ML12340A608

Official Exhibit - NYS000241-00-BD01 - Pre-Filed Testimony of Dr. Francois J. Lemay

ML12340A608
Person / Time
Site:	Indian Point
Issue date:	06/29/2012
From:	Lemay F State of NY, Office of the Attorney General
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 22873, 50-247-LR, ASBLP 07-858-03-LR-BD01, 50-286-LR
Download: ML12340A608 (56)

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) NYS000241 ASLBP #: 07-858-03-LR-BD01 Submitted: December 21, 2011 Docket #: 05000247 l 05000286 Exhibit #: NYS000241-00-BD01 Identified: 10/15/2012 Admitted: 10/15/2012 Withdrawn:

Rejected: Stricken:

Other:

1 UNITED STATES 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 -----------------------------------x 5 In re: Docket Nos. 50-247-LR; 50-286-LR 6 License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 7 Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 8 Entergy Nuclear Indian Point 3, LLC, and 9 Entergy Nuclear Operations, Inc. December 21, 2011 10 -----------------------------------x 11 PRE-FILED WRITTEN TESTIMONY OF 12 DR. FRANÇOIS J. LEMAY 13 REGARDING CONSOLIDATED NYS-12-C (NYS-12/12-A/12-B/12-C) 14 On behalf of the State of New York, the Office of the 15 Attorney General hereby submits the following testimony by 16 François J. Lemay regarding Consolidated Contention NYS-12-C.

17 I. WITNESS BACKGROUND 18 Q: Please state your full name.

19 A: François Jean Lemay 20 Q: By whom are you employed and what is your position?

21 A: I am currently Vice President of International Safety 22 Research Inc., also known as ISR.

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 1

23 Q: Please summarize your educational and professional 24 qualifications.

25 A: My education, professional qualifications, and 26 experience are provided in Exhibit NYS000291. I am a 27 professional engineer with a Ph.D. in Physics of Nuclear 28 Reactors from the University of Birmingham, United Kingdom. I 29 have 27 years of experience in safety analysis, emergency 30 response plans, procedures and systems, radiation protection, 31 radiation transport, risk assessment, environmental impact 32 assessment, standards and guidelines, audits and evaluations, 33 emergency exercises, courses and training and international 34 projects.

35 I currently offer an advanced level course on COSYMA and 36 MACCS2 for health physicists and engineers.

37 Q: Please elaborate on your familiarity with nuclear 38 accident economic cost models such as the MELCOR Accident 39 Consequence Code System, which Ill refer to as MACCS, code.

40 A: I have extensive experience with the MACCS and MACCS2 41 codes, including using the codes to calculate the consequences 42 to the population for several accidents scenarios in the context 43 of the Nanticoke New Build Project for Bruce Power in Ontario.

44 I also have extensive experience with COSYMA, a code from the 45 European Union that is similar to MACCS, and have performed Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 2

46 similar calculations for ESKOM in South Africa, Hydro-Quebec and 47 New Brunswick Power in Canada, and the Canadian Navy. I also 48 used COSYMA to calculate the cost of accidents near Darlington 49 and Gentilly for the Canadian Department of Natural Resources.

50 II. WITNESS PREPARATION FOR TESTIMONY 51 Q: Have you reviewed materials in preparation for your 52 testimony?

53 A: Yes.

54 Q: Dr. Lemay, I show you what has been marked as Exhibit 55 NYSR70001. Do you recognize this document?

56 A: Yes. It is a list of all the documents which were 57 referred to, used and/or relied upon in preparing the ISR report 58 and this testimony.

59 Q: What is the source of those materials?

60 A: Many are documents prepared by government agencies, 61 peer reviewed articles, or documents prepared by Entergy, Sandia 62 National Laboratories, NRC or the utility industry.

63 Q: I show you Exhibits NYS000240 through NYS000292. Do 64 you recognize these documents?

65 A: Yes. These are true and accurate copies of the 66 documents that were referred to, used and/or relied upon in 67 preparing the ISR report and this testimony. In some cases, 68 where the document was extremely long and only a small portion Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 3

69 is relevant to my testimony, an excerpt of the document is 70 provided. If it is only an excerpt, that is noted on the first 71 page of the Exhibit.

72 Q: How do these documents relate to the work that you do 73 as an expert in forming opinions such as those contained in this 74 testimony?

75 A: These documents represent the type of information that 76 persons within my field of expertise reasonably rely upon in 77 forming opinions of the type offered in this testimony.

78 Q: Did you review any other documents in connection with 79 the ISR report and/or this testimony?

80 A: Yes, I have reviewed all of the filings involving NYS-81 12, 12-A, 12-B, and 12-C, including: NYS Notice of Intention to 82 Participate and Petition to Intervene, Contention 12, at pp.

83 140-145 (November 30, 2007); Answer of Entergy Opposing New York 84 State Notice of Intention to Participate and Petition to 85 Intervene, section on NYS-12, at pp. 86-91 (January 22, 2008);

86 NRC Staffs Response to Petitions for Leave to Intervene, 87 section on NYS-12, at pp. 50-52 (January 22, 2008); NYS Reply in 88 Support of Petition to Intervene, Contention 12, at pp. 75-81 89 (February 22, 2008); the portion of the transcript of the March 90 2008 hearing before the Board concerning the MACCS2 code; the 91 July 31, 2008 Board Order (see infra note 1); NYS Contentions Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 4

92 Concerning NRC Staffs Draft Supplemental Environmental Impact 93 Statement, Contention 12-A, at pp. 2-9 (February 27, 2008);

94 Answer of Entergy Opposing New and Amended Environmental 95 Contentions of NYS, , Contention 12-A, at pp. 12-13 (March 24, 96 2009); NRC Staffs Answer to Amended and New Contentions Filed by 97 NYS and Riverkeeper, Inc. Concerning the Draft Supplemental 98 Environmental Impact Statement, Contention 12-A, at p. 12 (March 99 24, 2009); NYS Combined Reply to Entergy and NRC Staff in 100 Support of Contentions 12-A, 16-A, 17-A, 33, and 34 (March 31, 101 2009); the June 16, 2009 Board Order (see infra, note 1); NYS 102 New and Amended Contentions Concerning the December 2009 SAMA 103 Reanalysis, Contention 12-B, at pp. 1-6 (March 11, 2010) 104 (including the March 11, 2010 declaration of David Chanin);

105 Applicants Answer to NYS New and Amended Contentions Concerning 106 Entergys December 2009 Revised SAMA Analysis, Contention 12-B, 107 at pp. 1-19 (April 5, 2010); NRC Staffs Answer to NYS New and 108 Amended Contentions Concerning the December 2009 SAMA 109 Reanalysis, Contention 12-B, at pp. 1-12 (April 5, 2010); the 110 June 30, 2010 Board Order (see infra, note 1); NYS New 111 Contention 12-C concerning NRC Staffs December 2010 FEIS and 112 the Underestimation of Decontamination and Clean Up Costs 113 Associated With a Severe Reactor Accident in the New York 114 Metropolitan Area (February 3, 2011) (including the February Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 5

115 2011 declaration of David Chanin); NYS Motion for Leave to File 116 New and Amended Contention 12-C (February 3, 2011); Applicants 117 Answer to NYS Amended Contention 12C (March 7, 2011); NRC 118 Staffs Answer to NYS Contention 12-C (March 7, 2011); NYS 119 Combined Reply to NRC Staff and Entergys Answers to Contention 120 12-C (March 18, 2011); and the July 6, 2011 Board Order.

121 III. OVERVIEW AND SCOPE OF TESTIMONY 122 Q: What is the purpose of your testimony?

123 A: The purpose of my testimony is to address, on behalf 124 of New York State, which I'll refer to as NYS, Contentions 12, 125 12-A, 12-B, and 12-C, which were admitted by the Atomic Safety 126 Licensing Board on July 31, 2008, June 16, 2009, June 20, 2010, 127 and July 6, 2011, respectively.1 The Board consolidated these 128 contentions and I will collectively refer to them as 129 Consolidated NYS-12-C.

130 Q: Please describe your familiarity with and 131 understanding of the issues raised in Consolidated NYS-12-C.

1 See Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3) LBP-08-13, 61-65 (July 31, 2008);

Licensing Board Memorandum and Order (Ruling on New York States New and Amended Contentions)(June 16, 2009)(unpublished) at 3-4.

Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3) LBP-10-13, 9-10 (June 30, 2010);

Licensing Board Memorandum and Order (Ruling on Pending Motions for Leave to File New and Amended Contentions)(July 6, 2011)(unpublished) at 1-9.

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 6

132 A: As I explained earlier, I have reviewed pleadings and 133 orders related to NYS-12, NYS-12-A, NYS-12-B, and NYS-12-C.

134 Consolidated NYS-12-C challenges the adequacy of the economic 135 cost modeling that was used by Entergy in the analysis of Severe 136 Accident Mitigation Alternatives, which I'll refer to as SAMAs, 137 for the Indian Point Nuclear Generating Station, which I'll 138 refer to as IP. Entergy is in the process of applying for a 139 twenty-year operating license extension for IP Units 2 and 3, 140 which I'll refer to as IP2 and IP3 respectively. As part of its 141 License Renewal Application, Entergy was required to submit an 142 Environmental Report, which I'll refer to as ER that included a 143 SAMA analysis. As part of the relicensing proceeding, NRC Staff 144 completed a Final Supplemental Environmental Impact Statement, 145 which I'll refer to as the FSEIS, which evaluates, among other 146 things, Entergys SAMA analysis.

147 Consolidated NYS-12-C asserts that Entergys ER, NRC 148 Staffs Draft Supplemental Environmental Impact Statement, which 149 I'll refer to as DSEIS, Entergys December 2009 SAMA Reanalysis 150 and NRC Staffs FSEIS failed to address site specific 151 assumptions and inputs related to clean-up and decontamination 152 costs in the New York City metropolitan region in the event of a 153 severe accident at IP. In Consolidated NYS-12-C, NYS asserts 154 that NRC Staff and Entergy substantially underestimate the costs Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 7

155 of decontamination measures which must be considered in the 156 License Renewal Application process.

157 Q: Please summarize the work NYS asked ISR to complete.

158 A: In connection with Consolidated NYS-12-C, NYS 159 requested that ISR:

160 (1) examine Entergys use of the MACCS2 code, including 161 Entergys input files and all other relevant parts of the code 162 which address the long-term phase of a severe nuclear accident; 163 (2) determine whether and to what extent economic costs of 164 a severe accident at IP were underestimated due to, for example, 165 the use of generic assumptions concerning decontamination costs 166 that are not necessarily applicable to the densely populated 167 area surrounding IP2 and IP3 found in the NYC metropolitan 168 region; and 169 (3) specifically address NRCs evaluation of NYS 12/12-170 A/12-B contained in Appendix G to the FSEIS.

171 Q: How will your testimony address the issues raised by 172 Consolidated NYS-12-C?

173 A: This testimony will explain ISRs review and 174 assessment of Entergys use of the MACCS2 code to estimate the 175 economic costs associated with a severe accident at IP for its 176 SAMA analysis, and NRC Staffs evaluation of Entergys SAMA 177 analysis as part of the FSEIS. ISRs review and evaluation Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 8

178 encompasses the assumptions inherent in the MACCS2 code. In 179 particular, this includes the input parameters to the CHRONC 180 module of the code which were developed and used by Entergy for 181 its SAMA analysis, and the NRCs discussion of these issues in 182 the FSEIS. ISRs analysis is focused on the effect of the 183 critical input parameters on the total economic cost of a severe 184 nuclear accident.

185 Q: I show you what has been marked as Exhibit NYS000242.

186 Do you recognize this document?

187 A: Yes. It is a copy of the report that ISR prepared for 188 NYS in this proceeding. The report reflects our analyses and 189 opinions.

190 Q: Does ISR agree with the assertion in Consolidated NYS-191 12-C that Entergy and NRC Staff have underestimated the costs 192 associated with a severe accident at IP?

193 A: Yes.

194 Q: Please summarize ISR's conclusions.

195 A: ISR has concluded that Entergy underestimated the 196 total economic cost of a severe nuclear accident at IP. This 197 underestimation is primarily a result of Entergys use of MACCS2 198 Sample Problem A input values for the CHRONC module and was 199 largely due to Entergy's use of costs and times for 200 decontamination that were unrealistic given current known Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 9

201 decontamination data and the complexities of an urban to hyper-202 urban area such as that surrounding IP.

203 IV. SAMA ANALYSIS 204 Q: Are you familiar with the SAMA analysis and the 205 economic cost modeling that was performed for IP?

206 A: Yes, The SAMA analysis is a cost-benefit analysis to 207 identify potential upgrades to a nuclear power plant, or its 208 operations, that could reduce the risk (the likelihood or the 209 consequences, or both) of a severe reactor accident for which 210 the benefit of implementing the change outweighs the cost of 211 implementation. These potential changes are referred to as 212 SAMAs or SAMA candidates. A severe accident is a beyond design 213 basis accident that could result in substantial damage to the 214 reactor core, whether or not there are serious off-site 215 consequences. Upgrades to the nuclear power plant that could 216 reduce the risk of a severe accident include, for example, plant 217 modifications (such as the use of additional engineering safety 218 features) or operational changes such as improved procedures, 219 and augmented training of control room and plant personnel.

220 Q: How is a SAMA analysis performed?

221 A: To determine whether a SAMA is cost-beneficial, it is 222 necessary to determine the statistical expectation value of the 223 benefit of implementing a SAMA, which is compared to the cost of Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 10

224 implementing the SAMA. The expectation value of the benefit is 225 obtained by calculating the economic consequences of a range of 226 accidents and weighting these consequences by the probability of 227 their occurrence. Accordingly, a SAMA analysis is probabilistic, 228 averaging the economic consequences over a range of accidents, 229 weather scenarios and physical locations. The analysis models 230 the dispersion of a cloud of radioactive dust and its deposition 231 on the ground. It uses a years worth of site-specific 232 meteorological data to predict the probabilistic consequences of 233 an accident over the 50-mile radius area around the site. It 234 also uses site-specific population density and economic activity 235 parameters to evaluate the costs of an accident. The ultimate 236 goal is a cost-benefit analysis comparing the expected value of 237 the avoided consequences against the cost of implementing 238 specific preventative or mitigative measures.

239 A. The MACCS2 Code 240 1. Overview of the MACCS2 Code 241 Q: Is there a computer model that is generally accepted 242 in the nuclear industry for calculating the costs of a severe 243 accident for use in a SAMA analyses?

244 A: Yes. It is called MELCOR Accident Consequence Code 245 Systems 2, or MACCS2. To the best of my knowledge, the MACCS2 246 code is the only computer model used in the United States for Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 11

247 performing the consequence portion of a full SAMA analysis. In 248 other jurisdictions (such as Canada) the COSYMA Code has also 249 been used for the same purpose. For IP, Entergy used the MACCS2 250 code to estimate the cost of decontamination and costs of 251 evacuation and relocation after a severe accident.

252 Q: Please describe the origin and general use of the 253 MACCS2 Code.

254 A: MACCS2 is a Gaussian plume model for calculation of 255 radiological atmospheric dispersion and consequences, developed 256 by Sandia National Laboratories. The MACCS2 code is the latest 257 of a series of computer modeling tools developed to evaluate 258 impacts of severe accidents at nuclear power plants on the 259 surrounding public. MACCS2 was released in 1997 and developed as 260 an improved version of the MACCS code, which itself replaced the 261 earlier CRAC2 code. The MACCS2 code simulates the atmospheric 262 release of radioactivity, the direction, speed of travel, and 263 dispersion (spread and dilution) of the plume based on 264 meteorological inputs; and ultimately, MACCS2 calculates 265 radiological health and economic impacts. It can model, among 266 other things, economic costs of an accident.

267 Q: How does the MACCS code differ from its predecessor, 268 the CRAC code?

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 12

269 A: MACCS incorporates many improvements in modeling 270 flexibility in comparison to CRAC2. While the underlying models 271 of CRAC2 and MACCS are largely similar, the main difference 272 between the two is that a number of parameters are hard-wired 273 and, thus, cannot be changed in the CRAC code. In MACCS and 274 MACCS2, those same parameters are user-defined and, thus, can be 275 derived from site-specific data. Essentially, the MACCS and 276 MACCS2 updates to the CRAC code facilitate the analysis of 277 consequence uncertainties in the model parameters.

278 Q: How does the MACCS2 code estimate the costs associated 279 with a severe accident?

280 A: The MACCS2 code evaluates several major factors which 281 contribute to the costs of a severe nuclear accident. For 282 example, MACCS2 evaluates release characteristics, weather 283 pattern, population profile, clean-up costs, and other factors 284 which affect the cost of a severe accident.

285 Q: How does the MACCS2 model operate?

286 A: MACCS2 is executed in three steps. The first module, 287 ATMOS, calculates air and ground concentrations, plume size, and 288 timing information for all plume segments as a function of 289 downwind distance. The next module, EARLY, calculates the 290 consequences due to exposure to radiation in the first seven 291 days, which is the emergency phase of the accident. The last Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 13

292 module, CHRONC, calculates the consequence of the long-term 293 effects of radiation and computes the decontamination and 294 economic impacts incurred due to the accident.

295 2. The CHRONC Module of the MACCS2 Code 296 Q: Did ISRs analysis focus on particular aspects of the 297 MACCS2 code?

298 A: Yes. ISR was tasked with evaluating the MACCS2 299 factors directly associated with the long-term management of the 300 nuclear accident, specifically decontamination, relocation, and 301 condemnation of buildings and property. All of the inputs used 302 by Entergy in its SAMA analysis that are associated with 303 decontamination and long-term economic costs are found in the 304 CHRONC module of the code. Thus, ISRs analysis is focused on 305 the CHRONC module and its input parameters.

306 Q: Please describe the operation of the CHRONC module.

307 A: The CHRONC module uses the input parameters that 308 pertain to both the intermediate and long-term phases of the 309 nuclear accident consequence management. It simulates the 310 events that occur following the emergency-phase time period 311 modeled by the EARLY module. CHRONC calculates both the 312 individual health effects and the economic cost of the long-term 313 decontamination and relocation associated with a severe 314 accident.

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 14

315 MACCS2 determines the economic cost of a severe accident 316 primarily on the basis of the CHRONC input parameters. The 317 CHRONC module contains two models: the economic cost model and 318 mitigative actions model.

319 Q: Please describe CHRONCs economic cost model.

320 A: The economic consequence calculations in the economic 321 cost model of the MACCS2 code are intended to estimate the 322 direct offsite costs from a severe accident at a nuclear 323 reactor. Two main costs are modeled: costs resulting from early 324 protective actions, and costs resulting from long-term 325 protective actions.

326 Q: Are costs based on user-defined inputs to the MACCS2 327 code?

328 A: Yes. The following costs are treated as user defined 329 inputs in the economic models implemented in the MACCS2 code:

330 (1) Food and lodging costs for short-term relocation of 331 people who are evacuated or relocated during the emergency phase 332 of the accident; 333 (2) Decontamination costs for property that can be returned 334 to use if decontaminated; 335 (3) Economic losses incurred while property, both farm and 336 nonfarm, is temporarily interdicted for a period of time Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 15

337 following decontamination to allow for radioactive decay to 338 reduce ground contamination to acceptable levels; 339 (4) Economic losses resulting from milk and crop disposal; 340 and 341 (5) Economic losses due to permanent interdiction of 342 property.

343 Q: Do the MACCS2 inputs take into account all costs 344 associated with a severe accident?

345 A: No. Indirect costs such as the costs of 346 transportation, disposal, and storage of contaminated wastes are 347 not accounted for in the MACCS2 economic model.

348 Q: What is the purpose of CHRONCs mitigative actions 349 model?

350 A: CHRONCs mitigative actions module determines what 351 mitigative strategies to employ for a severe accident.

352 Mitigative actions are measures taken to reduce the dose to the 353 population after the emergency phase of an accident.

354 Q: What types of mitigative strategies does MACCS2 355 implement?

356 A: In MACCS2, there are typically five possible 357 mitigative strategies for any given spatial sector. These 358 include:

359 (1) No mitigative actions Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 16

360 (2) Decontaminate areas using the lowest selected 361 decontamination factor; 362 (3) Decontaminate areas using the highest selected 363 decontamination factor; 364 (4) Decontaminate areas using the highest selected 365 decontamination factor and implement temporary interdiction for 366 up to 30 years; or 367 (5) Condemn the area.

368 Q: Please explain the term decontamination factor as it 369 is used in the MACCS2 code.

370 A: Decontamination factor, which I will refer to as DF, 371 is a factor representing the dose reduction due to 372 decontamination activities. Mathematically, DF is equal to the 373 dose from contamination present before clean up divided by the 374 dose from contamination present after cleanup. For example, a 375 DF of 3 means that the radiation dose has been reduced to a 376 value 3 times lower than the original (or a 66% reduction from 377 the initial contamination). I will discuss DF in more detail 378 later on my testimony.

379 Q: How does MACCS2 determine which mitigative actions to 380 implement?

381 A: The decision on which mitigative action to implement 382 hinges on a threshold value, the habitability criterion, which Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 17

383 I'll refer to as HC. The HC is dependent on the long-term 384 projected dose that a person would get if he or she continued to 385 live in the contaminated area for the specified time. The HC 386 recommended by the US Environmental Protection Agency is 0.04 387 Sieverts in 5 years.

388 The MACCS2 decision sequence for determining which 389 mitigative action to implement is as follows and is depicted in 390 Figure 2 of the ISR report:

391 (1) If there is no decontamination and the projected 392 radiation dose to the public in the contaminated area is less 393 than the HC, relocation or other mitigative actions are not 394 required, otherwise:

395 (2) If after decontamination using the lowest selected DF, 396 the dose is less than the HC, decontaminate to the lowest 397 selected DF and allow return to property after the time required 398 to decontaminate, which is called TIMDEC1, otherwise:

399 (3) If after decontamination using the highest selected DF, 400 the dose is less than the HC, decontaminate to the highest 401 selected DF and allow return to property after the time required 402 to decontaminate, which is called TIMDEC2, otherwise:

403 (4) If decontamination using the highest selected DF and 404 temporary relocation for any time less than 30 years to allow 405 for radioactive decay results in a dose less than the HC, Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 18

406 decontaminate to the highest selected DF and move back after 407 TIMDEC2 plus the interdiction time, otherwise:

408 (5) Condemn the property.

409 The decision sequence is carried out for each spatial sector.

410 MACCS2 includes the following cost effectiveness caveat: if 411 the cost of decontamination and interdiction is greater than the 412 cost of condemning the property, condemnation is chosen. This 413 insures that MACCS2 implements the lowest cost mitigative action 414 that meets the HC.

415 3. Determining Input Values for the MACCS2 Code 416 Q: Dr. Lemay, you mentioned earlier that a key advantage 417 of the MACCS2 code over previous codes is that it allows the 418 user to specify inputs. Do you have an opinion on how a user 419 should go about determining proper MACCS2 inputs for a given 420 nuclear reactor?

421 A: Inputs to the MACCS2 code are dependant on the 422 location of the nuclear reactor. The costs and methods of 423 cleaning up after a severe accident will be very different 424 depending on whether a reactor is surrounded by farmland, 425 forests, suburban areas, urban areas, or hyper-urban areas.

426 Thus, to determine reasonable input values, one must look at 427 site-specific data or, where site-specific data is not Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 19

428 available, modify available data to reflect site-specific 429 conditions.

430 Q: Generally, how should one go about determining proper 431 inputs for the area surrounding IP?

432 A: Due to the fact that there is very little data on 433 actual severe reactor accidents in a hyper-urban area such as 434 NYC, research must be done to accurately determine an 435 appropriate range of input parameters. In its expert report, 436 ISR determined a reasonable range of values for sensitive input 437 parameters by extrapolating data from other types of nuclear 438 accidents, field radiological decontamination work, and actual 439 decontamination experiments.

440 Q: What do you mean when you say hyper-urban?

441 A: Manhattan is an example of a hyper-urban area. It has 442 a very high population density and consists mostly of high-rise 443 buildings. Urban areas typically consist of mixed commercial and 444 residential suburbs surrounding a downtown core.

445 V. ENTERGY'S USE OF THE MACCS2 CODE 446 Q: Dr. Lemay, did Entergy use the MACCS2 code for IP?

447 A: Yes, Entergy used the MACCS2 code to estimate the 448 costs associated with a severe accident. Attachment E to 449 Entergy's April 2007 ER describes Entergy's SAMA analysis and 450 its use of the MACCS2 code.

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 20

451 Q: Did ISR evaluate Entergy's use of the MACCS2 code?

452 A: Yes, in particular ISR reviewed Entergy's inputs to 453 the CHRONC module of the code.

454 Q: Does ISR have an understanding of how Entergy selected 455 the input values they used for their MACCS2 runs?

456 A: Yes, ISR was able to determine how Entergy selected 457 the input values they used for many of the sensitive parameters.

458 Q: And what did ISR determine?

459 A: As explained in its ER, Entergy took all but three of 460 the MACCS2 input values related to decontamination from Sample 461 Problem A, which is found in the MACCS2 user guide, and adjusted 462 those inputs for inflation. Value of nonfarm wealth along with 463 the value of farm wealth and the long-term exposure period were 464 the only values not derived from Sample Problem A.

465 Q: What is Sample Problem A?

466 A: The MACCS2 User Guide includes 14 sample problems 467 containing sets of example inputs that were designed to be used 468 to test that the MACCS2 code was installed and running properly.

469 Sample Problem A is one of the 14 sample problems in the User 470 Guide. Sample Problem A incorporates site-specific data for the 471 Surry site in Virginia.

472 Q: Why did the authors of NUREG-1150 chose the Surry site 473 for Sample Problem A?

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 21

474 A: The NUREG-1150 authors chose five commercial nuclear 475 plants of different design to estimate the risks of a severe 476 accident. One of these, the Surry reactor, is a Westinghouse 477 designed three-loop reactor in a large, dry containment building 478 located near Williamsburg, Virginia. Using the Surry reactor in 479 Sample Problem A allowed the authors of MACCS2 to test the food 480 chain model because it is largely surrounded by farmland.

481 Q: Are the parameter values in the MACCS2 sample problems 482 intended to be used as default values?

483 A: No. Neither he MACCS nor MACCS2 documentation 484 suggests that the input values of the code sample problems be 485 considered recommended or default values. In fact, David 486 Chanin, the developer of the MACCS2 code, discussed the use of 487 Sample Problem A as default values in his 2005 paper, The 488 Development of MACCS2: Lessons Learned. In this paper, he 489 stated We also went so far as to scrupulously avoid using the 490 common default value in referring to the codes provided 491 Sample Problem input data files. Sample data and example 492 usage were the terms used to remind the analyst that they, and 493 they alone, were responsible for reviewing MACCS and MACCS2 494 input data and resultant code outputs to ensure appropriateness 495 for their application.

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 22

496 Q: Did Entergy use the inputs from Sample Problem A to 497 derive the input values it used for its SAMA analysis?

498 A: Yes. As I explained, all but three of Entergys 499 MACCS2 input values related to decontamination are taken from 500 Sample Problem A. The only adjustment Entergy made to the 501 Sample Problem A inputs was for inflation from the 1986-based 502 dollars of NUREG-1150 to the 2005-based dollars of the Entergys 503 SAMA analysis.

504 Q: What effect did Entergy's use of Sample Problem A 505 input values have on its evaluation of the economic costs of a 506 severe accident at IP?

507 A: ISR concluded that Entergy's use of the generic input 508 values contained in Sample Problem A caused Entergy to 509 underestimate the economic costs of a severe accident at IP. I 510 will discuss this conclusion in greater detail later in my 511 testimony.

512 VI. ISRS MACCS2 CODE SENSITIVITY ANALYSIS 513 Q: Dr. Lemay, lets move on to the specifics of ISRs 514 analysis of the economic costs associated with a severe accident 515 at IP. What was the first step in ISRs analysis?

516 A: ISR conducted a sensitivity analysis on the MACCS2 517 code to determine which input parameters directly and most 518 significantly affect the costs of mitigative actions following a Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 23

519 severe accident. This allowed ISR to focus on input parameters 520 that could make a difference in the cost of mitigative actions.

521 Because ISR was interested in the economic costs associated with 522 decontamination at IP and its surrounding areas, ISR's 523 sensitivity analysis focused on the CHRONC module of the MACCS2 524 model.

525 Q: What is a sensitivity analysis?

526 A: A sensitivity analysis is a method by which one can 527 measure how much an output, such as the total offsite economic 528 cost risk (OECR) changes by varying an input, such as the Value 529 of nonfarm wealth. If the output does not change when the input 530 varies, the calculation can be said to be insensitive to this 531 input parameter. If on the other hand, the output changes, the 532 calculation can be said to be sensitive to this input parameter.

533 Q: How did ISR evaluate the sensitivity of the MACCS2 534 model?

535 A: To evaluate the sensitivity of each of the CHRONC 536 input parameters, ISR varied each input parameter, one at a 537 time, and performed a MACCS2 simulation run for IP2 using 538 Entergy's five input files which include the ATMOS, EARLY, 539 CHRONC weather, and site file.

540 Q: How did ISR quantify the effect of changing each 541 parameter?

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 24

542 A: ISR chose to quantify the effect of changing each 543 parameter by calculating the change in the resulting total 544 offsite economic cost risk, which I will refer to as OECR.

545 Q: Why did ISR choose to calculate the change in the 546 resulting OECR?

547 A: ISR selected the total OECR because it is the value 548 used in the cost-benefit analysis in the SAMA analysis and 549 therefore, the most pertinent value derived from the MACCS2 550 output.

551 Q: What does the OECR represent and how is it obtained?

552 A: The OECR is a probability-averaged cost, on a per year 553 basis. The real cost of clean-up following a severe nuclear 554 reactor accident could be in the billions of dollars, but 555 weighted by the actual frequency of a severe reactor event 556 occurring per year, the cost can be expressed on a per year 557 basis as OECR.

558 The OECR is obtained by adding the total offsite economic 559 cost for each of the eight release categories after weighting 560 them by their respective frequencies. The release categories 561 correspond to an end state of the reactor (such as core melt) 562 and each have an associated frequency. The OECR calculated by 563 Entergy using Sample Problem A input values was $2.12E+05/yr for Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 25

564 IP2. ISR used Entergy's OECR as a basis for comparison to ISR's 565 calculated OECRs.

566 Q: How did ISR evaluate the sensitivity of each 567 parameter?

568 A: To ascertain the relative sensitivity, ISR increased 569 each input parameter by 10% and then calculated the percentage 570 increase in the total OECR. The results of ISR's sensitivity 571 analysis indicated the most sensitive CHRONC input parameters.

572 Q: Why did ISR choose to increase each parameter by 10%?

573 A: A change of 10% in the input value is credible and is 574 a good benchmark for assessing the sensitivity of the output 575 value. ISR attempted larger changes in input parameters, but 576 noticed that some input parameters were restricted to a limited 577 range of values. Setting the input value outside that range made 578 the comparison between input parameters difficult.

579 Q: Which parameters did ISR determine to be the most 580 sensitive to the economic costs determined by the CHRONC module?

581 A: ISR determined that eleven parameters were sensitive.

582 Annex B to the ISR expert report, Exhibit NYS000242, describes 583 the results of our sensitivity analysis in more detail.

584 Q: Did ISR determine which input parameters ultimately 585 have the greatest impact on the economic costs associated with a 586 severe accident at IP?

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 26

587 A: Yes, ISR determined that decontamination costs are the 588 dominant factor in the evaluation of the remediation costs 589 following a severe nuclear accident. The most sensitive input 590 parameters related to decontamination costs include:

591 decontamination factor, nonfarm decontamination cost, and 592 decontamination time.

593 VII. ISRS ANALYSIS OF SENSITIVE INPUT PARAMETERS 594 Q: What was the next step in ISR's analysis after 595 determining the sensitive input parameters?

596 A: For each sensitive input, ISR determined the input 597 parameter's definition, the value chosen by Entergy, and the 598 rationale or source for Entergy's chosen value. ISR then 599 performed research and calculations to arrive at an appropriate 600 range of values for each input.

601 A. Decontamination Factor (DF) 602 Q: Dr. Lemay, Id like to discuss each of these sensitive 603 parameters with you. Lets start with the decontamination 604 factor. What is a decontamination factor?

605 A: As I explained previously, the DF is defined in MACCS2 606 as the dose from contamination before clean-up divided by the 607 dose from contamination after cleanup. Table 1, which is taken 608 from the ISR report, Exhibit NYS000242, and reproduced below, 609 expresses DFs as clean-up percentages.

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 27

610 Table 1: Reduction in contamination for each DF Reduction in DF contamination 2 50%

3 67%

5 80%

7 85.7%

10 90%

15 93.3%

20 95%

611 612 For example, to achieve a DF of 3, 67% of the contamination 613 would need to be removed. To achieve a DF of 15, 93.3% of the 614 contamination would need to be removed. Decontamination factors 615 may be classified as light, moderate, or heavy. These 616 classifications correlate with differing activities and degrees 617 of cleanup.

618 Q: Could you explain what light decontamination means?

619 A: Yes. Light decontamination includes activities such 620 as prompt vacuuming of all structural exteriors followed by 621 detergent scrubbing. Building interiors would be vacuumed 622 and/or shampooed. Turf or lawn areas that could not be 623 decontaminated would be removed. Tree foliage would be hosed 624 down, and the wash water would be collected to avoid run-off.

625 Light DFs typically range from 2 to 5, or 50% to 80% removal of 626 contamination.

627 Q: What does moderate decontamination mean?

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 28

628 A: Moderate decontamination includes activities such as 629 removing and replacing roofing and all landscape material.

630 Interiors of buildings would be emptied of all removable 631 contents including items such as desks, chairs, and personal 632 items. Moderate DFs typically range from 5 to 10, or 80% to 90%

633 removal of contamination.

634 Q: What does heavy decontamination mean?

635 A: Heavy decontamination is typically a DF higher than 636 10, meaning that more than 90% of contamination is removed.

637 Based on experience following the Chernobyl accident as 638 explained in Exhibits NYS000249, NYS000250 and NYS000251, 639 decontamination of an entire building to a level greater than 10 640 may not be possible without complete demolition and disposal in 641 a licensed burial facility.

642 Q: Did you determine the DFs that Entergy used in their 643 analysis?

644 A: Yes, Entergy used the DFs from Sample Problem A, which 645 were 3 and 15.

646 Q: Did Entergy offer any explanation as to why it chose 647 these values?

648 A: In the materials I reviewed, I did not come across any 649 explanation of why Entergy used Sample Problem A.

650 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 29

651 B. Approaches for Nonfarm Decontamination Cost (CDNFRM) 652 Q: Please describe Nonfarm Decontamination Cost, which I 653 will refer to as CDNFRM.

654 A: CDNFRM is the MACCS2 input that defines the nonfarm 655 decontamination cost. MACCS2 requires the user to input a 656 CDNFRM in dollars per person for each DF specified.

657 Q: Did ISR determine the source of the values used by 658 Entergy for CDNFRM?

659 A: Yes, Entergy selected values of $5,184/person and 660 $13,824/person for DFs of 3 and 15, respectively. Entergy 661 obtained these values by using the values found in Sample 662 Problem A, which were $3,000/person and $8,000/person, 663 respectively, and then adjusting them by the Consumer Price 664 Index change from 1986 to 2005. Entergy did not supply a 665 rationale for its reliance on Sample Problem A.

666 Q: Did ISR develop an opinion about the use of the CPI-667 adjusted values Entergy derived from Sample Problem A?

668 A: Yes. While ISR acknowledges that the determination of 669 the costs of decontamination following a severe nuclear accident 670 is very complex, ISR's research and calculations led ISR to 671 conclude that Entergys use of Sample Problem A inputs, adjusted 672 for inflation, was not reasonable for IP.

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 30

673 Q: Did ISR evaluate other methods for calculating a 674 realistic CDNFRM that would be more applicable to IP?

675 A: Yes, ISR developed a methodology and four approaches 676 to calculate realistic CDNFRM values for IP.

677 (1) First, ISR divided the spatial grid defined in the 678 Entergy MACCS2 site input file into two discrete areas within 679 the 50 mile radius of IP for the purpose of evaluation. ISR 680 called these the NYC metropolitan area and the areas outside 681 of the NYC metropolitan area.

682 (2) Second, for each of these two areas, ISR calculated the 683 costs of light and/or heavy decontamination using the per square 684 kilometer decontamination costs obtained from the following four 685 sources:

686 Approach A is based on data from Site Restoration as 687 modified by Survey of Costs, which describe the results from US 688 plutonium dispersal tests; 689 Approach B relies upon data from Barbara Reichmuths 690 presentation of results from radiological dispersal device 691 economic consequence analysis in the US; 692 Approach C uses CONDO, a decontamination cost 693 estimation tool from the UK National Radiological Protection 694 Board, and its database; Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 31

695 Approach D relies upon data from RISO presenting 696 results from decontamination analyses completed by RISO National 697 Laboratory in Denmark.

698 (3) Third, for each approach, ISR calculated a single total 699 cost for light and/or heavy decontamination within the 50-mile 700 radius area of the IP power plant; 701 (4) Fourth, for each approach, ISR divided the total cost 702 by the total population, as reported by Entergy, in the 50-mile 703 radius area surrounding the IP power plant to obtain a per 704 capita cost for both light and heavy decontamination; and 705 (5) Fifth, ISR updated the per capita cost for each 706 approach to 2005 values, using the CPI. Figure 3 from the ISR 707 report, Exhibit NYS000242, is a flowchart which depicts ISR's 708 methodology and approaches for determining CDNFRM.

709 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 32

Approach A Approach C Approach D Site Restoration as modified by Survey of CONDO, RISO, Costs and ISR cost per km2 cost per km2 cost per km2 Cost per km2 for plutonium, for NYC metro Cost per km2 for cesium, area and elsewhere for a generic area ISR assuming CONDO, using area CONDO, using area DF (Pu) = DF (Cs) fractions for medium fractions for high and population densities population densities DF (Pu) = 1/2 DF (Cs)

Cost per km2 for cesium, Cost per km2 for cesium, for NYC metro area and for NYC metro area and elsewhere elsewhere Entergy Site file, using spatial grid areas Total cost for cesium, for entire 50-mi radius area Entergy Site file, using population data Per capita cost for cesium, for entire 50-mi radius area Approach B Value of CDNFRM Reichmuth (2005) Per capita cost for cesium, for NYC and Vancouver, Canada areas Per capita cost for cesium, for entire 50-mi radius area Entergy, from MACCS2 Sample Problem A (CPI adjusted) 710 711 Figure 3: ISRs methodology for determining light and heavy decontamination costs (CDNFRM) 712 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 33

713 714 1. Approach A: Site Restoration/Survey of Costs 715 Q: Please describe, in more detail, the first approach 716 ISR used to calculate CDNFRM.

717 A: Using approach A, which Ill refer to as Site 718 Restoration/Survey of Costs, ISR arrived at CDNFRM by modifying 719 the cost of decontamination values from Sandia's Site 720 Restoration using information from Lunas Survey of Costs and US 721 Census data.

722 Site Restoration used historical data from various actual 723 releases of plutonium and other radionuclides to derive the 724 costs of a cleanup following plutonium dispersal in an urban 725 area, namely Albuquerque, New Mexico. Site Restoration reported 726 five categories of land use: residential, commercial, 727 industrial, streets, and vacant land. In Site Restoration, 728 Sandia specifically recognized that the derivation 729 underestimates hyper-dense population areas such as NYC.

730 Survey of Costs subsequently used the Site Restoration 731 analysis as a basis for calculating the cost of cleanup of the 732 hyper-dense population area of interest here, NYC. To do this, 733 Survey of Costs used the actual area coverage percentage in NYC 734 for Site Restorations five categories of land use and then 735 multiplied the results by the population density ratio of NYC to Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 34

736 Albuquerque, to account for the greater structure density in 737 NYC. In Survey of Costs, Luna pre-supposes that building 738 density is directly proportional to population density.

739 ISRs calculation was a modification of both Site 740 Restoration and Survey of Costs. Instead of assuming that 741 building density is directly proportional to population density, 742 ISR used the actual building densities for NYC and Albuquerque 743 obtained from US Census data to modify Site Restoration and 744 Survey of Costs and arrive at a range of appropriate 745 decontamination costs. The average building density for the 746 five NYC boroughs is 13,980 buildings/mi2, compared to 1,557 747 buildings/mi2 for Albuquerque.

748 ISRs results are shown in Table 2 below, which was taken 749 from the ISR report, Exhibit NYS000242.

750 Table 2: Modified decontamination costs for NYC using building density multiplier Luna, Site Restoration Survey of (Albuquerque) ISR Using Actual Building Densities (NYC)

Costs Land Use Area Light Moderate Heavy Building Light Moderate Heavy Fraction (2<DF<5) (5<DF<10) (DF>10) Density (2<DF<5) (5<DF<10) (DF>10) in NYC ($M/km2) ($M/km2) ($M/km2) Multiplier ($M/km2) ($M/km2) ($M/km2)

Residential 0.287 $20.31 $45.99 $84.51 8.98 $182.38 $412.99 $758.90 Commercial 0.164 $32.09 $48.55 $139.84 8.98 $288.17 $435.98 $1,255.76 Industrial 0.068 $45.51 $47.55 $84.12 1.00 $45.51 $47.55 $84.12 Streets 0.250 $3.97 $4.62 $61.88 1.00 $3.97 $4.62 $61.88 Vacant land 0.238 $19.29 $20.38 $22.64 1.00 $19.29 $20.38 $22.64 Overall cost $121.17 $167.09 $392.99 $539.32 $921.52 $2,183.30 751 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 35

752 Q: You mentioned that Site Restoration used historical 753 data for plutonium and other radionuclides. Do the ability and 754 methods used to decontaminate vary depending on the 755 radionuclides involved in a radioactive release?

756 A: Yes. In fact, decontamination following any 757 radioactive release will vary considerably in cost depending on 758 the chosen DF and the isotope involved. Small-sized, soluble 759 cesium is more difficult to remove from porous surfaces than the 760 large-sized, insoluble radionuclides, such as plutonium.

761 Plutonium dispersion accidents such as those from nuclear 762 weapons, involve explosions that create large-sized aerosols.

763 Roughly half the aerosols produced by the explosive dispersion 764 of plutonium are larger than 30 microns. For particle sizes 765 larger than about 30 microns, gravitational settling is 766 important and the particles tend to deposit on the soil near the 767 site of the explosion. This limits the size of the zone to 768 decontaminate, increases the mass loading (g/m2) on the surfaces 769 to decontaminate, and limits their mobility in the environment.

770 On the other hand, severe reactor accidents create 771 relatively smaller-sized aerosols. Particle sizes of about 3.5 772 - 4 microns are typical for this process while for core debris 773 interactions with concrete they are typically around 1 micron.

774 The smaller particles have a lower deposition velocity and they Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 36

775 tend to disperse further downwind. Their concentration on the 776 surface is typically lower and the size of the zone to 777 decontaminate is larger.

778 Q: Why does cesium make decontamination challenging?

779 A: Soluble radionuclides such as cesium have the ability 780 to ion exchange with sodium and potassium present in materials 781 such as concrete. Thus, cesium will migrate rapidly into porous 782 materials such as concrete. Trials have shown that at a depth of 783 5mm into the material, their concentration is 50% of the surface 784 concentration. This migration, of course, increases with time 785 and, therefore, decontamination of cesium is more difficult as 786 more time passes after the event.

787 Q: In approach A, Site Restoration/Survey of Costs, did 788 ISR evaluate the effect of the different radionuclides expected 789 to be released from a nuclear accident in using the data from 790 Site Restoration?

791 A: Yes. Because Site Restoration derived the costs of a 792 cleanup following a plutonium dispersal, ISR determined that an 793 appropriate multiplicative factor for the overall costs shown 794 for plutonium in Table 2 is required to estimate the costs of 795 decontamination of cesium, which is the radionuclide of primary 796 concern in a severe nuclear accident.

797 Q: Did ISR compare DFs for cesium and plutonium?

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 37

798 A: Yes. First, ISR evaluated the results obtained from 799 one of the more recent Holt decontamination experiments 800 described in Exhibit NYS000259. In that experiment, Sandia 801 attempted to remove both cesium and plutonium from concrete 802 using a decontamination technique called strippable coatings.

803 Sandia's results show that using this technique, it could 804 achieve a DF of 1.2 for cesium and a DF of 5.8 for plutonium.

805 The results of this experiment indicate that cesium is about 806 five times more difficult to remove than plutonium.

807 Next, ISR evaluated the dataset from the CONDO software 808 tool. I'll discuss the CONDO tool in more detail when I discuss 809 approach C, but the key point Id like to make here is that the 810 DFs for cesium is always less or equal to the DFs for plutonium 811 in the CONDO dataset.

812 Based on the Sandia experiment and the CONDO dataset, ISR 813 determined that the DF for cesium may be smaller than the DF for 814 plutonium, as in the Sandia experiment, or equal to the DF for 815 plutonium, as in the CONDO dataset. ISR also concluded that 816 current data shows that the DF for cesium is never greater than 817 the DF for plutonium.

818 Q: In its approach A, Site Restoration/Survey of Costs, 819 calculations, how did ISR account for the likelihood that Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 38

820 cesium, and possibly small quantities of plutonium, will be 821 released if there is severe accident at IP?

822 A: In modifying the Site Restoration data, ISR considered 823 two cases: (1) the cost of cesium decontamination equals that of 824 plutonium, and (2) the cost of cesium decontamination is twice 825 that of plutonium. This assumes that the cost of 826 decontamination increases when a large DF is difficult to 827 achieve, as is the case for cesium. ISR's calculations for 828 CDNFRM employ both cases for the costs determined by Site 829 Restoration/Survey of Costs and are shown in Table 3 and Table 4 830 below which were taken from ISR's report, Exhibit NYS000242.

831 832 Table 3: Suggested values of CDNFRM assuming cost (cesium) = cost (plutonium) (costs in 2005 833 USD)

Light Decontamination (DF=3) Heavy Decontamination (DF=15)

Area Outside Area Outside NYC metro NYC metro NYC Metro Area NYC Metro Area Cost per km2 ($) from Site 5.39E+08 1.21E+08 2.18E+09 3.93E+08 Restoration/Survey of Costs Total area within 50-mi radius 356 19986 356 19986 (km2)

Total cost for the area ($) 1.92E+11 2.42E+12 7.77E+11 7.85E+12 Total cost over 50-mi radius 2.61E+12 8.63E+12

($)

Population over 50-mi radius 19,228,712 19,228,712 CDNFRM 135,927 448,889 Per capita cost ($, 2005) 834 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 39

835 Table 4: Suggested values of CDNFRM assuming cost (cesium) = 2 x cost (plutonium) (costs in 836 2005 USD)

Light Decontamination (DF=3) Heavy Decontamination (DF=15)

Area Outside Area Outside NYC metro NYC metro NYC Metro Area NYC Metro Area Cost per km2 ($) from Site 1.08E+09 2.42E+08 4.37E+09 7.86E+08 Restoration/Survey of Costs Total area within 50-mi radius 356 19986 356 19986 (km2)

Total cost for the area ($) 3.84E+11 4.84E+12 1.55E+12 1.57E+13 Total cost over 50-mi radius 5.23E+12 1.73E+13

($)

Population over 50-mi radius 19,228,712 19,228,712 CDNFRM 271,854 897,778 Per capita cost ($, 2005) 837 838 839 As you can see from the calculations in Tables 3 and 4, 840 ISRs modifications to Site Restoration/Survey of Costs results 841 in a range of appropriate values for CDNFRM. ISR has determined 842 that the 2005 adjusted cost of light decontamination would be 843 between $135,927 and $271,854 per person, while the cost of 844 heavy decontamination would be between $448,889 and $897,778 per 845 person.

846 Q: How does ISRs range of values calculated using 847 approach A compare to Entergys values?

848 A: The value used by Entergy, based on Sample Problem A 849 is much lower than the range calculated using approach A.

850 851 852 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 40

853 2. Approach B: Reichmuth 854 Q: Dr. Lemay, lets discuss the second approach ISR used 855 to determine CDNFRM. Please describe that approach.

856 A: Using approach B, which Ill refer to as Reichmuth, 857 ISR determined decontamination costs using current US data from 858 studies conducted by Barbara Reichmuth, Senior Research Engineer 859 at Pacific Northwest National Laboratory.

860 Q: What relevant studies did Barbara Reichmuth conduct?

861 A: Recognizing that cesium presents a major problem for 862 radiological decontamination, US Homeland Security and the EPA 863 commissioned studies (1) to identify the economic extent of the 864 threat of a cesium-based radiological dispersal device, which I 865 refer to as RDD, and (2) to determine the efficacy of novel 866 decontamination methods on cesium-contaminated surfaces.

867 Reichmuth has conducted many of these studies evaluating the 868 economic consequences of nuclear weapons and RDD effects on 869 major metropolitan centers in the US and Canada.

870 Of particular relevance here is Reichmuth's work with RDDs 871 involving cesium, Exhibit NYS000256. While ISR recognizes that 872 the mechanisms for dispersal differ between a reactor accident 873 and an RDD event, the key factor in determining cost for both is 874 removal of cesium from porous substances such as concrete found 875 in urban areas. In Exhibit NYS000256, Reichmuth derived costs Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 41

876 for an RDD event based on a dose rate limit for rehabitation, 877 which is similar to the HC used by Entergy in its MACCS2 code 878 inputs.

879 Q: How did ISR use the Reichmuth studies to determine an 880 appropriate CNDFRM value for IP?

881 A: The decontamination techniques proposed by Reichmuth 882 correspond to heavy decontamination. Therefore, using 883 Reichmuths results, the cost for nonfarm heavy decontamination 884 equivalent to Entergys DF of 15 would be between $200,000 and 885 $252,000 per person. Since Reichmuth assessed the costs of 886 cesium decontamination in NYC and Vancouver, these values are 887 directly relevant to the cost of remediation for an accident at 888 IP.

889 Q: How do Reichmuths decontamination costs compare to 890 Entergys CDNFRM inputs?

891 A: Reichmuths value is significantly higher than 892 Entergy's selected value of $13,824/person for heavy 893 decontamination.

894 3. Approach C: CONDO 895 Q: What was the third approach ISR used to determine 896 decontamination costs?

897 A: In approach C, ISR derived decontamination costs using 898 CONDO.

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 42

899 Q: What is CONDO?

900 A: CONDO, Exhibit NYS000250, is a software tool for 901 estimating the consequences of decontamination options. It was 902 developed by the National Radiological Protection Board, which 903 Ill refer to as NRPB, in the United Kingdom. CONDO is a 904 software linked to a database that gives the DFs, cost, and 905 labor required for the decontamination of cesium and plutonium 906 using several decontamination techniques.

907 Q: How does CONDO calculate decontamination costs?

908 A: CONDO includes a database which contains 909 decontamination costs per km2 of land. The database includes 910 costs for decontamination techniques as well as various types of 911 land areas like paved areas, buildings, trees, and many others.

912 The CONDO software can evaluate various scenarios of land use, 913 accounting for population density in those areas. The CONDO 914 model also accounts for building heights and vegetative cover.

915 Accounting for all these factors, CONDO calculates a total cost 916 of decontamination.

917 Q: Please describe in more detail how ISR used CONDO to 918 determine decontamination costs.

919 A: Because the NYC metropolitan area is comprised of both 920 urban and hyper-urban population densities, ISR performed 921 calculations in CONDO to obtain a range of decontamination Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 43

922 values for light decontamination, Entergys DF of 3, and heavy 923 decontamination, Entergys DF of 15.

924 For the first CONDO calculation, ISR assumed that the NYC 925 metropolitan area has an urban population density of greater 926 than 1,000 persons per km2, and everywhere else has a population 927 density less than 1,000 persons per km2. ISR performed this 928 calculation for light and heavy decontamination.

929 For the second calculation, ISR assumed that the NYC 930 metropolitan area has a hyper-urban population density of about 931 10,000 persons per km2, and everywhere else has a population 932 density between 1,000 and 10,000 persons per km2. ISR performed 933 this calculation for light and heavy decontamination.

934 Annex C to the ISR report, Exhibit NYS000242, contains the 935 details of ISRs CONDO calculations.

936 Q: What did ISR conclude based on the use of the CONDO 937 software?

938 A: Applying CONDO to the 50-mile area surrounding IP, the 939 cost of light decontamination would be between $19,000 and 940 $30,000 per person, while the cost of heavy decontamination 941 would be between $90,000 and $140,000 per person. The tables 942 below, taken from the ISR report Exhibit NYS000242, summarize 943 ISRs results for the CONDO approach.

944 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 44

945 Table 1: Costs using CONDO values assuming the NYC metro area is classified as urban and the 946 area outside the NYC metro area is classified as semi-urban (costs in 2005 USD)

Light Decontamination Heavy Decontamination (DF=3) (DF=15)

Area Outside Area Outside NYC NYC metro NYC metro NYC Metro Area Metro Area Cost per km2, ($)

2.78E+07 1.82E+07 1.31E+08 8.40E+07 (Annex C)

Total area (km2) 356 19986 356 19986 Total cost for the area ($) 9.90E+09 3.64E+11 4.66E+10 1.68E+12 Total cost over 50-mi radius 3.74E+11 1.73E+12

($)

Population over 50-mi radius 19,228,712 19,228,712 CDNFRM 19,431 89,734 Per capita cost ($, 2005) 947 948 Table 2: Costs using CONDO values assuming the NYC metro area is classified as hyper-urban 949 and the area outside the NYC metro area is classified as urban (costs in 2005 USD)

Light Decontamination Heavy Decontamination (DF=3) (DF=15)

Area Outside Area Outside NYC metro NYC metro NYC Metro Area NYC Metro Area Cost per km2, ($)

5.61E+07 2.78E+07 2.64E+08 1.31E+08 (Annex C)

Total area (km2) 356 19986 356 19986 Total cost for the area ($) 2.00E+10 5.56E+11 9.40E+10 2.62E+12 Total cost over 50-mi radius 5.76E+11 2.71E+12

($)

Population over 50-mi radius 19,228,712 19,228,712 CDNFRM 29,933 140,430 Per capita cost ($, 2005) 950 951 952 Q: How do the results ISR obtained using CONDO compare to 953 Entergys CDNFRM inputs?

954 A: The ranges from CONDO are higher than Entergy's 955 selected values of $5,184/person and $13,824/person for DFs of 3 956 and 15, respectively. These values were derived using population 957 densities and decontamination techniques relevant to the 958 remediation of an accident at IP.

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 45

959 960 4. Approach D: RISO 961 Q: Please describe the last approach ISR used to 962 determine CDNFRM.

963 A: For approach D, which Ill refer to as RISO, ISR 964 repeated the methodology used for the CONDO approach, but 965 substituted the costs per km2 reported by the Riso National 966 Laboratory, Exhibit NYS000251, for the costs reported in the 967 CONDO dataset.

968 RISO independently assessed decontamination costs for a 969 variety of decontamination techniques on a variety of surfaces 970 (pavement, grass, et). For this approach, ISR chose 971 decontamination techniques from RISO that most closely 972 correlated to those selected in the CONDO analysis. For each 973 type of area (hyper-urban, urban, semi-urban), the fraction of 974 land covered by a given type of surface was taken from CONDO, 975 and the cost per square km was calculated using the RISO values.

976 The rest of the cost evaluation used the same methodology as the 977 CONDO analysis I just described.

978 All of the RISO techniques are only recommended for light 979 decontamination. Thus, ISR did not use RISO to calculate CDNFRM 980 for heavy decontamination.

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 46

981 The RISO cost rates are provided in Annex C to the ISR 982 report, Exhibit NYS000242.

983 Q: What did ISR conclude from its use of RISO?

984 A: Using RISO, ISR determined that the cost of light 985 decontamination would be between $36,000 and $59,000 per person.

986 The following tables summarizing the RISO results and are taken 987 from the ISR report, Exhibit NYS000242.

988 Table 3: Costs using RISO values assuming the NYC metro area is classified as urban and the 989 area outside the NYC metro area is classified as semi-urban (costs in 2005 USD)

Light Decontamination (DF=3)

Area Outside NYC NYC metro Metro Area Cost per km2 ($) (Annex C) 5.46E+07 3.34E+07 2

Total area within 50-mi radius (km ) 356 19985 Total cost for the area ($) 1.94E+10 6.68E+11 Total cost over 50-mi radius ($) 6.87E+11 Population over 50-mi radius 19,228,712 CDNFRM 35,726 Per capita cost ($, 2005) 990 991 Table 4: Costs using RISO values assuming the NYC metro area is classified as hyper-urban and 992 the area outside the NYC metro area is classified as urban (costs in 2005 USD)

Light Decontamination (DF=3)

Area Outside NYC NYC metro Metro Area Cost per km2 ($)(Annex C) 1.17E+08 5.46E+07 2

Total area within 50-mi radius (km ) 356 19985 Total cost for the area ($) 4.17E+10 1.09E+12 Total cost over 50-mi radius ($) 1.13E+12 Population over 50-mi radius 19,228,712 CDNFRM 58,916 Per capita cost ($,2005) 993 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 47

994 Q: How do the results ISR obtained using RISO compare to 995 Entergys CDNFRM inputs?

996 A: The RISO-derived range is significantly higher than 997 Entergy's selected values of $5,184/person for light 998 decontamination. Although approach D (RISO) uses the same 999 methodology as approach C (CONDO), the underlying 1000 decontamination cost data was determined independently.

1001 5. Summary of ISR's Calculated Decontamination Costs 1002 Q: Have you completed describing the four approaches ISR 1003 used to calculate appropriate ranges of decontamination costs 1004 for IP?

1005 A: Yes.

1006 Q: Could you summarize the results of ISRs 1007 decontamination cost calculations?

1008 A: Yes. The following Table 11 and Figure 4, which are 1009 taken from the ISR report, Exhibit NYS000242, summarize the 1010 ranges of decontamination costs calculated by ISR. As you can 1011 see, the range of decontamination costs ISR calculated by using 1012 the four approaches I just described are much higher than the 1013 decontamination costs calculated by Entergy using Sample Problem 1014 A. In fact, none of the range of values calculated by ISR goes 1015 as low as the values used by Entergy. It is therefore likely Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 48

1016 that the decontamination costs used by Entergy in the MACCS2 1017 input file underestimate the cost of decontamination.

1018 Table 11: Summary of ISRs decontamination costs CDNFRM ($/person, 2005)

Approach Reference or Source of Data Light Decontamination Heavy Decontamination

- Entergy (Sample Problem A) 5,184 13,824 A Site Restoration/Luna 136,000 - 272,000 449,000 - 898,000 B Reichmuth Not available 200,000 - 252,000 C CONDO 19,000 - 30,000 90,000 - 140,000 D RISO 36,000 - 59,000 Not available

- Aggregate 19,000 - 272,000 90,000 - 898,000 1019

$1,000,000 Per capita non-farm decontamination cost

$900,000 Columns indicate the midpoint

$800,000 of the range represented by

$700,000 the high-low values

$600,000

$500,000

$400,000

$300,000

$200,000

$100,000 Entergy (Sample Chanin/Luna Reichmuth* CONDO RISO* Aggregate of the Problem A) four sources

• There was no data available for light Reference or source of data examined in this decontamination based on Reichmuth's report studies or for heavy decontamination Light decontamination Heavy decontamination based on RISO's studies 1020 1021 Figure 4: Graphical summary of decontamination costs with ranges 1022 1023 Q: Does the MACCS2 source code, as written, limit the 1024 decontamination cost input, CDNFRM, that can be calculated and 1025 considered?

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 49

1026 A: Yes, the MACCS2 code limits CDNFRM to a maximum of 1027 $100,000/person.

1028 Q: How did ISR calculate OECR given the fact that ISRs 1029 range of appropriate CDNFRM values exceeds $100,000 per person?

1030 A: ISR had to modify the MACCS2 source code to allow for 1031 the greater decontamination costs calculated by the approaches I 1032 just presented and which are discussed in its report. ISR found 1033 where the authors of the code had limited the value of CDNFRM to 1034 be less than $100,000 per person and removed this single line of 1035 code.

1036 Q: In the MACCS2 code, is there a point at which it is 1037 not longer cost-effective to decontaminate and property will be 1038 condemned instead of decontaminated?

1039 A: Yes. Once decontamination costs reach $200,000 per 1040 person, it will be more cost-effective to condemn property than 1041 to decontaminate according to the MACCS2 code calculations.

1042 Q: Could you explain how this happens?

1043 A: As shown in Figure 5 below, which was taken from the 1044 ISR report, Exhibit NYS000242, the OECR reaches a maximum when 1045 decontamination costs reach around $200,000/person. This is the 1046 threshold near which the cost of decontaminating equals that of 1047 condemning property. In the MACCS2 code, the cost of 1048 condemnation is governed by the value of nonfarm wealth, which I Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 50

1049 will discuss later on in my testimony. The value of nonfarm 1050 wealth is a user-defined value, set with input parameter VALWNF.

1051 Figure 5: OECR vs heavy decontamination cost 7.00E+05 6.00E+05 5.00E+05 OECR ($/yr) 4.00E+05 3.00E+05 2.00E+05 1.00E+05 0.00E+00 0 50 100 150 200 250 300 350 400 CDNFRM, DF=15 ($ thousand/person) 1052 1053 If the cost of heavy decontamination is greater than 1054 $200,000/person, the resulting OECR calculated by ISR is 1055 $581,000/year, which is 2.74 times the OECR calculated by 1056 Entergy ($212,000/year for IP2).

1057 3. Decontamination Time (TIMDEC) 1058 Q: Dr. Lemay, now that we have completed describing the 1059 work performed by ISR to evaluate the nonfarm decontamination 1060 cost input parameter to the MACCS2 code, can you please describe 1061 the next sensitive parameter ISR evaluated?

1062 A: Yes, the next sensitive parameter we evaluated was the 1063 Decontamination Time, which is called TIMDEC in the code.

1064 Q: What is TIMDEC?

1065 A: TIMDEC is a MACCS2 input parameter used by the code to 1066 account for the time it would take to decontaminate following a Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 51

1067 severe accident. The MACCS2 code requires users to input two 1068 decontamination times: one for the lower DF, and one for the 1069 higher DF. As discussed previously, DFs of 3 and 15 were used 1070 by Entergy and therefore, by ISR, in this analysis.

1071 Q: What inputs did Entergy use for the TIMDEC parameter?

1072 A: Once again, Entergy took its inputs directly from 1073 Sample Problem A. These inputs are 60 days for a DF of 3 and 1074 120 days for DF of 15.

1075 Q: How did ISR assess whether Entergys use of the Sample 1076 Problem A TIMDEC inputs of 60 and 120 days produced realistic 1077 costs for decontamination?

1078 A: ISR determined this by comparing Entergys inputs to 1079 two actual severe accidents: Chernobyl and Fukushima.

1080 For Chernobyl, large-scale decontamination of the area 1081 affected by the accident terminated four years after the 1082 accident. This included the decontamination of tens of 1083 thousands of buildings in the most contaminated cities and 1084 villages of the former USSR. Since large-scale decontamination 1085 efforts stopped prematurely is not possible for anyone to 1086 estimate what the total duration of a clean-up for the Chernobyl 1087 accident could have been.

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 52

1088 Although decontamination following the Fukushima nuclear 1089 accident has barely begun, some estimates suggests that the 1090 decontamination could last for decades.

1091 Q: How did ISR use the Chernobyl and Fukushima 1092 information in its calculations?

1093 A: ISR used the MACCS2 code to calculate the effect that 1094 increased decontamination times, TIMDEC, would have on cost.

1095 Figure 6 from the ISR report, Exhibit NYS000242, is a graphical 1096 depiction of the effect of decontamination time on cost in 1097 MACCS2. Figure 6 shows that OECR increases as TIMDEC increases.

1098 Total economic cost increases over time because relocation costs 1099 increase as decontamination time increases. As the OECR 1100 increases due to decontamination time, it becomes more cost-1101 effective to condemn infrastructure and buildings and therefore 1102 the OECR plateaus.

1.40E+06 1.20E+06 1.00E+06 OECR ($/yr) 8.00E+05 6.00E+05 4.00E+05 2.00E+05 0.00E+00 0 5 10 15 20 25 30 Decontamination (DF=15) time (years)

Decontamination (DF=3) time is half as long 1103 1104 Figure 6: OECR (2005 USD) for decontamination times up to 30 years Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 53

1105 1106 Q: Does the MACCS2 source code, as written, restrict the 1107 decontamination time, TIMDEC, input values?

1108 A: Yes, the MACCS2 code limits decontamination times to a 1109 maximum of one year. Thus, ISR had to modify the source code to 1110 allow for the likelihood that decontamination would take longer 1111 than the values from Sample Problem A and longer than one year.

1112 Q: What did ISR conclude from its assessment of Entergys 1113 TIMDEC inputs?

1114 A: ISR concluded that Entergys decontamination times of 1115 60 and 120 days, which were taken from Sample Problem A are 1116 unreasonable and have not been justified with supportive 1117 evidence. Considering large-scale decontamination took four 1118 years after Chernobyl, it is reasonable to expect that the 1119 decontamination time would be at least four years of continuous 1120 time for a severe accident at IP, which is surrounded by a much 1121 more densely populated and developed area that that which 1122 surrounds Chernobyl.

1123 It is difficult to give a precise estimate of the time it 1124 would take to decontaminate a large urban area after a severe 1125 nuclear accident, given the fact that the Chernobyl clean-up was 1126 stopped after 4 years and given estimates that the Fukushima 1127 clean-up could last several decades. In order to assess the Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 54

1128 impact of longer decontamination times, ISR calculated the OECR 1129 from a range of 2 to 15 years for a DF of 3 and a range of 4 to 1130 30 years for a DF of 15.

1131 ISR determined that for this range of decontamination 1132 times, if all other inputs by Entergy remain unchanged, the 1133 resulting OECR calculated by ISR is 3 to 5.7 times higher than 1134 the OECR calculated by Entergy (2.12E+05 $/year for IP2).

1135 C. Value of Nonfarm Wealth (VALWNF) 1136 Q: Please discuss the next sensitive parameter ISR 1137 evaluated.

1138 A: The next sensitive parameter evaluated by ISR was 1139 value of nonfarm wealth, which I'll call VALWNF. As I testified 1140 previously, in MACCS2, the total economic cost, and therefore 1141 the OECR, reaches a maximum for decontamination costs around 1142 $200,000/person. This value is important since it limits the 1143 cost of decontamination. If the cost of decontamination exceeds 1144 the nonfarm wealth, the buildings are condemned and the nonfarm 1145 wealth is added to the cost of the accident.

1146 Q: How does the MACCS2 code manual define VALWNF?

1147 A: According to the MACCS2 manual, the value of the 1148 nonfarm wealth in the region includes all public and private 1149 property not associated with farming that would be unusable if 1150 the region was rendered either temporarily or permanently Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 55

1151 uninhabitable. The MAACS2 manual specifies that VALWNF should 1152 include the cost of land, buildings, infrastructure, and the 1153 cost of any nonrecoverable equipment or machinery.

1154 In MACCS2, the user must enter the value of nonfarm wealth 1155 in two input files: (1) the site data input file requires a 1156 value of nonfarm wealth, VNFRM, for each economic region or in 1157 the case of NY, each county; (2) the CHRONC input file requires 1158 a value of nonfarm wealth, VALWNF, for the entire region of 1159 interest (i.e. the 50-mile radius zone) that is an aggregate of 1160 the VNFRM values. ISR determined that the OECR output value is 1161 not sensitive to changes in the VNFRM values entered in the site 1162 data input, but is sensitive to the VALWNF value entered in the 1163 CHRONC input file.

1164 Q: What value did Entergy use for VALWNF?

1165 A: $208,838 per person.

1166 Q: Was Entergys value for VALWNF derived from Sample 1167 Problem A?

1168 A: No. In fact, VALWNF, along with the value of farm 1169 wealth, VALWF, and the long-term exposure period, EXPTIM, was 1170 the only MACCS2 input value Entergy did not derive from Sample 1171 Problem A.

1172 Q: How did Entergy generate the VALWNF values?

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 56

1173 A: Entergy used a computer program called, SECPOP2000 as 1174 a starting point for its calculation of VALWNF.

1175 Q: What is SECPOP2000?

1176 A: SECPOP2000 is a sector population, land fraction and 1177 economic estimation program capable of generating MACCS2 input 1178 data. The SECPOP2000 calculation sums the Reproducible Tangible 1179 Wealth, value of the urban land, and farm household assets.

1180 Then SECPOP2000 subtracts the value of the farm assets, and 1181 divides by the entire population of the United States, resulting 1182 in a dollar/person value.

1183 Q: Why did Entergy use SECPOP2000 as a starting point for 1184 its calculation of VALWNF?

1185 A: According to Entergy, the VALWNF value cannot be 1186 readily calculated without recent data from the US Bureau of 1187 Economic Analysis, specifically data on reproducible tangible 1188 wealth. In the absence of this data, Entergy used SECPOP2000 to 1189 generate the original VNFRM values, as tabulated in Entergys 1190 report.

1191 Q: How did Entergy modify its SECPOP200-generated values?

1192 A: Entergy concluded that the SECPOP2000-provided values 1193 were not entirely adequate because SECPOP2000s database uses 1194 1997 economic data. In an effort to better represent the 1195 economic worth of the area, Entergy obtained the Gross County Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 57

1196 Product, GCP, or Gross Metro Product, GMP, values per spatial 1197 sector surrounding IP for the year 2004. Entergy divided the 1198 GCP by the population to obtain a value of GCP/person.

1199 Entergy then added this GCP/person value to the original 1200 VNFRM value to obtain a final VNFRM value. Entergy felt that 1201 adjusting the SECPOP2000 output using GCP better represents the 1202 economic worth of the area surrounding IP. Finally, Entergy 1203 weighted these values by population surrounding IP to obtain a 1204 final VALWNF value for use as the MACCS2 CHRONC input.

1205 Q: In ISRs opinion, are Entergys calculations of VALWNF 1206 complete?

1207 A: No, ISR concluded that Entergys calculations of 1208 VALWNF are outdated since the values obtained from SECPOP2000 1209 were not scaled up from 1997 values to 2004 values. It should be 1210 noted that for every other input parameter evaluation, the costs 1211 calculated by Entergy and by ISR are adjusted to 2005 dollars.

1212 In this instance, ISR adjusted the costs to 2004 to allow direct 1213 comparison with the Entergy estimates. The difference between 1214 2004 and 2005 costs is not significant.

1215 Q: How did ISR revise Entergys VALWNF calculation?

1216 ISR scaled the SECPOP VNFRM values from 1997 to 2004 1217 dollars by using the increase in GDP: $8,332 billion for 1997 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 58

1218 and $11,853 billion for 2004 [30], resulting in an increase by a 1219 factor of 1.43.

1220 All of the SECPOP2000 VNFRM values were increased by a 1221 factor of 1.43 to better represent economic worth in 2004 1222 dollars. The rest of the calculation followed with Entergys 1223 methodology. The GCP was then added to the SECPOP2000 to obtain 1224 VNFRM for each county.

1225 Q: What were the values that ISR obtained for VALWNF and 1226 how do they compare to Entergys values?

1227 A: The population-weighted sum of all counties in the 50-1228 mile radius around IP yields a VALWNF of $284,189 per person, 1229 which is higher than the value used by Entergy, which was 1230 $208,838. Using a VALWNF of $284,189 per person increases the 1231 final cost, OECR, by about 18%.

1232 D. Per capita cost of long-term relocation (POPCST) 1233 Q: What was the next parameter assessed by ISR?

1234 A: The next parameter assessed by ISR is the per capita 1235 cost of long-term relocation.

1236 Q: What value did Entergy use?

1237 A: Entergys use of the value of $8,640 was based on a 1238 CPI-adjustment to 2005 of a moving cost of $5,000 in 1986 found 1239 in NUREG/CR-4551. The cost of $5,000 is the average between a Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 59

1240 moving cost of $4,500 and the cost of 140 days of lost wages 1241 estimated as $5,600.

1242 Q: How did ISR assess the estimation of the cost of long-1243 term relocation used by Entergy?

1244 A: First, ISR agreed that the moving expenses would 1245 contribute very little to the cost of long-term relocation since 1246 the majority of the personal belongings would be contaminated.

1247 Second, ISR felt that given current unemployment benefits 1248 policies in the State of New York, it seemed that 140 days of 1249 lost wages was too low.

1250 New York State unemployment benefits normally last 26 weeks 1251 (182 days) and have recently been extended to 93 weeks (651 1252 days).

1253 Q: What value of lost wages did you use?

1254 A: ISR calculated the cost of long-term relocation by 1255 multiplying the 2005 average income per capita ($76/day) by a 1256 range of duration for the lost wages. The resulting cost 1257 $10,640/person (for 140 days of lost wages) to $49,857/person 1258 (for 93 weeks of lost wages).

1259 E. Other Sensitive Parameters 1260 Q: After evaluating POPCST, did ISR analyze any other 1261 MACCS2 parameters in detail?

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 60

1262 A: Yes. ISR evaluated the effect of the following 1263 additional sensitive parameters on the OECR: Property 1264 Depreciation Rate or DPRATE, Societal Discount Rate for Property 1265 or DSRATE, and Nonfarm Wealth Improvements Fraction or FRNFIM.

1266 Q: Did Entergy use Sample Problem A values for these 1267 parameters?

1268 A: Yes.

1269 Q: Did ISR also conclude that it was inappropriate to use 1270 Sample Problem A values for these input parameters?

1271 A: Yes, as I previously explained, the MACCS2 code is 1272 designed to calculate economic costs based on site-specific 1273 data. Entergy did not attempt to derive site-specific inputs 1274 for these parameters. Instead they relied upon Sample Problem A 1275 adjusted for inflation. As I discussed previously, these values 1276 were developed for the Surry site, and were not intended as 1277 default values.

1278 Q: What did ISR conclude from its evaluation of these 1279 parameters?

1280 A: Having evaluated alternative inputs for these 1281 sensitive parameters, ISR determined that Entergys use of 1282 Sample Problem A sometimes led Entergy to overestimate the OECR 1283 and sometimes led Entergy to underestimate the OECR. The 1284 overall effect of ISRs calculations using more appropriate Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 61

1285 values for the remaining sensitive parameters was negligible on 1286 the final OECR. A more detailed discussion of these 1287 calculations can be found in Section 4 of the ISR report, 1288 Exhibit NYS000242.

1289 VIII. ISR'S COMPARISON OF ENTERGYS MACCS2 INPUT VALUES WITH 1290 THOSE FROM OTHER NUCLEAR POWER PLANTS IN THE US 1291 Q: Dr. Lemay, did ISR review the MACCS2 input values used 1292 for the SAMA analysis at any other nuclear power plants in the 1293 US?

1294 A: Yes, we did. The ISR report provides a comparison of 1295 the MACCS2 input values used by Entergy with those of other 1296 nuclear power plant license applicants. Table 12 of the ISR 1297 report, Exhibit NYS000242, shows the values for parameters 1298 discussed in detail in the ISR report which are the most 1299 sensitive for cost determination. In the Table, ISR displays 1300 cost-parameter values in 2005 dollars, which was the reference 1301 year used for the IP analysis.

1302 Q: What was the purpose of performing this comparison?

1303 A: ISR was interested in comparing Entergys MACCS2 1304 inputs with those of other nuclear power plants to determine 1305 whether others relied upon Sample Problem A or developed site-1306 specific data.

1307 Q: What does this comparison show?

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 62

1308 Q: It appears that for all the other nuclear power plants 1309 for which ISR obtained data, values for the decontamination 1310 costs, CDNFRM, and relocation costs, POPCST, were determined by 1311 adjusting MACCS2 Sample Problem A values using CPI. The value 1312 of non-farm wealth, VALWNF, for the various plants appears to be 1313 site-specific, likely resulting from location census data. The 1314 decontamination times, TIMDEC; depreciation rate, DPRATE; rate 1315 of return, DSRATE; and fraction of non-farm wealth due to 1316 improvements, FRNFIM; are all equivalent to the values used in 1317 Sample Problem A.

1318 Q: What did ISR conclude from its comparison of Entergys 1319 input values to those of other nuclear power plants?

1320 A: It appears that no matter the specific location or 1321 attributes of the facility, the input values remain constant.

1322 This is because, with the exception of the value for VALWNF, 1323 they were derived from Sample Problem A. ISR has concluded that 1324 it is inappropriate to simply rely on Sample problem A for any 1325 and all power plants because the Sample Problem A inputs do not 1326 account for site-specific circumstances. For IP, a reliance on 1327 the generic Sample Problem A values has led to a significant 1328 underestimation of the costs of a severe accident.

1329 1330 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 63

1331 IX. ISRS RESPONSE TO NRC STAFF EVALUATION (FSEIS APPENDIX G) 1332 Q: Did ISR review NRC Staff's Evaluation of Severe 1333 Accident Mitigation Alternatives which is found in Appendix G to 1334 the FSEIS?

1335 A: Yes. NYS asked ISR to review and respond to the NRC 1336 Staff's discussion related to Contention 12 in Section G.2.3 of 1337 the FSEIS. Section G.2.3. of the FSEIS also discusses work that 1338 NRC Staff asked Sandia to complete. In connection with its 1339 review of Appendix G, ISR also reviewed a Sandia report provided 1340 to the NRC Staff, Exhibit NYS000218, on issues discussed in 1341 Appendix G.

1342 Q: Dr. Lemay, Id like to walk you through the NRC 1343 Staffs comments related to Contention 12 and ask you about 1344 ISRs response to those comments. Lets start on page G-23, 1345 lines 37-43. What is NRC Staff addressing here?

1346 A: NRC staff is responding to the portion of NYS 1347 Contention 12 where NYS asserts that the size of particles 1348 dispersed from a severe accident would be smaller than the 1349 particle size considered in MACCS2 and that it would be more 1350 expensive to decontaminate and clean up a suburban/urban area in 1351 which small-sized radionuclide particles have been dispersed.

1352 In their response, NRC Staff argued that they had reviewed the 1353 inputs and assumptions regarding particle size distribution and Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 64

1354 decontamination costs used in the SAMA analysis, and determined 1355 that the particle size utilized in the analysis was reasonable 1356 and acceptable.

1357 Q: What specific points does NRC Staff raise to support 1358 its position that the particle size utilized in Entergys SAMA 1359 analysis was reasonable and acceptable?

1360 A: The NRC Staff discusses the difference between the 1361 primary constituent in weapons grade plutonium and the primary 1362 contaminant from a severe accident at a nuclear plant. NRC 1363 Staff notes that plutonium is an alpha emitter thats more 1364 difficult and expensive to characterize and verify in the field 1365 than gamma emitters like cesium. Also, NRC Staff states that 1366 plutonium is primarily an inhalation hazard with a much longer 1367 half-life than cesium, which is primarily an external health 1368 hazard. According to NRC Staff, the need for evacuating the 1369 public is much greater with plutonium because if inhaled, the 1370 health consequences can be severe.

1371 Q: What is ISRs response to this NRC Staff comment?

1372 A: By discussing the expense associated with 1373 characterizing plutonium, NRC Staff implies that radionuclide 1374 detection and characterization is a large part of the 1375 decontamination costs. While detection and characterization of 1376 plutonium may be more costly than for cesium, it comprises a Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 65

1377 small part of decontamination costs, less than 1% of the 1378 decontamination costs, according to Exhibit NYS000249. The main 1379 cost of decontamination is not radionuclide 1380 detection/characterization, but decontamination, removal, 1381 transport and storage of waste and/or building demolition.

1382 NRC Staffs discussion of the need for evacuation is 1383 inappropriate because public evacuation and the associated costs 1384 are not part of the MACCS2 code's assessment of economic costs.

1385 The SAMA analysis includes the costs of longer-term dose 1386 reduction measures such as permanent relocation and 1387 decontamination. It is the cost of these measures that should be 1388 assessed for plutonium and cesium.

1389 Q: Thank you. Lets move on to Appendix G, page G-24, 1390 lines 7-11. What is NRC Staff's addressing here?

1391 A: NRC Staff is describing Sandias review of the 1392 decontamination methods discussed in Site Restoration. Sandia 1393 concluded that the activities in Site Restoration required to 1394 support clean-up of moderate plutonium contamination align more 1395 closely with clean-up activities for heavy cesium contamination.

1396 Thus, Sandia determined that decontamination cost values for 1397 moderate plutonium contamination are comparable to those for 1398 heavy cesium contamination.

1399 Q: What is ISRs response to this conclusion?

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 66

1400 A: NRC Staff and Sandia rely heavily on the cost of 1401 decontamination of a road to estimate the costs of 1402 decontamination of buildings, houses, soil and vegetation in 1403 urban areas. A review of the literature does not support this 1404 extrapolation. Our review of the literature shows that cesium is 1405 more difficult to remove from porous surfaces like concrete than 1406 plutonium.

1407 The concern for plutonium resuspension is due to the fact 1408 that it initially does not bind to surfaces because plutonium 1409 oxide is not readily soluble. This property also makes it 1410 initially easy to remove. Over time plutonium settles into the 1411 surface and resuspension becomes less significant.

1412 Data on plutonium resuspension shows that the initial 1413 inhalation health hazard goes down by a factor 10,000 over a few 1414 decades. After 30 years, the resuspension coefficient becomes 1415 negligible and the long term health hazard from plutonium is 1416 much less than for other radionuclides. Long-term control of 1417 contamination would likely be based on similar consideration for 1418 plutonium and cesium.

1419 A severe reactor accident will result in contamination 1420 containing fission products (cesium and other radionuclides) and 1421 actinides (plutonium). The choice of decontamination techniques 1422 will be based on an analysis of the exposure pathways for all Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 67

1423 these radionuclides. In some locations, the hazard from 1424 plutonium could be the driving factor while in other places the 1425 hazard from cesium could dominate. Any effective decontamination 1426 technique will result in some removal of cesium, plutonium and 1427 any other radionuclides. Therefore, using the example of road 1428 decontamination presented by Sandia, if complete removal of the 1429 road is justified for plutonium, it will also result in the full 1430 decontamination of cesium.

1431 Q: Lastly, lets discuss page G-24, lines 20 - 26. What 1432 is NRC Staff discussing here?

1433 A: NRC Staff uses the Site Restoration value of $178.4 1434 million/km2 for clean-up of moderate plutonium contamination in 1435 urban areas and divides that value by the population density of 1436 NYC to arrive at a cost of $14,900 per person. NRC Staff then 1437 compares this value to Entergys MACCS2 input of $13,824 per 1438 person for decontamination of heavy cesium contamination. NRC 1439 Staff concludes that the decontamination cost from Site 1440 Restoration "is not significantly different than the value used 1441 by Entergy in the SAMA analysis.

1442 Q: What is ISRs response to this NRC Staff comment?

1443 A: NRC Staffs analysis ignores the fact that NYC has a 1444 much higher building density than Albuquerque, the city upon 1445 which the Site Restoration cost figures are based. One cannot Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 68

1446 simply divide the Site Restoration decontamination cost per km2 1447 by population density to arrive at an accurate cost figure. By 1448 doing just that, NRC Staff has assumed that a cleanup of the 1449 same size contaminated area in Albuquerque would be the same as 1450 a contaminated area in New York City. This is simply not true.

1451 For a city such as NYC, building density must be taken into 1452 account. Survey of Costs proposed that the ratio of population 1453 densities of New York City to Albuquerque, the city upon which 1454 the Site Restoration data is based, be used to take building 1455 density in account. Since Entergy has questioned this 1456 assumption, ISR has found a better way to account for building 1457 density. As I explained when describing ISRs approach A for 1458 calculating decontamination costs, ISR used census values of 1459 building densities in Albuquerque and NYC to adjust the Site 1460 Restoration data. Using ISRs approach A, this leads to a cost 1461 of heavy decontamination between $449,000 and $898,000 per 1462 person.

1463 X.

SUMMARY

OF ISRS CONCLUSIONS REGARDING ENTERGY'S ANALYSIS 1464 AND NRC STAFF'S DISCUSSION OF THE COSTS RELATED TO A SEVERE 1465 ACCIDENT AT IP 1466 Q: Dr. Lemay, after reviewing and responding to Entergys 1467 calculation of the economic costs associated with a severe Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 69

1468 accident and the NRC Staffs comments, what conclusions did ISR 1469 ultimately reach?

1470 A: ISR concludes that Entergys input parameters to the 1471 MACCS2 code, which were accepted by NRC Staff, underestimated 1472 the total economic cost of a severe nuclear accident primarily 1473 because of the direct use of MACCS2 Sample Problem A input 1474 values for the CHRONC module. The underestimation was mostly 1475 due to costs and times for decontamination that were unrealistic 1476 given current known decontamination data and the complexities of 1477 an urban to hyper-urban area such as that surrounding IP.

1478 Q: Has ISR derived a more appropriate range of values for 1479 the MACCS2 input parameters?

1480 A: Yes. ISR has derived more appropriate values and 1481 calculated the effect on the MACCS2 output. A summary of the 1482 ISR-proposed range of inputs and calculated OECR for all of the 1483 sensitive parameters is provided in Table 13, reproduced below.

1484 For all cases, only a single input parameter is varied, keeping 1485 all others as determined by Entergy.

1486 1487 1488 1489 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 70

1490 Table 13: Summary of ISR proposed inputs and calculated OECRs (costs in 2005 USD)

Entergy's ISR's proposed input ISR's calculated OECR Parameter Description value value ($/yr) and ratioa Minimum Maximum Minimum Maximum Per capita cost of CDNFRM nonfarm light $5,184 $19,000 $272,000 (DF=3) decontamination 4.21E+05 1.25E+06 Per capita cost of (1.99) (5.88)

CDNFRM nonfarm heavy $13,824 $90,000 $898,000 (DF=15) decontamination TIMDEC Time required for light 60 d 2y 15 y (DF=3) decontamination 6.44E+05 1.20E+06 TIMDEC Time required for heavy (3.04) (5.66) 120 d 4y 30 y (DF=15) decontamination Per capita value of 2.51E+05 VALWNF nonfarm wealth (2004 $208,838 $284,189 (1.18)

USD) 2.12E+05 DPRATE Depreciation rate 20% 20%

(1.00)

Societal discount rate for 1.87E+05 1.95E+05 DSRATE 12% 5% 7%

property (0.88) (0.92)

Per capita cost of long- 2.23E+05 4.41E+05 POPCST $8,640 $10,640 $49,857 term relocation (1.05) (2.08)

Nonfarm wealth 2.19E+05 FRNFIM 80% 90%

improvements fraction (1.03) 9.07E+05 1.47E+06 Using all of ISRs proposed input values (4.28) (6.96)

Notes: a The ratio shown in brackets is the ratio of the ISR-calculated OECR to the Entergy-calculated OECR ($2.12E+05/yr).

1491 1492 Q: If all of the ISR proposed inputs are used, what is the 1493 effect on the OECR?

1494 A: The OECR is determined to be between 4 and 7 times the 1495 currently calculated Entergy value of $212,000/year.

1496 Q. Does this conclude your testimony?

1497 A. Yes.

1498 1499 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 71