ML14224A568
| ML14224A568 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/12/2014 |
| From: | Lampert M - No Known Affiliation |
| To: | Nadiyah Morgan Office of Nuclear Reactor Regulation |
| References | |
| MF2656 | |
| Download: ML14224A568 (32) | |
Text
NRR-PMDAPEm Resource From: Mary Lampert [mary.lampert@comcast.net]
Sent: Tuesday, August 12, 2014 9:50 AM To: NRCExec@nrc.gov Cc: Morgan, Nadiyah
Subject:
Pilgrim Watch Supplement to its KLD Petition 08.11.14; Attachment, KLD PNPS Memo Population Update 2014; Attachment-KLD Pilgrim Population Update Report 2013.
Attachments: PILGRIM WATCH SUPPLEMENT TO ITS KLD PETITION 08 11 14.pdf; KLD_PNPS_Memo_Population_Update_2014.pdf; KLD_Pilgrim_Population_Update_Report_
2013_Rev0.pdf Hello:
Please find Pilgrim Watch Supplement to its KLD Petition 08.11.14; Attachment, KLD PNPS Memo Population Update 2014; Attachment-KLD Pilgrim Population Update Report 2013.
If you have any difficulty opening the documents, please call Mary Lampert at 781-934-0389.
Courtesy of receipt by return email appreciated.
On August 11, 2014, we tried to email these documents and had difficulty. We understand only some went through and the rest remained stuck in the outbox. We discovered the reason was that the KLD PNPS Memo Population Update 2014 was in Rich Txt that was more than 23,000 KBs. Once we turned it into a Pdf file, the problem we hope is resolved.
Apologies for any additional work on your part and certainly confusion.
Thank you, Mary 1
Hearing Identifier: NRR_PMDA Email Number: 1491 Mail Envelope Properties (107b01cfb634$439cae10$cad60a30$)
Subject:
Pilgrim Watch Supplement to its KLD Petition 08.11.14; Attachment, KLD PNPS Memo Population Update 2014; Attachment-KLD Pilgrim Population Update Report 2013.
Sent Date: 8/12/2014 9:49:40 AM Received Date: 8/12/2014 9:55:22 AM From: Mary Lampert Created By: mary.lampert@comcast.net Recipients:
"Morgan, Nadiyah" <Nadiyah.Morgan@nrc.gov>
Tracking Status: None "NRCExec@nrc.gov" <NRCExec@nrc.gov>
Tracking Status: None Post Office: lampert@comcast.net Files Size Date & Time MESSAGE 819 8/12/2014 9:55:22 AM PILGRIM WATCH SUPPLEMENT TO ITS KLD PETITION 08 11 14.pdf 359791 KLD_PNPS_Memo_Population_Update_2014.pdf 868077 KLD_Pilgrim_Population_Update_Report_2013_Rev0.pdf 1239957 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
August 11, 2014 Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 By Mail & Email: NrcExecSec@nrc.gov PILGRIM WATCHS AUGUST 8, 2014 SUPPLEMENT TO ITS AUGUST 30, 2013 2.206 PETITION TO MODIFY, SUSPEND, OR TAKE ANY OTHER ACTION TO THE OPERATING LICENSE OF PILGRIM STATION UNTIL THE NRC CAN ASSURE EMERGENCY PREPAREDNESS PLANS ARE IN PLACE TO PROVIDE REASONABLE ASSURANCE PUBLIC HEALTH & SAFETY ARE PROTECTED IN THE EVENT OF A RADIOLOGICAL EMERGENCY PILGRIM NUCLEAR POWER STATIONS ANNUAL POPULATION UPDATE - 2014 I. INTRODUCTION Pursuant to §2.206 of Title 10 in the Code of Federal Regulations, Pilgrim Watch (Hereinafter PW) on behalf of its members and members of the Town of Duxbury Nuclear Advisory Committee, Pilgrim Coalition, Project for Entergy Accountability, Cape Cod Bay Watch, EcoLaw, Beyond Nuclear, Greenpeace, and others submits this supplement to its request that the Nuclear Regulatory Commission (NRC) institutes a proceeding to modify, suspend or take any other action1 as may be proper to the operating license of Pilgrim Station in order that the NRC can assure Pilgrims Radiological Emergency Plan and Standard Operating Procedures/Guidelines are based on accurate and credible Evacuation Time Estimates (ETEs).
The new and significant information petitioners add to the KLD petition is based on the July 31, 2014 MEMO from KLD, Kevin Weinisch, Regarding Pilgrim Nuclear Power Station 1
NRC Enforcement actions include: notices of violation, civil penalties, orders, notice of nonconformance, confirmatory action letters, letters of reprimand, and demand for action.
2 Annual Update-2014. (Attached) The MEMO simply shows updated population figures that indicate a small increase in population. The updated 2014 report is not completed. But the numbers in it make clear that the final 2014 Update will follow the same flawed format, methodology and assumptions that were used in the KLD Pilgrim Evacuation Estimate December 12, 2012 Final Report KLD-TR-510 and its 2013 Pilgrim Nuclear Power Station Annual Population Update, 2013 Whats wrong with KLDs update analyses? The 2013 update failed to learn two fundamental lessons from KLDs Cape Cod Telephone Survey; and unless the NRC orders otherwise, the 2014 update will fail also.
First, the 2013 update used KLDs ridiculously low assumption that only 20% of the shadow evacuation would evacuate. The Cape Cod Telephone Survey shows that the actual number who would choose to evacuate is between 50% and 70%, at the 95% confidence level2.
Second, the Cape Telephone Survey also showed that the shadow evacuation extends to 25 miles not 15 miles, as assumed by KLD.
Section IV of Appendix E to 10 CFR part 50 and Section 5.4, Reviews and Updates of NUREG/CR-7002 says that:
If at any time during the decennial period, the EPZ permanent resident population increases such that it causes the longest ETE value for the 2-mile zone or 5-mile zone, including all affected Emergency Response Planning Areas, or for the entire 10-mile EPZ to increase by 25 percent or 30 minutes, whichever is less, from the nuclear power reactor licensee's currently NRC approved or updated ETE, the 2
Pilgrim Watch August 30, 2013 filing in this proceeding fully discussed the KLD Cape Telephone Survey and the KLD telephone survey in the EPZ and its 15 mile shadow It showed that if telephone survey respondents were told that the questions regarded a radiological incident, and not simply an unspecified incident like the Sandias and the EPZ survey, far more respondents said they would evacuate. This is expected because the public fears radiation the most, especially so since Fukushima.
3 licensee shall update the ETE analysis to reflect the impact of that population increase. The licensee shall submit the updated ETE analysis to the NRC under § 50.4 no later than 365 days after the licensee's determination that the criteria for updating the ETE have been met and at least 180 days before using it to form protective action recommendations and providing it to State and local governmental authorities for use in developing offsite protective action strategies.
If the shadow evacuation estimate were correctly to assume either (i) that 50% to 70% of the shadow population would try to evacuate, or (ii) that the actual shadow evacuation zone would extend to 25 miles then the increase in the number of evacuees will increase KLDs base line ETE analysis by more than 30 minutes and an updated ETE for Pilgrim Station will be required.
II. DOCUMENTS PETITIONERS RELY UPON x MEMO from KLD, Kevin Weinisch, Regarding Pilgrim Nuclear Power Station Annual Update-2014, July 31, 2014 x KLD Pilgrim Nuclear Power Station Annual Population Update - 2013, September 25, 2013 x KLD Pilgrim Evacuation Estimate December 12, 2012, Final Report KLD-TR-510014 x U.S. Census Bureau QuickFacts x Pilgrim Watchs 2.206 Petition To Modify, Suspend, Or Take Any Other Action To The Operating License Of Pilgrim Station Until The NRC Can Assure Emergency Preparedness Plans Are In Place To Provide Reasonable Assurance Public Health And Safety Are Protected In The Event Of A Radiological Emergency, August 30, 2013 x Amendment And Supplement To Pilgrim Watchs 2.206 Petition To Modify, Suspend, Or Take Any Other Action To The Operating License Of Pilgrim Station Until The NRC Can Assure Emergency Preparedness Plans Are In Place To Provide Reasonable Assurance Public Health & Safety Are Protected In The Event Of A Radiological Emergency, November 22,2013
4 III. FACTUAL BASIS The following analysis is based on KLD Pilgrim Nuclear Power Station Annual Population Update - 2013, September 25, 2013, and is the model that KLD will follow for the 2014 update unless NRC steps in and requires a reliable and honest analysis.
- 1. The ETE is the time required to evacuate the zone in question. The ETE depends on the number of evacuees, assumes that the entire zone is evacuated, and also assumes a 20% shadow evacuation of those in the 10-15 mile zone.
- 2. Table 6 from KLDs 2013 update shows that an updated ETE will be required if the number of evacuees increases by 25,258 from KLDs base assumption of 109,891 to 135,077.
KLD determined that an increase in slightly more than 25,000 evacuees would increase the full EPZ 90th Percentile ETE by 30 minutes. Obviously, a larger increase in the number of evacuees would result in even longer ETEs.
2013 Update, pg., 11
5
- 3. In the 2013 Population Update Analysis, the only increases in the number of evacuees that KLD considered were those resulting from increases in the populations of the EPZ and the 10-15 mile shadow region. The ETE is critically dependent on the percentage of those in the shadow region that will choose to evacuate.
- 4. Table 4 shows KLDs estimate of the population of the shadow region, within 15 miles of Pilgrim. Its ETE estimate assumed that only 20% (16,077) of the 2013 Extrapolated Population (80,387) would choose to evacuate. It also unrealistically assumed that no one more than 15 miles from Pilgrim would evacuate.
2013 Update, pg., 7
- 5. The recent KLD Cape Cod Telephone Survey (discussed at length in Pilgrim Watchs August 30, 2013 2.206 Petition pending before the NRC, pages 5-13) showed that the 20%
6 assumption is ridiculously low, and that the actual number who would choose to evacuate at the 95% confidence level is between 50% and 70%. Seventy (70) percent of those within 25 miles said they would evacuate if they were told that there was an incident at the Pilgrim Nuclear Power Station; and fifty (50) percent of those within 25 miles of Pilgrim would evacuate, even if they were told that they were not in Pilgrims Emergency Planning Zone. KLDs Cape Telephone Survey unequivocally showed that ETEs shadow evacuation assumption is fatally wrong. Far more than 20% of those not instructed to evacuate will voluntarily evacuate anyway.
- 6. The recent Cape Cod Telephone Survey showed that actual number of evacuees from the 10-15 mile shadow zone would be far more than the 16,077 estimated by KLD.
x 70% (56,217) of the 2013 Extrapolated 50% Population (80,387) that said they would evacuate if there was an incident at Pilgrim is 40,194 more evacuees than KLD assumed.
x 50% (40,194) of the 2013 Extrapolated Population that that said they would evacuate even if told they were not in the EPZ is 24,117 more evacuees than KLD assumed.
Taking only the more conservative 50%, the increased number of evacuees is very, very close to the 25,258 additional evacuees that KLD admitted would require an updated ETE. If the actual number of shadow region evacuees was only 51.42% of the shadow region population, an updated ETE would be required.
Splitting the difference between the 50% and 70% in the Cape Telephone Survey responses, if 60% of those in the 10-15 mile zone chose to evacuate, the additional number of evacuees would be well over KLDs 25,258 number requiring an update, If 70% choose to evacuate, the number of evacuees would clearly require an update.
7
% of estimated 2013 Shadow Added Evacuees Updated ETE Required Population, (80,387) If population exceeds 25,258 20% = 16,077.4 0 No 50% = 40,193.5 24,117 Close 60% = 48,232.2 32,155 Yes 70% = 56,270.89 40,194 Yes Sources:
Table 4 Estimated 2013 shadow population = 80,387 Table 6: updated ETE required if evacuees increases by 25,258
- 7. Shadow Region out to 25 miles: KLDs Cape Cod Telephone Survey also showed that the ETEs assumption that there would be shadow evacuation only from the 10-15 mile region is incorrect. The Cape survey showed that 50% to 70% of the respondents throughout the Cape, out to 25 miles, would choose to evacuate. The number of evacuees from outside the official 15 mile shadow region would also be well over the 25,258 more required for an ETE.
Any realistic ETE must take into account a shadow region that extends out to at least 25 miles. If as little as 20% of the population of either, or only 4% of both, chose to evacuate, the total number of evacuees would increase by more than the 22,258 that KLD admits requires a new ETE analysis.
Barnstable Countys 2010 permanent population3 is 215,888; and the 2013 estimated permanent population is 214,990. (U.S. Census QuickFacts) The KLD Population Estimate included two towns in Barnstable County Bourne and Sandwich (Table 1) with a total population of 40,468, in its 10-15 mile Shadow Region. Subtracting the population of those already counted 3
The census provides permanent population numbers; the summer population approximately doubles the Cape population. If NRC were to insist on a conservative estimate, it would base the population on the largest population, summer.
8 two towns, the ignored population of what should be the Barnstable County Shadow Region is 174,522.
If only 20% of this added Barnstable County population decided to evacuate, there would be 34,904 more evacuees. If 50%, 60%, or 70% decided to evacuate the number of additional evacuees would be respectively 87,261, 104,713 and 122,165. In each case the number of evacuees would far exceed the 25,248 that KLD 2013 admits would require an updated ETE.
Plymouth Countys 2010 population was 494,919 and the 2013 estimate is 501,915.
(U.S. Census QuickFacts) The KLD Population Estimate included 10 towns in its 10-15 mile Shadow Region with a total population of 109,819 (Table 6). Subtracting the population of those ten already counted towns, the ignored population of what should be the 25-mile Plymouth County Shadow Region is 392,096. There are two ignored Norfolk County towns within the 25 mile radius, Cohasset (pop., 7,483) and Weymouth (pop., 54,565), bringing the total ignored shadow evacuation population to 454,144.
If only 20% of this nearly half-million Plymouth County and two Norfolk County town populations, (all within 25 miles) decided to evacuate, there would be 90,828 more evacuees. If 50%, 60%, or 70% decided to evacuate the number of additional evacuees would be respectively 227,072, 272,486, and 317,901. In each case the number of evacuees would far exceed the 25,248 that KLD 2013 admits would require an updated ETE. Indeed, an updated ETE would be required if less than 6% decided to do so.
Barnstable and Plymouth Shadow Evacuation Regions to 25 Miles: The total population of the 25-mile Barnstable County 2013 Shadow Region on one side of Pilgrim is
9 214,990; the total population of the 25-mile Plymouth County and two Norfolk County towns 2013 Shadow Region is 501,915. The total shadow population would be 669,134 - over eight times the 80,387 estimated by KLD (Table 4).
If only 4% of the shadow population out to 25 miles chose to evacuate, there would be 26,765 more evacuees than KLD estimated, exceeding the 25,258 number that KLD admits requires an ETE update; if only 20% (KLDs assumed percentage) were to evacuate, there would be almost 134,000 more evacuees, five times what KLD admits requires an update.
The overall picture emphasizes the total inadequacy of KLDs estimates. In an effort to produce ETEs that the NRC might find acceptable, KLD chose to deal with a population of less than 175,000, the 2010 EPZ population plus the 2010 10-15 mile shadow region population, and to ignore 80% of the latter. The total number of people now in the EPZ and within 25 miles of Pilgrim is 764,908.
What are the almost 600,000 that KLD says will not even try to evacuate supposed to do?
- 8. Incorrect Methodology & Assumptions: The KLD Population Update further underestimates the population demand, the total number of people evacuating, by using the incorrect methodology and making the same inaccurate assumptions that were made in KLD Pilgrim Evacuation Estimate December 12, 2012 Final Report KLD-TR-510014, discussed in Pilgrim Watchs August 30, 2013 petition.
- a. Methodology: Population Update 2013 and 2014 Only Looked At Undifferentiated Permanent Population Data The Update should have looked at increases in population sub-groups. The KLD Pilgrim Evacuation Estimate December 12, 2012 Final Report KLD-TR-510 looked at summer
10 population, transient population, worker population, and the transportation dependent-school children and residents of nursing/ group homes. By doing so, KLD acknowledged that these sub groups are important to consider in estimating evacuation times4.
- b. KLDs Population Update 2013, Like the ETE, Incorrectly Assumes That The Longest 90 Percentile is Scenario 8: Winter, Mid-Day, Mid-Week, Snow Regulations require that an updated ETE must be conducted if population growth is large enough to cause the 90 percentile ETE to increase by 25% or 30 minutes. In order for the Population Update to be valid it must correctly assess the longest scenario. It did not do so.
Pilgrim Watch and DNAC showed in the on-going 2.206 Enforcement Petition that the ETE underestimated traffic flow. It failed to account for chronically heavy traffic over summer weekends that significantly increases travel times; and it underestimated traffic flow during inclement weather. The impact of snow is greatest during peak commuting hours that KLD never studied. Peak Traffic Scenarios must be recalculated to satisfy the requirement.
- c. KLDs Population Update 2013 models the 2-mile zone or 5-mile zone, including all affected Emergency Response Planning area and the entire EPZ.
This conforms to Section IV of Appendix E to 10 CFR part 50 and Section 5.4, Reviews and Updates of NUREG/CR-7002 but it does not conform to reality. The Cape Telephone Survey showed that 50% of the respondents said that they would evacuate anyway even if told that they were not in the EPZ. Therefore it shows that the segmented evacuation will never be followed inside the EPZ, far more than 20% will choose to voluntarily evacuate outside the 2-mile or 5-mile area. Additionally at the Alert Stage of the accident beaches, parks, forests are closed and boaters are told to get off the water. The word of trouble at Pilgrim will rapidly 4
Note that Pilgrim Watchs August 2013 filing showed that KLDs ETE did not properly estimate the numbers and times required to evacuate different sub-groups.
11 spread due to todays rapid communication capability and an unplanned evacuation will begin.
Unplanned evacuations mean an increase in vehicle accidents that will clog the routes when the actual evacuation is called, increasing evacuation times.
IV. CONCLUSION Faulty assumptions and methodology in the KLD Pilgrim Evacuation Estimate December 12, 2012 Final Report KLD-TR-510014 were carried forward in KLD Pilgrim Nuclear Power Station Annual Population Update - 2013 and likewise will infect the 2014 Update. The result is KLD documents that are not credible. There will be much higher levels of congestion, and much longer evacuation times, as our filings in this proceeding showed. Absent an honest and credible ETE, the population does not have reasonable assurance of adequate proptection in the event of an accident. It is time to do better.
Pilgrim should not be operating until a new Population Update and ETE is done. Indeed an updated ETE analysis must be prepared if the EPZ resident population increases such that it causes the 90th percentile ETE for either the 2-mile zone, the 5-mile zone or the entire 10-mile EPZ to increase by 25% or 30 minutes, whichever is less. (Section IV of Appendix E to 10 CFR part 50 and Section 5.4, Reviews and Updates of NUREG/CR-7002). Pilgrim Watch has shown that based on KLDs own Cape Telephone Survey that the EPZ resident population and shadow evacuation exceeds the population number requiring a new study. Properly adding the summer population would further escalate the population figures.
As we concluded in our original August 2013 KLD petition, Judge Rosenthal of the ASLB accurately said that, with one possible exception, the NRC had not granted a section 2.206
12 petitioner the substantive relief it sought for at least 37 years. Judge Rosenthal concluded that, where truly substantive relief is being sought (i.e., some affirmative administrative action taken with respect to the licensee or license), there should be no room for a belief on the requesters part that the pursuit of such a course is either being encouraged by Commission officialdom or has a fair chance of success."5 We truly hope that Judge Rosenthal will be proven wrong and this petition will be granted.
Respectfully submitted on behalf of the Petitioners, Mary Lampert Pilgrim Watch, Director 148 Washington Street Duxbury, MA 02332 Tel 781-934-0389 Email: mary.lampert@comcast.net August 11, 2014 5
Memorandum And Order (Denying Petitions For Hearing), LBP-12-14, July 10, 2012, Additional Comments of Judge Rosenthal ( See NRCs EHD Docket EA-12-05-/12-51)
Memo To: Donna Calabrese From: Kevin Weinisch CC: Karen Larson-Sullivan, Kara ONeill (KLD), Christina Hoffman (KLD), Lorena Moschetta (KLD)
Date: July 31, 2014 Re: Pilgrim Nuclear Power Station Annual Population Update - 2014 Introduction Section IV of Appendix E to 10 CFR part 50 and Section 5.4, Reviews and Updates of NUREG/CR-7002 stipulate:
Licensees shall estimate EPZ [Emergency Planning Zone] permanent resident population changes at least annually during the years between decennial censuses using U. S. Census Bureau data. These estimates shall occur no more than 365 days apart. State/local government population data may also be used, if available. Licensees shall maintain these estimates available for NRC inspection during the period between censuses and shall submit these estimates to the NRC with any updated ETEs [Evacuation Time Estimates].
If at any time during the decennial period, the EPZ permanent resident population increases such that it causes the longest ETE value for the 2-mile zone or 5-mile zone, including all affected Emergency Response Planning Areas, or for the entire 10-mile EPZ to increase by 25 percent or 30 minutes, whichever is less, from the nuclear power reactor licensee's currently NRC approved or updated ETE, the licensee shall update the ETE analysis to reflect the impact of that population increase. The licensee shall submit the updated ETE analysis to the NRC under § 50.4 no later than 365 days after the licensee's determination that the criteria for updating the ETE have been met and at least 180 days before using it to form protective action recommendations and providing it to State and local governmental authorities for use in developing offsite protective action strategies.
Page 1 of 6
Entergy has contracted KLD Engineering, P.C. to estimate annual population changes between the decennial censuses for the Pilgrim Nuclear Power Station (PNPS) in accordance with the aforementioned federal regulations. KLD requests that Entergy and the Offsite Response Organizations (OROs) - the Massachusetts Emergency Management Agency (MEMA), and the Towns of Carver, Duxbury, Kingston, Marshfield and Plymouth - review the methodology and Census growth rates provided below and provide feedback/comments by close of business on August 15, 2014. If no comments are generated during your review, please indicate via e-mail that there are no comments and you approve the methodology and growth rates as documented in this memo. Once approval is received, KLD will proceed with the population estimates.
US Census Growth Rates The population analysis for the 2012 PNPS Evacuation Time Estimates (KLD TR-510, dated December 2012), was performed using 2010 Census population data provided on the U.S. Census Bureau website1.
The Census Bureau QuickFacts2 website provides annual population updates for each state, county, minor civil division (town)3 and municipality in the United States. The most recent update for town growth rates available on the QuickFacts website is for the time period from April 1, 2010 to July 1, 2013. The growth rates for each town within the study area (Emergency Planning Zone - EPZ - plus Shadow Region) provided by QuickFacts are summarized in Table 1. The Census does not provide annual population estimates for the Census Designated Places (CDPs - i.e., North Plymouth) within the study area. The Census boundaries for all towns are shown in Figure 1.
1 www.census.gov 2
http://quickfacts.census.gov/qfd/index.html 3
http://www.census.gov/popest/data/cities/totals/2013/SUB-EST2013.html Page 2 of 6
Table 1. Town Growth Rates from April 1, 2010 to July 1, 2013 2010 2013 Percent Town Population Population Change Barnstable County, MA Shadow Region Bourne 19,754 19,733 -0.11%
Sandwich 20,675 20,589 -0.42%
Plymouth County, MA EPZ Carver 11,509 11,494 -0.13%
Duxbury 15,059 15,288 1.52%
Kingston 12,629 12,819 1.50%
Marshfield 25,132 25,509 1.50%
Plymouth 56,468 57,826 2.40%
Shadow Region Halifax 7,518 7,606 1.17%
Hanson 10,209 10,324 1.13%
Middleborough 23,116 23,601 2.10%
Pembroke 17,837 18,097 1.46%
Plympton 2,820 2,859 1.38%
Rochester 5,232 5,381 2.85%
Wareham 21,822 22,384 2.58%
Page 3 of 6
Atlantic Ocean w-\r*
Cape Cod Bay Legend PNPS County Boundary CJ EPZ m::il Town Boundary 0 Shadow Region ,_,.., _ Date: 7/31/2014 Census Places J Cop,.-il5h t:ESRIB:.5emllp Dlltll Municipailties with Data Q Census Designated Places (No Data)
Figure 1. Census Boundaries within PNPS Study Area Page 4 of 6
Methodology The compound growth formula (Equation 1) will be used for all population projections, where g is the annual growth rate and X is the number of years projected forward from Year 2010. The compound growth formula can be solved for g as shown in Equation 2. The data provided in Table 1 was used in Equation 2 to compute the annual growth rate for each town in the study area using X = 3.25 (3 years and 3 months from April 1, 2010 to July 1, 2013). The computed annual growth rates for town are summarized in Table 2.
Equation 1
:
201 2010 1
Equation 2
- 201 2010/ - 1 Table 2. Annual Growth Rate by Town Annual Growth Town Rate Barnstable County, MA Shadow Region Bourne -0.03%
Sandwich -0.13%
Plymouth County, MA EPZ Carver -0.04%
Duxbury 0.47%
Kingston 0.46%
Marshfield 0.46%
Plymouth 0.73%
Shadow Region Halifax 0.36%
Hanson 0.35%
Middleborough 0.64%
Pembroke 0.45%
Plympton 0.42%
Rochester 0.87%
Wareham 0.79%
Page 5 of 6
The most detailed data should always be used when forecasting population. In terms of detailed data, municipal data is the finest level of detail, then town data, county data, and state data. As shown in Figure 1, there are no incorporated municipalities within the study area. Town growth rates are available for the entire study area and were used as they are the finest level of detail available. Thus, county and state data need not be used.
The appropriate annual growth rate will be applied to each Census block in the study area depending on which town the block is located within. The population will then be projected to the desired month and year - September 2014 for this update - using Equation 1. The estimated population for 2014 will be provided for each sub-area, for the EPZ as a whole, the 2 and 5 mile regions, the Shadow Region, and the entire study area. In accordance with federal guidance, the computed percent change in population will be compared with Table M-3 from the 2012 ETE report to check if a full ETE update has been triggered. A report documenting this methodology and the results of the analysis will be provided to Entergy and the OROs upon completion.
Page 6 of 6
PilgrimNuclearPowerStation
2013PopulationUpdateAnalysis
WorkperformedforEntergy,by:
KLDEngineering,P.C.
43CorporateDrive
Hauppauge,NY11788
mailto:kweinisch@kldcompanies.com September25,2013 DraftReport,Rev0 KLDTR-567
Introduction
SectionIVofAppendixEto10CFRpart50andSection5.4,ReviewsandUpdatesofNUREG/CR7002
stipulate:
Licensees shall estimate EPZ permanent resident population changes at least annually during
the years between decennial censuses using U. S. Census Bureau data. These estimates shall
occurnomorethan365daysapart.State/localgovernmentpopulationdatamayalsobeused,if
available. Licensees shall maintain these estimates available for NRC inspection during the
periodbetweencensusesandshallsubmittheseestimatestotheNRCwithanyupdatedETEs.
If at any time during the decennial period, the EPZ permanent resident population increases
such that it causes the longest ETE value for the 2mile zone or 5mile zone, including all
affected Emergency Response Planning Areas, or for the entire 10mile EPZ to increase by 25
percent or 30 minutes, whichever is less, from the nuclear power reactor licensee's currently
NRCapprovedorupdatedETE,thelicenseeshallupdatetheETEanalysistoreflecttheimpactof
thatpopulationincrease.ThelicenseeshallsubmittheupdatedETEanalysistotheNRCunder§
50.4nolaterthan365daysafterthelicensee'sdeterminationthatthecriteriaforupdatingthe
ETE have been met and at least 180 days before using it to form protective action
recommendations and providing it to State and local governmental authorities for use in
developingoffsiteprotectiveactionstrategies.
Entergy has contracted KLD Engineering, P.C. to estimate annual population changes between the
decennialcensusesforthePilgrimNuclearPowerStation(PNPS)inaccordancewiththeaforementioned
federal regulations. Entergy and the offsite response organizations (OROs) - the Massachusetts
EmergencyManagementAgency,andtheTownsofCarver,Duxbury,Kingston,MarshfieldandPlymouth
-havereviewedthemethodologyandCensusgrowthratesprovidedbelow.
PilgrimNuclearPowerStation 1 KLDEngineering,P.C.
PopulationUpdateAnalysis Rev.0
USCensusGrowthRates
Thepopulationanalysisforthe2012PNPSEvacuationTimeEstimate(ETE)wasperformedusing2010
CensuspopulationdataprovidedontheU.S.CensusBureauwebsite1.TheCensusBureau QuickFacts2
websiteprovidesannualupdatesofpopulationdataforeachstate,county,minorcivildivision(town)3
andmunicipalityintheUnitedStates.Themostrecentupdatefortowngrowthratesavailableonthe
QuickFactswebsiteisforthetimeperiodfromApril1,2010toJuly1,2012.Thegrowthratesforeach
town within the study area (Emergency Planning Zone - EPZ - plus the Shadow Region) provided by
QuickFactsaresummarizedinTable1.TheCensusdoesnotprovideannualpopulationestimatesforthe
CensusDesignatedPlaces(CDPs-i.e.,NorthPlymouth)withinthestudyarea.TheCensusboundaries
foralltownswithinthestudyareaareshowninFigure1.
Table1.TownGrowthRatesfromApril1,2010toJuly1,2012
2010 2012 Percent
Town
Population Population Change
EPZ
Carver 11,509 11,521 0.10%
Duxbury 15,059 15,172 0.75%
Kingston 12,629 12,727 0.78%
Marshfield 25,132 25,436 1.21%
Plymouth 56,468 57,463 1.76%
ShadowRegion
Bourne 19,754 19,806 0.26%
Halifax 7,518 7,546 0.37%
Hanson 10,209 10,292 0.81%
Middleborough 23,116 23,395 1.21%
Pembroke 17,837 17,959 0.68%
Plympton 2,820 2,840 0.71%
Rochester 5,232 5,325 1.78%
Sandwich 20,675 20,662 0.06%
Wareham 21,822 22,339 2.37%
1
www.census.gov
2
http://quickfacts.census.gov/qfd/index.html
3
http://www.census.gov/popest/data/cities/totals/2012/index.html
PilgrimNuclearPowerStation 2 KLDEngineering,P.C.
PopulationUpdateAnalysis Rev.0
Figure1.CensusBoundarieswithinthePNPSStudyArea
PilgrimNuclearPowerStation 3 KLDEngineering,P.C.
PopulationUpdateAnalysis Rev.0
Methodology
The compound growth formula (Equation 1) was used for all population projections, where g is the
annual growth rate and X is the number of years projected forward from Year 2010. The compound
growthformulacanbesolvedforgasshowninEquation2.ThedataprovidedinTable1wasusedin
Equation2tocomputetheannualgrowthrateforeachtowninthestudyareausingX=2.25(2years
and3monthsfromApril1,2010toJuly1,2012).Thecomputedannualgrowthratesforeachtownare
summarizedinTable2.
Equation1.CompoundGrowthRate
Equation2.AnnualGrowthRate
Table2.AnnualGrowthRatebyTown
AnnualGrowth
Town
Rate
EPZ
Carver 0.05%
Duxbury 0.33%
Kingston 0.34%
Marshfield 0.54%
Plymouth 0.78%
ShadowRegion
Bourne 0.12%
Halifax 0.17%
Hanson 0.36%
Middleborough 0.53%
Pembroke 0.30%
Plympton 0.31%
Rochester 0.79%
Sandwich 0.03%
Wareham 1.05%
PilgrimNuclearPowerStation 4 KLDEngineering,P.C.
PopulationUpdateAnalysis Rev.0
Themostdetaileddatashouldalwaysbeusedwhenforecastingpopulation.Intermsofdetaileddata,
municipal data is the finest level of detail, then town data, county data, and state data. As shown in
Figure 1, there are no incorporated municipalities within the study area. Town growth rates are
availablefortheentirestudyareaandwereusedastheyarethefinestlevelofdetailavailable.Thus,
countyandstatedatawerenotused.
Using Geographical Information Systems (GIS) mapping software, the appropriate annual growth rate
wasappliedtoeachCensusblockinthestudyareadependingonwhichtowntheblockislocatedwithin.
ThepopulationwasprojectedtoSeptember1,2013forthisupdateusingEquation1withX=3.42(3
yearsand5monthsfromtheApril1,2010CensusdatetoSeptember1,2013).
Results
Thesubareaswhichcomprisetheapproximate10mileEPZforthePNPSareshowninFigure2.Table3
presents the 2010 population and estimated population for 2013 for each subarea, for the EPZ as a
whole,andalsoforthe2and5mileregions.Table4presentstheestimatedpopulationfor2013forthe
PNPSShadowRegion,whichextends15milesradiallyfromthePNPS.Figure3andFigure4presentthe
estimated2013EPZandShadowRegionpopulation,respectively,bysectoranddistancefromthePNPS
site.ThesepopulationroseswereconstructedusingGISsoftware.
Notethatthe2MileRegionand5MileRegiondonotconformexactlytothe2mileand5mileradiidue
totheirregularshapeoftheSubareas;seeFigure2.Thus,the2mileand5milepopulationsshownin
Figure3donotexactlymatchthe2MileRegionand5MileRegiontotalsinTable3.
Equation 3 was used to compute the percent change in population from 2010 to 2013. The percent
changeinpopulationforthevariousregionsofinterestissummarizedinTable5.
PilgrimNuclearPowerStation 5 KLDEngineering,P.C.
PopulationUpdateAnalysis Rev.0
Figure2.SubareasComprisingthePNPSEPZ
PilgrimNuclearPowerStation 6 KLDEngineering,P.C.
PopulationUpdateAnalysis Rev.0
Table3.EPZPopulation
2010Census 2013Extrapolated
Subarea Population Population
1 3,710 3,805
12
2MileRegionTotal: 3,710 3,805
2 8,985 9,221
3 10,946 11,236
4 17 17
5MileRegionTotal: 23,658 24,279
5 15,546 15,953
6 8,305 8,524
7 8,959 9,196
8 12,629 12,760
9 15,059 15,206
10 2,329 2,372
11 7,479 7,484
EPZTotal: 93,964 95,774
Table4.ShadowPopulationbySector
2010Census 2013Extrapolated
Sector Population Population
N 0 0
NNE 0 0
NE 0 0
ENE 0 0
E 0 0
ESE 0 0
SE 0 0
SSE 6,756 6,760
S 9,469 9,494
SSW 12,363 12,790
SW 3,968 4,069
WSW 4,928 4,965
W 4,741 4,794
WNW 12,639 12,729
NW 10,158 10,288
NNW 14,255 14,498
Total 79,277 80,387
PilgrimNuclearPowerStation 7 KLDEngineering,P.C.
PopulationUpdateAnalysis Rev.0
Figure3.PermanentEPZResidentPopulationbySector
PilgrimNuclearPowerStation 8 KLDEngineering,P.C.
PopulationUpdateAnalysis Rev.0
Figure4.ShadowPopulationbySector
PilgrimNuclearPowerStation 9 KLDEngineering,P.C.
PopulationUpdateAnalysis Rev.0
Equation3.PercentPopulationChange
Table5.SummaryofPercentPopulationChanges
Percent
Region PopulationChange
(20102013)
2MileRegion 2.6%
5MileRegion 2.6%
EPZ 1.9%
ShadowRegion 1.4%
EPZ+ShadowRegion 1.7%
AsdocumentedintheNRCsresponsetotheEmergencyPlanningFrequentlyAskedQuestion(EPFAQ)
2013001, the licensee should consider the impact of a population increase on the longest 90th
percentileETEforthescenariosidentifiedinTable13ofNUREG/CR7002,withtwopossibleexceptions:
- 1. Theroadwayimpactscenarioneednotbeconsideredbecausetheonlypurposeofthisscenario
istosupportthedevelopmentoftrafficcontrolplanning.
- 2. Theneedtoincludethespecialeventscenariodependsonthefrequencyofthespecialevent
analyzed.Licenseesshouldconsiderusingthisscenarioifthespecialeventchosenisrepetitive
during the year, such as multiple home football or baseball games, and not a onetime event
suchasaseasonalparade.
AsdocumentedinTable71,TimetoCleartheIndicatedAreaof90PercentoftheAffectedPopulation
in the PNPS ETE Report (KLD TR510, dated December 2012), the scenario with the longest 90th
percentileETEisScenario8-awinter,midweek,middayscenariowithsnow-anonspecialevent.
Table6isadaptedfromTableM3inAppendixMofthePNPSETEReportanddocumentsthepopulation
sensitivity study conducted for an evacuation under Scenario 8 conditions. As discussed in the
introduction,federalregulationsstipulatethatanupdatedETEmustbeconductedifpopulationgrowth
PilgrimNuclearPowerStation 10 KLDEngineering,P.C.
PopulationUpdateAnalysis Rev.0
islargeenoughtocausethe90thpercentileETEtoincreaseby25percentor30minutes,whicheveris
less.
Comparing the percent population changes presented in Table 5 with those in Table 6 indicates that
population has not grown enough to trigger an ETE update. Asdiscussedintheintroduction,annual
populationestimatesshallbemaintainedbylicenseesandmadeavailableforNRCinspectionbetween
censuses.ThisreportshouldbekeptonfileforNRCinspectorstoindicatethattheannualpopulation
analysisfor2013hasbeencompletedandthatanupdatedETEanalysisisnotwarrantedatthistime.
This report need not be submitted to the NRC as an updated ETE analysis has not been triggered by
populationgrowth.
Table6.ETEVariationwithPopulationChange
Resident PopulationChange
Population+ Base 10% 20% 23%
20%Shadow
Population 109,819 120,801 131,783 135,077
th ETEfor90 Percentile
PopulationChange
Region Base 10% 20% 23%
2MILE 2:55 2:55 3:00 3:00
5MILE 2:35 2:45 2:50 2:55
FULLEPZ 3:30 3:40 3:55 4:00
th ETEfor100 Percentile
PopulationChange
Region Base 10% 20% 26%
2MILE 6:00 6:00 6:00 6:00
5MILE 6:05 6:05 6:05 6:05
FULLEPZ 6:10 6:10 6:10 6:10
PilgrimNuclearPowerStation 11 KLDEngineering,P.C.
PopulationUpdateAnalysis Rev.0