to Workplace County Flows at 25, 135, 426 (NYS000215).
If accounting for daily commuters was appropriate, it would not be reasonable to assume that people from more than 150 miles - or 3,000 miles - away commute into the region on a daily basis.
Rather, these people would have to secure overnight lodging when visiting the region and would thus be considered business travelers, which have already been included as part of the transient population values used by Entergy in the SAMA analysis. See Dec. 2010 FSEIS Vol. 3, App. G at G-25 (NYS000133I).
Second, Dr. Sheppard indicates that we must use the most accurate inputs possible.
Sheppard Report at 7. But an accurate accounting of commuters would also need to consider commuters out of the 50-mile region surrounding IPEC. The U.S. Census Bureaus County-to-County Worker Flow Files also include data for commuters and business travelers out of the 50-mile region, but Dr. Sheppard does not consider such data in either his testimony or report.
Q84. Did you attempt to perform an analysis to address the above-identified errors in Dr. Sheppards calculations?
A84. (LAP, JLR) Yes. We performed an analysis that corrected the above errors in Dr.
Sheppards analysis to determine what his projected population should have been, accepting, for the 45
sake of argument, his assumptions that Entergy should have considered census undercount and commuters in its population projection. See L. Potts and J. Riggs, Rebuttal Commuter Analysis (Jan. 2012) (Rebuttal Commuter Analysis) (ENT000027). The revised analysis considered only residents of Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, and Vermont with work locations in the 50-mile region as commuters into the region. Id. at 9. It also considered residents in the 50-mile region who work outside the 50-mile region as commuters out of the region. Id. at 12-13.
Table 4 below summarizes the results of the revised analysis. The Year 2035 Net Commuters Into the 50-mile Region column reflects the number of commuters into the 50-mile region minus the number of commuters out of the region. Therefore, a negative number in this column indicates that more commuters left the 50-mile region than entered it. The Year 2035 Revised Total Population column incorporates information from Table 1 of Dr. Sheppards report
- Resident Pop plus Transient Pop plus Undercount (see Sheppard Report at 8 (NYS000209))
- plus the net commuter total that Entergy calculated in the second column.
In his report, Dr. Sheppard indicates that his improved estimate of 20,456,285 persons is 6.38% larger than Entergys 2035 projected population of 19,228,712. Sheppard Report at 7 (NYS000209). However, the commuter analysis reflected in Table 4 below results in a revised total population estimate - which also includes, for the sake of argument, the 231,631 people Dr.
Sheppard claims were undercounted - of 19,571,172, which is only 1.78% larger than Entergys original projection of 19,228,712 persons. This, in our opinion, is a negligible increase in the projected 2035 population. This revised population estimate reflects a commuter-related population increase of only 0.58% (110,663 net commuters / 19,228,712 total population), in contrast to Dr.
Sheppards posited commuter-related population increase of 5.18%.
46
Table 4. Analysis of Net Projected Commuters Into the IPEC SAMA Analysis 50-Mile Radial Region in 2035 by County (Source: Rebuttal Commuter Analysis at 15)
Year 2035 Net Year 2035 Revised Total County Commuters Into the Population 50-mile Region Fairfield, CT 23,923 962,452 Litchfield, CT -11,748 79,947 New Haven, CT -9,518 291,776 Bergen, NJ 6,475 1,128,408 Essex, NJ 24,192 927,673 Hudson, NJ -34,852 681,477 Middlesex, NJ 128 19,714 Morris, NJ 40,178 582,319 Passaic, NJ -42,499 530,087 Somerset, NJ 723 22,504 Sussex, NJ -46,672 163,022 Union, NJ -10,779 556,090 Warren, NJ -99 701 Bronx, NY -164,938 1,527,138 Dutchess, NY -14,515 277,624 Kings, NY -249,536 2,451,797 Nassau, NY -61,684 1,200,669 New York, NY 1,355,065 2,969,259 Orange, NY -32,861 425,227 Putnam, NY -30,570 93,285 Queens, NY -460,013 2,657,872 Richmond, NY -69,735 372,754 Rockland, NY -30,721 256,695 Suffolk, NY -24,253 302,362 Sullivan, NY -2,740 32,371 Ulster, NY -12,425 120,469 Westchester, NY -25,162 919,576 Pike, PA -4,703 17,902 Total 110,663 19,571,172 47
Q85. Is it possible to determine whether the population increases attributed by Dr.
Sheppard to census undercount and commuters, if assumed to be valid, would materially affect Entergys SAMA analysis results?
A85. (KRO, GAT) Yes. This can be accomplished by performing a sensitivity analysis using MACCS2.
Q86. What is a sensitivity analysis in this context?
A86. (KRO, GAT) A sensitivity analysis evaluates to what degree code outcomes or outputs are sensitive to changes in the code assumptions or inputs.
Q87. Did you perform a sensitivity analysis using MACCS2?
A87. (KRO, GAT) Yes. We performed a sensitivity case for the IP2 SAMA analysis to evaluate the potential impacts of the population increase posited by Dr. Sheppard in his report and testimony. See MACCS2 Population Sensitivity Case (ENT000006). The sensitivity case did not correct for the errors in Dr. Sheppards commuter population estimate (as discussed in Answer 83).
Instead, the MACCS2 sensitivity case incorporated Dr. Sheppards census undercount value and adjusted his commuter population value to account for the amount of time commuters would be expected to be within the 50-mile SAMA analysis region. Id.
Specifically, for the sensitivity case, we incorporated Dr. Sheppards undercount and commuter population estimates into the population distribution of the IPEC MACCS2 SITE file.
Dr. Sheppards population estimates were allocated to different grid locations in the 50-mile region based on the county values provided in Table 1 of Dr. Sheppards report. See Sheppard Report at 8 (NYS000209). One-hundred percent of the alleged census undercount population (231,631) was added to the existing IPEC SAMA population estimate, and 50% of the commuter (497,889, or 50%
of 995,778) population was included. Id. We reduced the commuter estimate by 50%, because 48
commuters would be expected to be in the 50-mile region only one-third to one-half of the time.
Also, as discussed previously in Answer 61, commuters into the 50-mile region are reasonably assumed not to have tangible property (e.g., a house) in the 50 mile-region (in contrast to permanent residents). Thus, using this approach, we added an additional 729,521 persons to the 50-mile radial population, a population increase of approximately 3.8%. Id.
Q88. What were the results of this sensitivity analysis?
A88. (KRO, GAT) The results of the sensitivity case show an increase of PDR and OECR of 3.1% and 3.2% respectively. MACCS2 Population Sensitivity Case (ENT000006). Performing a similar sensitivity for IP3 would be expected to result in similar increases. These are very small increases to PDR and OECR.
Q89. Would the results from this sensitivity analysis, which ignores the errors identified in Dr. Shepherds analysis, impact the conclusions of the SAMA analysis?
A89. (KRO, GAT, LAP) No. Even ignoring the errors in Dr. Shepherds analysis, the conclusions of the SAMA analysis would not be impacted by including the alleged census undercounts and commuter population. As noted above in Answer 46 and Figure 1, for a SAMA candidate to be cost-effective, the estimated benefit of the SAMA (expressed in dollars) must be larger than the estimated cost of its implementation. For example, Entergy identified SAMA candidate IP2 SAMA 025 (Improve MSIV design) as not cost-effective. See NL-09-165, Attach.
1 at 30 (ENT000009). For IP2 SAMA 025 to become cost effective, its benefit would have to increase by 11%. See id. Compared to the other SAMA candidates that are not cost-effective, at 11%, IP2 SAMA 025 has the smallest margin between the current benefit and the increased benefit to become cost effective. Thus, even if the benefit of IP2 SAMA 025 were increased by a full 3.2%
(i.e., the higher of the increase factors associated with the sensitivity case results for PDR and 49
OECR incorporating Dr. Sheppards assumptions), the SAMA candidate would still not be cost-beneficial. Accordingly, there is no material impact to the results of IPEC SAMA analysis.
VII. CONCLUSIONS Q90. Please summarize your conclusions with respect to NYSs claim that Entergy has materially underestimated the 2035 population used in its SAMA analysis by not accounting for census undercount and commuters from outside the 50-mile radial region.
A90. (LAP, KRO, GAT, JLR) We conclude that NYSs claims in NYS-16B lack factual and technical merit. Entergy reasonably and appropriately relied upon published 2000 U.S. Census Bureau data - data that were not adjusted for any census undercount or overcount. Federal, state, and local agencies commonly rely upon published U.S. census data in assessments performed to comply with their legal or regulatory obligations. In addition, the documents that Dr. Sheppard relies upon contain conclusions regarding census undercount that have been discredited and superseded by more recent U.S. Census Bureau documentation that Dr. Sheppard fails to acknowledge in either his testimony or report. The more recent documentation actually indicates that the 2000 census data relied upon by Entergy slightly overcounted the total population.
We also conclude that Entergy conservatively included appropriate transient populations for the entire 50-mile region within the SAMA analysis, including tourists and business travelers.
Defining the transient population to include tourists and business travelers was consistent with industry guidance. But even if we were to assume for the sake of argument that commuters should be included in the transient population, Dr. Sheppards commuter population calculations are flawed and significantly overstate the net commuter population into the 50-mile SAMA analysis region.
50
Notwithstanding the shortcomings of Dr. Sheppards methodology and assumptions, our MACCS2 sensitivity analysis shows that even if we were to increase the year 2035 population value as suggested by Dr. Sheppard (i.e., adjusting for census undercount and commuters), it would have no material impact on the results of the IPEC SAMA analysis.
Q91. Does this conclude your testimony?
A91. (LAP, KRO, GAT, JLR) Yes.
Q92. In accordance with 28 U.S.C. § 1746, do you state under penalty of perjury that the foregoing testimony is true and correct?
A92. (LAP, KRO, GAT, JLR) Yes.
Executed in accord with 10 C.F.R. § 2.304(d)
Lori Ann Potts Senior Consulting Engineer to Entergy License Renewal Services Arkansas Nuclear One ANO-GSB-45 1448 SR 333 Russellville, AR 72802 Phone: (479) 858-3529 E-mail: lpott90@entergy.com Executed in accord with 10 C.F.R. § 2.304(d)
Kevin R. OKula Advisory Engineer URS Safety Management Solutions LLC 2131 South Centennial Avenue Aiken, SC 29803-7680 Phone: (803) 502-9620 E-mail: kevin.okula@wsms.com 51
Executed in accord with 10 C.F.R. § 2.304(d)
Grant A. Teagarden Manager, Consequence Analysis ERIN Engineering and Research, Inc.
2105 S. Bascom Avenue Suite 350 Campbell, CA 95008 Phone: (408) 559-4514 E-mail: gateagarden@erineng.com Executed in accord with 10 C.F.R. § 2.304(d)
Jerry L. Riggs GIS Specialist Enercon Services, Inc.
6525 North Meridian, Suite 400 Oklahoma City, OK 73116 Phone: (405) 722-7693 E-mail: jriggs@enercon.com March 28, 2012 52 DB1/ 69123363.8