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| issue date = 03/28/2012
| issue date = 03/28/2012
| title = Entergy Pre-Filed Evidentiary Hearing Exhibit ENT000027 - Rebuttal Commuter Analysis
| title = Entergy Pre-Filed Evidentiary Hearing Exhibit ENT000027 - Rebuttal Commuter Analysis
| author name = Potts L A, Riggs J L
| author name = Potts L, Riggs J
| author affiliation = Entergy Nuclear Operations, Inc
| author affiliation = Entergy Nuclear Operations, Inc
| addressee name =  
| addressee name =  
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{{#Wiki_filter:ENT000027 Submitted: March 28, 2012 Rebuttal Commuter Analyses - Region within 50 miles of IPEC Page 2 of 15 1.0 PurposeThis calculation provides technical input to the testimony on contention NYS-16B concerning the population estimate used in the IPEC SAMA analysis. It was prepared at direction of counsel with the following objectives. A. Duplicate Sheppard's commuter calculations.
{{#Wiki_filter:ENT000027 Submitted: March 28, 2012
B. Assess impact of possible double counting between long-distance commuters and business transients. C. Evaluate impact of commuters traveling out of the 50-mile region.

2.0 ConclusionsA. Duplicate Sheppard's commuter calculations. The values in columns 2-4 of Table 1 of Sheppard's Report agree with Entergy's SAMA population estimates in the ENERCON Report (see Section 6.1). The commuters-in values in Table 1 of Sheppard's Report were calculated using the methodology described in Sheppard's Report, except for the following discrepancy (see Section 6.1). Table 1 of Sheppard's Report underestimates the commuters into Union Co., NJ by 3,987 because an incorrect value for the 2000 resident population was used (552,541 instead of 522,541). This caused the growth rate for this county to be underestimated resulting in an underestimate of the 2035 commuters-in. B. Assess impact of possible double counting between long-distance commuters and business transients.

The data for commuters-in from the U.S. Census Bureau, County-to-County Worker Flow Files includes commuters into the 50-mile region from locations all over the country. If accounting for daily commuters was appropriate, it would not be reasonable to assume that people from more than 150 miles away commute into the region on a daily basis. Rather, these people are considered "business travelers."  Business travelers have already been included in the "transient population" in the ENERCON Report.Revising the analysis in Sheppard's Report to only count commuters-in from closer to the region (and correcting the Sheppard's Report underestimate for Union Co., NJ) decreased the number of commuters in Sheppard's Report to 964,093 (see Section

January2012
LoriAnnPottsandJerryL.
Riggs


6.2).C. Evaluate impact of commuters traveling out of the 50-mile region. Revising the analysis in Sheppard's Report to also account for commuters out of the region (in addition to the changes in B) decreased the net number of commuters into the 50-mile region to 110,663 (see Section 6.3).
Rebuttal Commuter Analyses - Region within 50 miles of IPEC 1.0 Purpose This calculation provides technical input to the testimony on contention NYS-16B concerning the population estimate used in the IPEC SAMA analysis. It was prepared at direction of counsel with the following objectives.
Rebuttal Commuter Analyses - Region within 50 miles of IPEC Page 3 of 15 The revised analysis resulted in a more accurate estimate of the "work day" population distribution within the 50-mile region. The following observations can be made. The four counties closest to IPEC (Orange, Putnam, Rockland, and Westchester), where doses would be higher, show a net reduction of over 100,000 commuters. Seven counties in the 50-mile region show a net increase in commuters. Of these seven counties; New York, NY county has a net increase of about 1.4 million commuters; Morris, NJ county has a net increase of about 40,000 commuters; Fairfield, CT and Essex, NJ counties each have a net increase of about 24,000 commuters; and the other three counties (Bergen, Middlesex, and Somerset, NJ) have a combined net increase of about 7,000 commuters.
A. Duplicate Sheppard's commuter calculations.
3.0 Input and Design Criteria3.1 Dr. Sheppard's Commuter CalculationsDr. Sheppard's commuter calculations are described in Reference 4.1, also known as "Sheppard's Report."Sheppard's Report describes his commuter calculations, using data from the U.S. Census Bureau,County-to-County Worker Flow Files available at http://www.census.gov/population/www/cen2000/commuting/index.html, as follows. "An additional deficiency in the SAMA report population estimates relates to the number of persons who would be present within 50 miles of IPEC during a substantial portion of the day, not because they permanently reside there, nor because they are transient overnight visitors to the area, but because they commute to workplaces that are within the area. Because such workers are part of the population potentially at risk from a severe accident, it is important to include them in the estimate of population in the area. In order to estimate the number of commuters, I use data on county-to-county commuter flows in 2000 made available by the Census Bureau. These data provide, for every county in the US, the estimated number of commuters coming into the county each day from any other individual county in the US. Thus these data can tell us how many commuters can be expected to come to workplaces within a 50 mile radius of IPEC from residential locations outside of this radius. Using these data, I estimated the total commuter flow into the area within 50 miles of IPEC by the following procedure: 1. For every county that is 100 percent within the 50 mile boundary:  a. Take 100 percent of the average daily commuter flows into that county that come from counties that are completely outside of the 50 mile boundary. b. Take (100-S) percent of the average daily commuter flows into that county that come from counties that have S percent of their area within the 50 mile boundary.
B. Assess impact of possible double counting between long-distance commuters and business transients.
Rebuttal Commuter Analyses - Region within 50 miles of IPEC Page 4 of 15 2. For every county that is partially within the 50 mile boundary, where P percent is the percentage of land area in the county located within 50 miles of IPEC: a. Take P percent of the average daily commuter flows into that county that come from counties that are completely outside the 50 mile boundary. b. Take Px(100-S) percent of the average daily commuter flows into that county that come from counties that have S percent of their area within the 50 mile boundary. Just as using the shares of land area within 50 miles of IPEC to adjust resident, transient, and undercounted population in each county was equivalent to assuming population in each county is uniformly distributed over the entire county, the steps outlined above add the assumption that employment locations are also distributed uniformly over the entire land area of each county. Thus, for example, if a county has 25 percent of its land area within 50 miles of IPEC and 100 commuters come into that county from a county that is entirely outside of the 50 mile radius, we count 25 commuters as being present within the area that is being evaluated for SAMA (the other 75 are known to work in the county, but are assumed to be employed outside of the 50 mile radius). If 200 commuters come into this same county from a different county that has 50 percent of its area within 50 miles of IPEC, then 100 of those commuters are counted as already residing within the 50 mile boundary (and thus they are already counted under the resident population total) and the other 100 are counted as persons coming from outside the 50 mile area. Of these, 25 are counted as having employment within the area evaluated for SAMA and the other 75 are counted as having employment farther than 50 miles from IPEC. This procedure provides estimates of the commuter population in 2000 into that portion of each county that is within 50 miles of IPEC. Taking the county population growth rates from 2000 to 2035 used in the original report as a conservative estimate of growth in county employment, we apply those growth rates to total commuter population for each county to obtain the estimates provided in column 6 of Table 1." Note that although it is not stated in Sheppard's Report, the calculations described in Section 6.1 indicate that the following is true. If 400 residents of this county (with 25 percent of its land area within 50 miles of IPEC) stay in the same county to work, 100 are counted as already residing within the 50 mile boundary (and thus they are already counted under the resident population total) and the other 300 are counted as persons residing outside the 50 mile area. Of these, 75 are counted as having employment within the area evaluated for SAMA and the other 225 are counted as having employment farther than 50 miles from IPEC. Table 1 of Sheppard's Report is reproduced below for convenient reference.
C. Evaluate impact of commuters traveling out of the 50-mile region.
Rebuttal Commuter Analyses - Region within 50 miles of IPEC Page 5 of 15 3.2 U.S. Census Bureau County-to-County Worker Flow FilesAs indicated in Sheppard's Report, these files areavailable at http://www.census.gov/population/www/cen2000/commuting/index.html. The files listed below for states with land area within 50 miles of IPEC (Connecticut, New Jersey, New York, and Pennsylvania) were downloaded from this website. Files showing the work destinations for people who live in each county of Connecticut, New Jersey, New York, and Pennsylvania: 2KRESCO_CT.xls 2KRESCO_NJ.xls 2KRESCO_NY.xls 2KRESCO_PA.xls Files showing the origins for people who work in each county of Connecticut, New Jersey, New York, and Pennsylvania:
2.0 Conclusions A. Duplicate Sheppard's commuter calculations.
Rebuttal Commuter Analyses - Region within 50 miles of IPEC Page 6 of 15 2KWRKCO_CT.xls 2KWRKCO_NJ.xls 2KWRKCO_NY.xls 2KWRKCO_PA.xls 3.3 Entergy's SAMA Population EstimatesEntergy's SAMA population estimates were developed in the "ENERCON Report," Reference 4.3. Tables 1.1, 2.1, and 2.3 of this document are reproduced below for convenient reference.
The values in columns 2-4 of Table 1 of Sheppards Report agree with Entergys SAMA population estimates in the ENERCON Report (see Section 6.1).
Rebuttal Commuter Analyses - Region within 50 miles of IPEC Page 7 of 15 Rebuttal Commuter Analyses - Region within 50 miles of IPEC Page 8 of 15 4.0References 4.1 REPORT OF DR. STEPHEN C. SHEPPARD, PH.D. IN SUPPORT OF CONTENTION NYS-16/16A/16B ("NYS-16B") In re: License Renewal Application Submitted by Entergy Nuclear Indian Point 2, LLC, Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear Operations, Inc. Docket Nos. 50-247-LR; 50-286-LR ASLBP No. 07-858-03-LR-BD01 DPR-26, DPR-64, December 16, 2011 4.2 U.S. Census Bureau, County-to-County Worker Flow Files available at http://www.census.gov/population/www/cen2000/commuting/index.html , downloaded January 10, 2012 4.3 Site Specific MACCS2 Input Data for Indian Point Energy Center, Revision 1 prepared for Entergy Nuclear Northeast by Enercon Services, Inc., Section 2.3, Page 2-5, Dec. 2009 Rebuttal Commuter Analyses - Region within 50 miles of IPEC Page 9 of 15 5.0 Assumptions5.1 Employment locations are distributed uniformly over the entire land area of each county. (Sheppard's Report also uses this assumption.) 5.2 Workers who commute out of a county come from locations distributed uniformly over the entire land area of the county. (Corollary to assumption 5.1.) 5.3 The county population growth rates from 2000 to 2035 used in Reference 4.2 are a conservative estimate of growth in county employment. (Sheppard's Report also
The commuters-in values in Table 1 of Sheppards Report were calculated using the methodology described in Sheppards Report, except for the following discrepancy (see Section 6.1).
x  Table 1 of Sheppards Report underestimates the commuters into Union Co.,
NJ by 3,987 because an incorrect value for the 2000 resident population was used (552,541 instead of 522,541). This caused the growth rate for this county to be underestimated resulting in an underestimate of the 2035 commuters-in.
B. Assess impact of possible double counting between long-distance commuters and business transients.
The data for commuters-in from the U.S. Census Bureau, County-to-County Worker Flow Files includes commuters into the 50-mile region from locations all over the country. If accounting for daily commuters was appropriate, it would not be reasonable to assume that people from more than 150 miles away commute into the region on a daily basis. Rather, these people are considered business travelers. Business travelers have already been included in the transient population in the ENERCON Report.
Revising the analysis in Sheppards Report to only count commuters-in from closer to the region (and correcting the Sheppards Report underestimate for Union Co., NJ) decreased the number of commuters in Sheppards Report to 964,093 (see Section 6.2).
C. Evaluate impact of commuters traveling out of the 50-mile region.
Revising the analysis in Sheppards Report to also account for commuters out of the region (in addition to the changes in B) decreased the net number of commuters into the 50-mile region to 110,663 (see Section 6.3).
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uses this assumption.) 5.4 The county population growth rates from 2000 to 2035 used in Reference 4.2 are a conservative estimate of growth in the number of people commuting out of the county. (Corollary to assumption 5.3.) 5.5 People who live more than 150 miles outside the 50-mile region do not commute into the region on a daily basis. Rather, these people are considered "business travelers."  The impact of excluding these business travelers can be approximated by excluding commuters from states other than Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island and Vermont.
Rebuttal Commuter Analyses - Region within 50 miles of IPEC The revised analysis resulted in a more accurate estimate of the work day population distribution within the 50-mile region. The following observations can be made.
6.0Method of Analysis and Calculations The calculations described below were performed within an Excel spreadsheet entitled "Duplicate Sheppard Analysis Spreadsheet.xlsx."  The worksheets mentioned below are within this spreadsheet. 6.1 Duplicate Sheppard's commuter calculations. 6.1.1 Verify that the values in columns 2-4 of Table 1 of Sheppard's Report agree with Entergy's SAMA population estimates in the ENERCON Report. See worksheet "Verify Sheppard Table 1 Input" for calculations.
x  The four counties closest to IPEC (Orange, Putnam, Rockland, and Westchester), where doses would be higher, show a net reduction of over 100,000 commuters.
The values in Column 2 of Table 1 of Sheppard's Report (Pct within 50 mi.) are equal to the (Percent within 50-mile zone) values in Table 1.1 of the ENERCON Report. No discrepancies noted. The values in Column 3 of Table 1 of Sheppard's Report (Resident Pop) are equal to the 2035 permanent population projection in Table 2.1 of the ENERCON Report times the Percent within 50-mile zone values. No discrepancies noted. The values in Column 4 of Table 1 of Sheppard's Report (Transient Pop) are equal to the 2035 total population projection in Table 2.3 of the ENERCON Report times the Percent within 50-mile zone values minus the Resident Pop. No discrepancies noted; only minor rounding differences. 6.1.2 For each of the 28 counties with area in the region, copy the records showing the origins for people who work in each county from the U.S.
x  Seven counties in the 50-mile region show a net increase in commuters. Of these seven counties; New York, NY county has a net increase of about 1.4 million commuters; Morris, NJ county has a net increase of about 40,000 commuters; Fairfield, CT and Essex, NJ counties each have a net increase of about 24,000 commuters; and the other three counties (Bergen, Middlesex, and Somerset, NJ) have a combined net increase of about 7,000 commuters.
Rebuttal Commuter Analyses - Region within 50 miles of IPEC Page 10 of 15 Census bureau files to a worksheet with the county name, state abbreviation and the words "commute in" such as "Fairfield, CT Commute
3.0 Input and Design Criteria 3.1        Dr. Sheppards Commuter Calculations Dr. Sheppards commuter calculations are described in Reference 4.1, also known as Sheppards Report.
Sheppards Report describes his commuter calculations, using data from the U.S. Census Bureau, County-to-County Worker Flow Files available at http://www.census.gov/population/www/cen2000/commuting/index.html, as follows.
An additional deficiency in the SAMA report population estimates relates to the number of persons who would be present within 50 miles of IPEC during a substantial portion of the day, not because they permanently reside there, nor because they are transient overnight visitors to the area, but because they commute to workplaces that are within the area. Because such workers are part of the population potentially at risk from a severe accident, it is important to include them in the estimate of population in the area.
In order to estimate the number of commuters, I use data on county-to-county commuter flows in 2000 made available by the Census Bureau. These data provide, for every county in the US, the estimated number of commuters coming into the county each day from any other individual county in the US. Thus these data can tell us how many commuters can be expected to come to workplaces within a 50 mile radius of IPEC from residential locations outside of this radius. Using these data, I estimated the total commuter flow into the area within 50 miles of IPEC by the following procedure:
: 1. For every county that is 100 percent within the 50 mile boundary:
: a. Take 100 percent of the average daily commuter flows into that county that come from counties that are completely outside of the 50 mile boundary.
: b. Take (100-S) percent of the average daily commuter flows into that county that come from counties that have S percent of their area within the 50 mile boundary.
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In."Worksheets labeled as described above were created by copying the appropriate lines from 2KWRKCO_CT.xls, 2KWRKCO_NJ.xls, 2KWRKCO_NY.xls, and 2KWRKCO_PA.xls. 6.1.3 In each county worksheet from 6.1.2 add a column entitled "Commuters In". For residence counties completely outside the 50 mile region, Commuters In = count (from the U.S. Census bureau file). For residence counties with area inside the 50 mile region, Commuters In = count * (100 - % of residence county within 50 miles)/100.Sum the "Commuters In" column.
Rebuttal Commuter Analyses - Region within 50 miles of IPEC
The "Commuters In" column in each county worksheet accounts for the percentage of the residence county that is within the 50 mile region (S in Sheppard's Report.) 6.1.4 In worksheet entitled "Section 6.1 Worksheet", calculate the number of commuters into each county in 2000 by taking the Sum of "Commuters In" column in the county worksheet, multiplying by the % within 50 miles and dividing by 100. Column E (2000 Commuters In Calculated) in worksheet "Section 6.1 Worksheet" contains this calculation which accounts for the percentage of the workplace county that is within the 50 mile region (P in Sheppard's
: 2. For every county that is partially within the 50 mile boundary, where P percent is the percentage of land area in the county located within 50 miles of IPEC:
: a. Take P percent of the average daily commuter flows into that county that come from counties that are completely outside the 50 mile boundary.
: b. Take Px(100-S) percent of the average daily commuter flows into that county that come from counties that have S percent of their area within the 50 mile boundary.
Just as using the shares of land area within 50 miles of IPEC to adjust resident, transient, and undercounted population in each county was equivalent to assuming population in each county is uniformly distributed over the entire county, the steps outlined above add the assumption that employment locations are also distributed uniformly over the entire land area of each county.
Thus, for example, if a county has 25 percent of its land area within 50 miles of IPEC and 100 commuters come into that county from a county that is entirely outside of the 50 mile radius, we count 25 commuters as being present within the area that is being evaluated for SAMA (the other 75 are known to work in the county, but are assumed to be employed outside of the 50 mile radius). If 200 commuters come into this same county from a different county that has 50 percent of its area within 50 miles of IPEC, then 100 of those commuters are counted as already residing within the 50 mile boundary (and thus they are already counted under the resident population total) and the other 100 are counted as persons coming from outside the 50 mile area. Of these, 25 are counted as having employment within the area evaluated for SAMA and the other 75 are counted as having employment farther than 50 miles from IPEC.
This procedure provides estimates of the commuter population in 2000 into that portion of each county that is within 50 miles of IPEC. Taking the county population growth rates from 2000 to 2035 used in the original report as a conservative estimate of growth in county employment, we apply those growth rates to total commuter population for each county to obtain the estimates provided in column 6 of Table 1.
Note that although it is not stated in Sheppards Report, the calculations described in Section 6.1 indicate that the following is true. If 400 residents of this county (with 25 percent of its land area within 50 miles of IPEC) stay in the same county to work, 100 are counted as already residing within the 50 mile boundary (and thus they are already counted under the resident population total) and the other 300 are counted as persons residing outside the 50 mile area. Of these, 75 are counted as having employment within the area evaluated for SAMA and the other 225 are counted as having employment farther than 50 miles from IPEC.
Table 1 of Sheppards Report is reproduced below for convenient reference.
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Report.)6.1.5 In the same worksheet (Section 6.1 Worksheet), calculate the county population growth rates from 2000 to 2035 using data from Table 2.1 of the ENERCON Report. Apply those growth rates to calculate the year 2035 commuters-in for each of the counties. Columns F, G, and H in worksheet "Section 6.1 Worksheet" calculate the population growth rate for each county. Column I (2035 Commuters In Calculated) applies those growth rates to the 2000 Commuter-In values to calculate the 2035 commuters-in for each county. 6.1.6 Compare the year 2035 commuters-in values in "Section 6.1 Worksheet" to the commuters-in values in Table 1 of Sheppard's Report. The commuters-in values in Table 1 of Sheppard's Report were reproduced in this calculation, except for the following discrepancy.
Rebuttal Commuter Analyses - Region within 50 miles of IPEC 3.2      U.S. Census Bureau County-to-County Worker Flow Files As indicated in Sheppards Report, these files are available at http://www.census.gov/population/www/cen2000/commuting/index.html. The files listed below for states with land area within 50 miles of IPEC (Connecticut, New Jersey, New York, and Pennsylvania) were downloaded from this website.
Rebuttal Commuter Analyses - Region within 50 miles of IPEC Page 11 of 15  Sheppard's Report underestimated the commuters into Union Co., NJ by 3,987 because he used an incorrect value for the 2000 resident population (552,541 instead of 522,541). This caused the growth rate for this county to be underestimated resulting in an underestimate of the 2035 commuters-in. 6.2 Assess impact of possible double counting between long-distance commuters and business transients. The calculations described below were performed within an Excel spreadsheet entitled "Rebuttal Commuter Analysis Spreadsheet.xlsx."  The worksheets mentioned below are within this spreadsheet. 6.2.1 Commuters originating from within a circle with a radius of 200 miles centered on the IPEC site are within 150 miles of the 50-mile region. This circle includes all or portions of the following states as well as portions of  
Files showing the work destinations for people who live in each county of Connecticut, New Jersey, New York, and Pennsylvania:
2KRESCO_CT.xls 2KRESCO_NJ.xls 2KRESCO_NY.xls 2KRESCO_PA.xls Files showing the origins for people who work in each county of Connecticut, New Jersey, New York, and Pennsylvania:
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Canada.Connecticut Maine Massachusetts New Hampshire New Jersey New York Pennsylvania Rhode Island Vermont To simplify the analysis, it was assumed that all commuters from the listed states are counted as commuters-in. This is a conservative assumption since some of the commuters from some of these states are more than 150 miles away from the 50-mile region. The conservatism is mitigated somewhat by the fact that the datasets from the U.S. Census Bureau, County-to-County Worker Flow Files do not account for commuters into the region from Canada. 6.2.2 Copy the spreadsheet used to calculate the commuters into the region in Section 6.1 (Duplicate Sheppard Analysis Spreadsheet.xlsx) to a new spreadsheet entitled "Rebuttal Commuter Analysis Spreadsheet.xlsx."
Rebuttal Commuter Analyses - Region within 50 miles of IPEC 2KWRKCO_CT.xls 2KWRKCO_NJ.xls 2KWRKCO_NY.xls 2KWRKCO_PA.xls 3.3      Entergys SAMA Population Estimates Entergys SAMA population estimates were developed in the ENERCON Report, Reference 4.3. Tables 1.1, 2.1, and 2.3 of this document are reproduced below for convenient reference.
Delete unnecessary worksheet "Verify Sheppard Table 1 Input" and change the name of "Section 6.1 Worksheet" to "Section 6.2 Worksheet". 6.2.3 Within each of the county worksheets (such as "Fairfield, CT Commute In"), delete line items for commuters coming from states other than those listed in Section 6.2.1. 6.2.4 Compare the year 2035 commuters-in values in worksheet "Section 6.2 Worksheet" to the commuters-in values in Table 1 of Sheppard's Report.
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Rebuttal Commuter Analyses - Region within 50 miles of IPEC Page 12 of 15 These results reflect the population values if the commuters from far away are not included. (They also correct the underestimate in the Sheppard's Report values for Union Co., NJ mentioned in Section 6.1.6. The italicized, underlined values in the following table are the corrected Sheppard's Report values.)The number of commuters-in decreased slightly to 964,093. See the following table. County %within 50 miles SheppardReport Table 1 Commuters SheppardReport Table 1 Total Pop 2000 Commuters InCalculated 2035 Commuters In Revised Revised Total Pop  Fairfield, CT 100.0 52,388990,91748,60550,590 989,119 Litchfield, CT 41.5 20,633112,32817,23720,559 112,254 New Haven, CT 32.9 85,165386,45978,06984,924 386,218 Bergen, NJ 100.0 30,8931,152,82623,19028,575 1,150,508 Essex, NJ 100.0 62,809966,29053,50858,571 962,052 Hudson, NJ 100.0 30,913747,24226,37929,931 746,260 Middlesex, NJ 1.8 7,73927,3255,4837,700 27,286 Morris, NJ 80.8 83,176625,31758,80081,682 623,823 Passaic, NJ 100.0 12,135584,72110,32711,686 584,272 Somerset, NJ 4.5 9,16930,9505,7669,112 30,893 Sussex, NJ 93.9 9,762219,4566,3649,621 219,315 Union, NJ 92.9 73,433640,30264,28072,654 639,523 Warren, NJ 0.5 2561,056168255 1,055 Bronx, NY 100.0 6,6831,698,7595,1266,288 1,698,364 Dutchess, NY 88.9 18,957311,09616,41718,716 310,855 Kings, NY 100.0 34,7402,736,07331,31233,257 2,734,590 Nassau, NY 97.9 78,7101,341,06381,88176,794 1,339,147 New York, NY 100.0 154,7931,768,987140,883143,950 1,758,144 Orange, NY 100.0 14,410472,49810,68413,934 472,022 Putnam, NY 100.0 1,251125,1069241,166 125,021 Queens, NY 100.0 47,2693,165,15430,94541,985 3,159,870 Richmond, NY 65.4 37,816480,30525,00237,348 479,837 Rockland, NY 100.0 1,779289,1951,5591,516 288,932 Suffolk, NY 21.3 87,491414,10683,04687,223 413,838 Sullivan, NY 36.3 6,72441,8355,2696,700 41,811 Ulster, NY 58.1 19,466152,36015,49619,411 152,305 Westchester, NY 100.0 8,702953,4407,5217,452 952,190 Pike, PA 18.7 2,50325,1081,1152,492 25,097Total  999,76520,460,274855,357964,093 20,424,6026.3 Evaluate impact of commuters traveling in and out of each county, and each partial county, in the 50-mile region.
 
Rebuttal Commuter Analyses - Region within 50 miles of IPEC Page 13 of 15 The calculations described below were performed within an Excel spreadsheet entitled "Rebuttal Commuter Analysis Spreadsheet.xlsx."  The worksheets mentioned below are within this spreadsheet. 6.3.1 For each of the 28 counties with area in the region, copy the records showing the work destinations for people who live in each county from the U.S. Census bureau files to a worksheet in Section 6.3 Spreadsheet.xlsx.
Rebuttal Commuter Analyses - Region within 50 miles of IPEC Page 7 of 15
Name each worksheet with the county name, state abbreviation and the words "commute out" such as "Fairfield, CT Commute Out." Worksheets labeled as described above were created by copying the appropriate lines from 2KRESCO_CT.xls, 2KRESCO _NJ.xls, 2KRESCO _NY.xls, and 2KRESCO _PA.xls. 6.3.2 In each "Commuters In" county worksheet created in Section 6.1, sum the commuters into the county and subtract the commuters from the county being analyzed. Commuters originating from Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island and Vermont were retained as commuters. Workers originating from other states were considered "business travelers" and were not counted as commuters. The commuters-in from counties that are only partially within the 50-mile region are not adjusted as was done in Sheppard's Report because that adjustment results in the workers remaining in their residence county. To get an accurate representation of the "work day" population in each county, the commuters are moved to their workplace county in this analysis. The commuters who live and work in the same county are not included in the calculation because there is no net change and these workers have already been included in the permanent population. 6.3.3 In each "Commuters Out" county worksheet, sum the commuters out of the county and subtract the commuters from the county being analyzed. All commuters leaving the county were counted as commuters out of the county. Workers going to places other than Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island and Vermont are actually "business travelers". But, since the original Entergy population estimates did not consider these business travelers, they are considered here to get a more accurate representation of the "work day" population in each county. The commuters who live and work in the same county are not included in the calculation because there is no net change and these workers have already been included in the permanent population. 6.3.4 In worksheet entitled "Section 6.3 Worksheet", calculate the net number of commuters into each county in 2000 by subtracting the commuters-out for Rebuttal Commuter Analyses - Region within 50 miles of IPEC Page 14 of 15 the county from the commuters-in for the county and multiplying by the fraction of the county within the 50-mile region. Column E (2000 Net Commuters In Calculated) in worksheet "Section 6.3 Worksheet" contains this calculation which accounts for the percentage of the workplace county that is within the 50 mile region. 6.3.5 In the same worksheet (Section 6.3 Worksheet), calculate the county population growth rates from 2000 to 2035 using data from Table 2.1 of the ENERCON Report. Apply those growth rates to calculate the year 2035 net commuters-in for each of the counties. Columns F, G, and H in worksheet "Section 6.3 Worksheet" calculate the population growth rate for each county. Column K (2035 Net Commuters In Calculated) applies those growth rates to the 2000 net commuters-in values to calculate the 2035 net commuters-in for each county. 6.3.6 Compare the "2035 Net Commuters In Calculated" values in worksheet "Section 6.3 Worksheet" to the commuters-in values in Table 1 of Sheppard's Report. These results reflect the population values if the commuters and business travelers out of the region are not included. They also assume that commuters-in from far away are not included. (They also correct the underestimate in the Sheppard's Report values for Union Co., NJ mentioned in Section 6.1.6. The italicized, underlined values in the following table are the corrected Sheppard's Report values.) The revised number of commuters decreased to 110,663. See the following table. The revised analysis resulted in a more accurate estimate of the "work day" population distribution within the 50-mile region. The following observations can be made. The four counties closest to IPEC (Orange, Putnam, Rockland, and Westchester), where doses would be higher, show a net reduction of over 100,000 commuters. Seven counties in the 50-mile region show a net increase in commuters. Of these seven counties; New York, NY county has a net increase of about 1.4 million commuters; Morris, NJ county has a net increase of about 40,000 commuters; Fairfield, CT and Essex, NJ counties each have a net increase of about 24,000 commuters; and the other three counties (Bergen, Middlesex, and Somerset, NJ) have a combined net increase of about 7,000 commuters.
 
Rebuttal Commuter Analyses - Region within 50 miles of IPEC Page 15 of 15 County % within 50 miles SheppardReport Table 1 Commuters SheppardReport Table 1 Total Pop 2000 Net Commuters InCalculated 2035 Net Commuters InCalculated Revised Total Pop  Fairfield, CT 100.0 52,388990,91722,98523,923 962,452 Litchfield, CT 41.5 20,633112,328-9,849-11,748 79,947 New Haven, CT 32.9 85,165386,459-8,750-9,518 291,776 Bergen, NJ 100.0 30,8931,152,8265,2556,475 1,128,408 Essex, NJ 100.0 62,809966,29022,10124,192 927,673 Hudson, NJ 100.0 30,913747,242-30,716-34,852 681,477 Middlesex, NJ 1.8 7,73927,32591128 19,714 Morris, NJ 80.8 83,176625,31728,92240,178 582,319 Passaic, NJ 100.0 12,135584,721-37,557-42,499 530,087 Somerset, NJ 4.5 9,16930,950458723 22,504 Sussex, NJ 93.9 9,762219,456-30,872-46,672 163,022 Union, NJ 92.9 73,433640,302-9,536-10,779 556,090 Warren, NJ 0.5 2561,056-65-99 701 Bronx, NY 100.0 6,6831,698,759-134,458-164,938 1,527,138 Dutchess, NY 88.9 18,957311,096-12,731-14,515 277,624 Kings, NY 100.0 34,7402,736,073-234,946-249,536 2,451,797 Nassau, NY 97.9 78,7101,341,063-65,769-61,684 1,200,669 New York, NY 100.0 154,7931,768,9871,326,1961,355,065 2,969,259 Orange, NY 100.0 14,410472,498-25,195-32,861 425,227 Putnam, NY 100.0 1,251125,106-24,242-30,570 93,285 Queens, NY 100.0 47,2693,165,154-339,054-460,013 2,657,872 Richmond, NY 65.4 37,816480,305-46,683-69,735 372,754 Rockland, NY 100.0 1,779289,195-31,597-30,721 256,695 Suffolk, NY 21.3 87,491414,106-23,091-24,253 302,362 Sullivan, NY 36.3 6,72441,835-2,155-2,740 32,371 Ulster, NY 58.1 19,466152,360-9,919-12,425 120,469 Westchester, NY100.0 8,702953,440-25,396-25,162 919,576 Pike, PA 18.7 2,50325,108-2,105-4,703 17,902Total 999,76520,460,274301,320110,663 19,571,172}}
Rebuttal Commuter Analyses - Region within 50 miles of IPEC 4.0 References 4.1    REPORT OF DR. STEPHEN C. SHEPPARD, PH.D. IN SUPPORT OF CONTENTION NYS-16/16A/16B (NYS-16B) In re: License Renewal Application Submitted by Entergy Nuclear Indian Point 2, LLC, Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear Operations, Inc. Docket Nos. 50-247-LR; 50-286-LR ASLBP No. 07-858-03-LR-BD01 DPR-26, DPR-64, December 16, 2011 4.2   U.S. Census Bureau, County-to-County Worker Flow Files available at http://www.census.gov/population/www/cen2000/commuting/index.html, downloaded January 10, 2012 4.3    Site Specific MACCS2 Input Data for Indian Point Energy Center, Revision 1 prepared for Entergy Nuclear Northeast by Enercon Services, Inc., Section 2.3, Page 2-5, Dec. 2009 Page 8 of 15
 
Rebuttal Commuter Analyses - Region within 50 miles of IPEC 5.0 Assumptions 5.1   Employment locations are distributed uniformly over the entire land area of each county. (Sheppards Report also uses this assumption.)
5.2    Workers who commute out of a county come from locations distributed uniformly over the entire land area of the county. (Corollary to assumption 5.1.)
5.3    The county population growth rates from 2000 to 2035 used in Reference 4.2 are a conservative estimate of growth in county employment. (Sheppards Report also uses this assumption.)
5.4    The county population growth rates from 2000 to 2035 used in Reference 4.2 are a conservative estimate of growth in the number of people commuting out of the county. (Corollary to assumption 5.3.)
5.5    People who live more than 150 miles outside the 50-mile region do not commute into the region on a daily basis. Rather, these people are considered business travelers. The impact of excluding these business travelers can be approximated by excluding commuters from states other than Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island and Vermont.
6.0 Method of Analysis and Calculations The calculations described below were performed within an Excel spreadsheet entitled Duplicate Sheppard Analysis Spreadsheet.xlsx. The worksheets mentioned below are within this spreadsheet.
6.1      Duplicate Sheppard's commuter calculations.
6.1.1   Verify that the values in columns 2-4 of Table 1 of Sheppards Report agree with Entergys SAMA population estimates in the ENERCON Report.
See worksheet Verify Sheppard Table 1 Input for calculations.
The values in Column 2 of Table 1 of Sheppards Report (Pct within 50 mi.)
are equal to the (Percent within 50-mile zone) values in Table 1.1 of the ENERCON Report. No discrepancies noted.
The values in Column 3 of Table 1 of Sheppards Report (Resident Pop) are equal to the 2035 permanent population projection in Table 2.1 of the ENERCON Report times the Percent within 50-mile zone values. No discrepancies noted.
The values in Column 4 of Table 1 of Sheppards Report (Transient Pop) are equal to the 2035 total population projection in Table 2.3 of the ENERCON Report times the Percent within 50-mile zone values minus the Resident Pop. No discrepancies noted; only minor rounding differences.
6.1.2  For each of the 28 counties with area in the region, copy the records showing the origins for people who work in each county from the U.S.
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Rebuttal Commuter Analyses - Region within 50 miles of IPEC Census bureau files to a worksheet with the county name, state abbreviation and the words commute in such as Fairfield, CT Commute In.
Worksheets labeled as described above were created by copying the appropriate lines from 2KWRKCO_CT.xls, 2KWRKCO_NJ.xls, 2KWRKCO_NY.xls, and 2KWRKCO_PA.xls.
6.1.3 In each county worksheet from 6.1.2 add a column entitled Commuters In.
For residence counties completely outside the 50 mile region, Commuters In = count (from the U.S. Census bureau file).
For residence counties with area inside the 50 mile region, Commuters In = count * (100 - % of residence county within 50 miles)/100.
Sum the Commuters In column.
The Commuters In column in each county worksheet accounts for the percentage of the residence county that is within the 50 mile region (S in Sheppards Report.)
6.1.4  In worksheet entitled Section 6.1 Worksheet, calculate the number of commuters into each county in 2000 by taking the Sum of Commuters In column in the county worksheet, multiplying by the % within 50 miles and dividing by 100.
Column E (2000 Commuters In Calculated) in worksheet Section 6.1 Worksheet contains this calculation which accounts for the percentage of the workplace county that is within the 50 mile region (P in Sheppards Report.)
6.1.5 In the same worksheet (Section 6.1 Worksheet), calculate the county population growth rates from 2000 to 2035 using data from Table 2.1 of the ENERCON Report. Apply those growth rates to calculate the year 2035 commuters-in for each of the counties.
Columns F, G, and H in worksheet Section 6.1 Worksheet calculate the population growth rate for each county. Column I (2035 Commuters In Calculated) applies those growth rates to the 2000 Commuter-In values to calculate the 2035 commuters-in for each county.
6.1.6  Compare the year 2035 commuters-in values in Section 6.1 Worksheet to the commuters-in values in Table 1 of Sheppards Report.
The commuters-in values in Table 1 of Sheppards Report were reproduced in this calculation, except for the following discrepancy.
Page 10 of 15
 
Rebuttal Commuter Analyses - Region within 50 miles of IPEC x    Sheppards Report underestimated the commuters into Union Co.,
NJ by 3,987 because he used an incorrect value for the 2000 resident population (552,541 instead of 522,541). This caused the growth rate for this county to be underestimated resulting in an underestimate of the 2035 commuters-in.
6.2    Assess impact of possible double counting between long-distance commuters and business transients.
The calculations described below were performed within an Excel spreadsheet entitled Rebuttal Commuter Analysis Spreadsheet.xlsx. The worksheets mentioned below are within this spreadsheet.
6.2.1  Commuters originating from within a circle with a radius of 200 miles centered on the IPEC site are within 150 miles of the 50-mile region. This circle includes all or portions of the following states as well as portions of Canada.
Connecticut Maine Massachusetts New Hampshire New Jersey New York Pennsylvania Rhode Island Vermont To simplify the analysis, it was assumed that all commuters from the listed states are counted as commuters-in. This is a conservative assumption since some of the commuters from some of these states are more than 150 miles away from the 50-mile region. The conservatism is mitigated somewhat by the fact that the datasets from the U.S. Census Bureau, County-to-County Worker Flow Files do not account for commuters into the region from Canada.
6.2.2  Copy the spreadsheet used to calculate the commuters into the region in Section 6.1 (Duplicate Sheppard Analysis Spreadsheet.xlsx) to a new spreadsheet entitled Rebuttal Commuter Analysis Spreadsheet.xlsx.
Delete unnecessary worksheet Verify Sheppard Table 1 Input and change the name of Section 6.1 Worksheet to Section 6.2 Worksheet.
6.2.3  Within each of the county worksheets (such as Fairfield, CT Commute In),
delete line items for commuters coming from states other than those listed in Section 6.2.1.
6.2.4  Compare the year 2035 commuters-in values in worksheet Section 6.2 Worksheet to the commuters-in values in Table 1 of Sheppards Report.
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Rebuttal Commuter Analyses - Region within 50 miles of IPEC These results reflect the population values if the commuters from far away are not included. (They also correct the underestimate in the Sheppards Report values for Union Co., NJ mentioned in Section 6.1.6. The italicized, underlined values in the following table are the corrected Sheppards Report values.)
The number of commuters-in decreased slightly to 964,093. See the following table.
                      %                                        2000 Sheppard      Sheppard                        2035 within                                    Commuters                      Revised County                    Report Table  Report Table                  Commuters 50                                          In                      Total Pop 1 Commuters    1 Total Pop                    In Revised miles                                    Calculated Fairfield, CT        100.0          52,388        990,917        48,605        50,590      989,119 Litchfield, CT         41.5          20,633        112,328        17,237        20,559      112,254 New Haven, CT                    32.9          85,165        386,459        78,069        84,924      386,218 Bergen, NJ            100.0         30,893      1,152,826        23,190        28,575    1,150,508 Essex, NJ            100.0          62,809        966,290        53,508        58,571      962,052 Hudson, NJ            100.0          30,913        747,242        26,379        29,931      746,260 Middlesex, NJ           1.8          7,739        27,325          5,483        7,700      27,286 Morris, NJ             80.8          83,176        625,317        58,800        81,682      623,823 Passaic, NJ           100.0         12,135        584,721        10,327        11,686      584,272 Somerset, NJ           4.5          9,169        30,950          5,766        9,112      30,893 Sussex, NJ            93.9          9,762        219,456          6,364        9,621      219,315 Union, NJ             92.9          73,433        640,302        64,280        72,654      639,523 Warren, NJ             0.5             256          1,056            168          255        1,055 Bronx, NY            100.0          6,683      1,698,759          5,126        6,288    1,698,364 Dutchess, NY          88.9         18,957        311,096        16,417        18,716      310,855 Kings, NY             100.0         34,740      2,736,073        31,312        33,257    2,734,590 Nassau, NY            97.9          78,710      1,341,063        81,881        76,794    1,339,147 New York, NY          100.0        154,793      1,768,987        140,883        143,950    1,758,144 Orange, NY          100.0          14,410        472,498        10,684        13,934      472,022 Putnam, NY            100.0          1,251        125,106            924        1,166      125,021 Queens, NY          100.0          47,269      3,165,154        30,945        41,985    3,159,870 Richmond, NY          65.4          37,816        480,305        25,002        37,348      479,837 Rockland, NY          100.0          1,779        289,195          1,559        1,516      288,932 Suffolk, NY            21.3          87,491        414,106        83,046        87,223      413,838 Sullivan, NY          36.3          6,724        41,835          5,269        6,700      41,811 Ulster, NY            58.1          19,466        152,360        15,496        19,411      152,305 Westchester, NY                    100.0          8,702        953,440          7,521        7,452      952,190 Pike, PA              18.7          2,503        25,108          1,115        2,492      25,097 Total                              999,765    20,460,274        855,357        964,093  20,424,602 6.3      Evaluate impact of commuters traveling in and out of each county, and each partial county, in the 50-mile region.
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Rebuttal Commuter Analyses - Region within 50 miles of IPEC The calculations described below were performed within an Excel spreadsheet entitled Rebuttal Commuter Analysis Spreadsheet.xlsx. The worksheets mentioned below are within this spreadsheet.
6.3.1  For each of the 28 counties with area in the region, copy the records showing the work destinations for people who live in each county from the U.S. Census bureau files to a worksheet in Section 6.3 Spreadsheet.xlsx.
Name each worksheet with the county name, state abbreviation and the words commute out such as Fairfield, CT Commute Out.
Worksheets labeled as described above were created by copying the appropriate lines from 2KRESCO_CT.xls, 2KRESCO _NJ.xls, 2KRESCO
_NY.xls, and 2KRESCO _PA.xls.
6.3.2  In each Commuters In county worksheet created in Section 6.1, sum the commuters into the county and subtract the commuters from the county being analyzed.
Commuters originating from Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island and Vermont were retained as commuters. Workers originating from other states were considered business travelers and were not counted as commuters.
The commuters-in from counties that are only partially within the 50-mile region are not adjusted as was done in Sheppards Report because that adjustment results in the workers remaining in their residence county. To get an accurate representation of the work day population in each county, the commuters are moved to their workplace county in this analysis.
The commuters who live and work in the same county are not included in the calculation because there is no net change and these workers have already been included in the permanent population.
6.3.3  In each Commuters Out county worksheet, sum the commuters out of the county and subtract the commuters from the county being analyzed.
All commuters leaving the county were counted as commuters out of the county. Workers going to places other than Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island and Vermont are actually business travelers. But, since the original Entergy population estimates did not consider these business travelers, they are considered here to get a more accurate representation of the work day population in each county.
The commuters who live and work in the same county are not included in the calculation because there is no net change and these workers have already been included in the permanent population.
6.3.4  In worksheet entitled Section 6.3 Worksheet, calculate the net number of commuters into each county in 2000 by subtracting the commuters-out for Page 13 of 15
 
Rebuttal Commuter Analyses - Region within 50 miles of IPEC the county from the commuters-in for the county and multiplying by the fraction of the county within the 50-mile region.
Column E (2000 Net Commuters In Calculated) in worksheet Section 6.3 Worksheet contains this calculation which accounts for the percentage of the workplace county that is within the 50 mile region.
6.3.5  In the same worksheet (Section 6.3 Worksheet), calculate the county population growth rates from 2000 to 2035 using data from Table 2.1 of the ENERCON Report. Apply those growth rates to calculate the year 2035 net commuters-in for each of the counties.
Columns F, G, and H in worksheet Section 6.3 Worksheet calculate the population growth rate for each county. Column K (2035 Net Commuters In Calculated) applies those growth rates to the 2000 net commuters-in values to calculate the 2035 net commuters-in for each county.
6.3.6  Compare the 2035 Net Commuters In Calculated values in worksheet Section 6.3 Worksheet to the commuters-in values in Table 1 of Sheppards Report.
These results reflect the population values if the commuters and business travelers out of the region are not included. They also assume that commuters-in from far away are not included. (They also correct the underestimate in the Sheppards Report values for Union Co., NJ mentioned in Section 6.1.6. The italicized, underlined values in the following table are the corrected Sheppards Report values.)
The revised number of commuters decreased to 110,663. See the following table.
The revised analysis resulted in a more accurate estimate of the work day population distribution within the 50-mile region. The following observations can be made.
x  The four counties closest to IPEC (Orange, Putnam, Rockland, and Westchester), where doses would be higher, show a net reduction of over 100,000 commuters.
x  Seven counties in the 50-mile region show a net increase in commuters. Of these seven counties; New York, NY county has a net increase of about 1.4 million commuters; Morris, NJ county has a net increase of about 40,000 commuters; Fairfield, CT and Essex, NJ counties each have a net increase of about 24,000 commuters; and the other three counties (Bergen, Middlesex, and Somerset, NJ) have a combined net increase of about 7,000 commuters.
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Rebuttal Commuter Analyses - Region within 50 miles of IPEC Sheppard    Sheppard      2000 Net      2035 Net
                % within 50    Report      Report    Commuters      Commuters      Revised County miles      Table 1    Table 1        In            In      Total Pop Commuters    Total Pop    Calculated    Calculated Fairfield, CT          100.0      52,388    990,917        22,985        23,923    962,452 Litchfield, CT          41.5      20,633    112,328        -9,849        -11,748      79,947 New Haven, 32.9      85,165    386,459        -8,750          -9,518    291,776 CT Bergen, NJ            100.0      30,893  1,152,826        5,255          6,475  1,128,408 Essex, NJ              100.0      62,809    966,290        22,101        24,192    927,673 Hudson, NJ            100.0      30,913    747,242      -30,716        -34,852    681,477 Middlesex, NJ            1.8      7,739      27,325            91            128    19,714 Morris, NJ              80.8      83,176    625,317        28,922        40,178    582,319 Passaic, NJ            100.0      12,135    584,721      -37,557        -42,499    530,087 Somerset, NJ            4.5      9,169      30,950          458            723    22,504 Sussex, NJ              93.9      9,762    219,456      -30,872        -46,672    163,022 Union, NJ              92.9      73,433    640,302        -9,536        -10,779    556,090 Warren, NJ              0.5        256      1,056          -65            -99        701 Bronx, NY              100.0      6,683  1,698,759      -134,458      -164,938  1,527,138 Dutchess, NY            88.9      18,957    311,096      -12,731        -14,515    277,624 Kings, NY              100.0      34,740  2,736,073      -234,946      -249,536  2,451,797 Nassau, NY              97.9      78,710  1,341,063      -65,769        -61,684  1,200,669 New York, NY           100.0     154,793  1,768,987    1,326,196      1,355,065   2,969,259 Orange, NY             100.0     14,410    472,498       -25,195       -32,861     425,227 Putnam, NY             100.0       1,251    125,106       -24,242       -30,570     93,285 Queens, NY             100.0     47,269  3,165,154     -339,054       -460,013   2,657,872 Richmond, NY           65.4     37,816    480,305       -46,683       -69,735     372,754 Rockland, NY           100.0       1,779    289,195       -31,597       -30,721     256,695 Suffolk, NY             21.3     87,491    414,106       -23,091       -24,253     302,362 Sullivan, NY           36.3       6,724      41,835       -2,155         -2,740     32,371 Ulster, NY             58.1     19,466    152,360       -9,919       -12,425     120,469 Westchester, 100.0       8,702    953,440       -25,396       -25,162     919,576 NY Pike, PA               18.7       2,503      25,108       -2,105         -4,703     17,902 Total                            999,765  20,460,274      301,320        110,663 19,571,172 Page 15 of 15}}

Latest revision as of 07:13, 12 November 2019

Entergy Pre-Filed Evidentiary Hearing Exhibit ENT000027 - Rebuttal Commuter Analysis
ML12088A228
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 03/28/2012
From: Potts L, Riggs J
Entergy Nuclear Operations
To:
Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML12088A225 List:
References
RAS 22094, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML12088A228 (15)
v • d • e


Text

ENT000027 Submitted: March 28, 2012







January2012

LoriAnnPottsandJerryL.

Riggs

Rebuttal Commuter Analyses - Region within 50 miles of IPEC 1.0 Purpose This calculation provides technical input to the testimony on contention NYS-16B concerning the population estimate used in the IPEC SAMA analysis. It was prepared at direction of counsel with the following objectives.

A. Duplicate Sheppard's commuter calculations.

B. Assess impact of possible double counting between long-distance commuters and business transients.

C. Evaluate impact of commuters traveling out of the 50-mile region.

2.0 Conclusions A. Duplicate Sheppard's commuter calculations.

The values in columns 2-4 of Table 1 of Sheppards Report agree with Entergys SAMA population estimates in the ENERCON Report (see Section 6.1).

The commuters-in values in Table 1 of Sheppards Report were calculated using the methodology described in Sheppards Report, except for the following discrepancy (see Section 6.1).

x Table 1 of Sheppards Report underestimates the commuters into Union Co.,

NJ by 3,987 because an incorrect value for the 2000 resident population was used (552,541 instead of 522,541). This caused the growth rate for this county to be underestimated resulting in an underestimate of the 2035 commuters-in.

B. Assess impact of possible double counting between long-distance commuters and business transients.

The data for commuters-in from the U.S. Census Bureau, County-to-County Worker Flow Files includes commuters into the 50-mile region from locations all over the country. If accounting for daily commuters was appropriate, it would not be reasonable to assume that people from more than 150 miles away commute into the region on a daily basis. Rather, these people are considered business travelers. Business travelers have already been included in the transient population in the ENERCON Report.

Revising the analysis in Sheppards Report to only count commuters-in from closer to the region (and correcting the Sheppards Report underestimate for Union Co., NJ) decreased the number of commuters in Sheppards Report to 964,093 (see Section 6.2).

C. Evaluate impact of commuters traveling out of the 50-mile region.

Revising the analysis in Sheppards Report to also account for commuters out of the region (in addition to the changes in B) decreased the net number of commuters into the 50-mile region to 110,663 (see Section 6.3).

Page 2 of 15

Rebuttal Commuter Analyses - Region within 50 miles of IPEC The revised analysis resulted in a more accurate estimate of the work day population distribution within the 50-mile region. The following observations can be made.

x The four counties closest to IPEC (Orange, Putnam, Rockland, and Westchester), where doses would be higher, show a net reduction of over 100,000 commuters.

x Seven counties in the 50-mile region show a net increase in commuters. Of these seven counties; New York, NY county has a net increase of about 1.4 million commuters; Morris, NJ county has a net increase of about 40,000 commuters; Fairfield, CT and Essex, NJ counties each have a net increase of about 24,000 commuters; and the other three counties (Bergen, Middlesex, and Somerset, NJ) have a combined net increase of about 7,000 commuters.

3.0 Input and Design Criteria 3.1 Dr. Sheppards Commuter Calculations Dr. Sheppards commuter calculations are described in Reference 4.1, also known as Sheppards Report.

Sheppards Report describes his commuter calculations, using data from the U.S. Census Bureau, County-to-County Worker Flow Files available at http://www.census.gov/population/www/cen2000/commuting/index.html, as follows.

An additional deficiency in the SAMA report population estimates relates to the number of persons who would be present within 50 miles of IPEC during a substantial portion of the day, not because they permanently reside there, nor because they are transient overnight visitors to the area, but because they commute to workplaces that are within the area. Because such workers are part of the population potentially at risk from a severe accident, it is important to include them in the estimate of population in the area.

In order to estimate the number of commuters, I use data on county-to-county commuter flows in 2000 made available by the Census Bureau. These data provide, for every county in the US, the estimated number of commuters coming into the county each day from any other individual county in the US. Thus these data can tell us how many commuters can be expected to come to workplaces within a 50 mile radius of IPEC from residential locations outside of this radius. Using these data, I estimated the total commuter flow into the area within 50 miles of IPEC by the following procedure:

1. For every county that is 100 percent within the 50 mile boundary:
a. Take 100 percent of the average daily commuter flows into that county that come from counties that are completely outside of the 50 mile boundary.
b. Take (100-S) percent of the average daily commuter flows into that county that come from counties that have S percent of their area within the 50 mile boundary.

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Rebuttal Commuter Analyses - Region within 50 miles of IPEC

2. For every county that is partially within the 50 mile boundary, where P percent is the percentage of land area in the county located within 50 miles of IPEC:
a. Take P percent of the average daily commuter flows into that county that come from counties that are completely outside the 50 mile boundary.
b. Take Px(100-S) percent of the average daily commuter flows into that county that come from counties that have S percent of their area within the 50 mile boundary.

Just as using the shares of land area within 50 miles of IPEC to adjust resident, transient, and undercounted population in each county was equivalent to assuming population in each county is uniformly distributed over the entire county, the steps outlined above add the assumption that employment locations are also distributed uniformly over the entire land area of each county.

Thus, for example, if a county has 25 percent of its land area within 50 miles of IPEC and 100 commuters come into that county from a county that is entirely outside of the 50 mile radius, we count 25 commuters as being present within the area that is being evaluated for SAMA (the other 75 are known to work in the county, but are assumed to be employed outside of the 50 mile radius). If 200 commuters come into this same county from a different county that has 50 percent of its area within 50 miles of IPEC, then 100 of those commuters are counted as already residing within the 50 mile boundary (and thus they are already counted under the resident population total) and the other 100 are counted as persons coming from outside the 50 mile area. Of these, 25 are counted as having employment within the area evaluated for SAMA and the other 75 are counted as having employment farther than 50 miles from IPEC.

This procedure provides estimates of the commuter population in 2000 into that portion of each county that is within 50 miles of IPEC. Taking the county population growth rates from 2000 to 2035 used in the original report as a conservative estimate of growth in county employment, we apply those growth rates to total commuter population for each county to obtain the estimates provided in column 6 of Table 1.

Note that although it is not stated in Sheppards Report, the calculations described in Section 6.1 indicate that the following is true. If 400 residents of this county (with 25 percent of its land area within 50 miles of IPEC) stay in the same county to work, 100 are counted as already residing within the 50 mile boundary (and thus they are already counted under the resident population total) and the other 300 are counted as persons residing outside the 50 mile area. Of these, 75 are counted as having employment within the area evaluated for SAMA and the other 225 are counted as having employment farther than 50 miles from IPEC.

Table 1 of Sheppards Report is reproduced below for convenient reference.

Page 4 of 15

Rebuttal Commuter Analyses - Region within 50 miles of IPEC 3.2 U.S. Census Bureau County-to-County Worker Flow Files As indicated in Sheppards Report, these files are available at http://www.census.gov/population/www/cen2000/commuting/index.html. The files listed below for states with land area within 50 miles of IPEC (Connecticut, New Jersey, New York, and Pennsylvania) were downloaded from this website.

Files showing the work destinations for people who live in each county of Connecticut, New Jersey, New York, and Pennsylvania:

2KRESCO_CT.xls 2KRESCO_NJ.xls 2KRESCO_NY.xls 2KRESCO_PA.xls Files showing the origins for people who work in each county of Connecticut, New Jersey, New York, and Pennsylvania:

Page 5 of 15

Rebuttal Commuter Analyses - Region within 50 miles of IPEC 2KWRKCO_CT.xls 2KWRKCO_NJ.xls 2KWRKCO_NY.xls 2KWRKCO_PA.xls 3.3 Entergys SAMA Population Estimates Entergys SAMA population estimates were developed in the ENERCON Report, Reference 4.3. Tables 1.1, 2.1, and 2.3 of this document are reproduced below for convenient reference.

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Rebuttal Commuter Analyses - Region within 50 miles of IPEC Page 7 of 15

Rebuttal Commuter Analyses - Region within 50 miles of IPEC 4.0 References 4.1 REPORT OF DR. STEPHEN C. SHEPPARD, PH.D. IN SUPPORT OF CONTENTION NYS-16/16A/16B (NYS-16B) In re: License Renewal Application Submitted by Entergy Nuclear Indian Point 2, LLC, Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear Operations, Inc. Docket Nos. 50-247-LR; 50-286-LR ASLBP No. 07-858-03-LR-BD01 DPR-26, DPR-64, December 16, 2011 4.2 U.S. Census Bureau, County-to-County Worker Flow Files available at http://www.census.gov/population/www/cen2000/commuting/index.html, downloaded January 10, 2012 4.3 Site Specific MACCS2 Input Data for Indian Point Energy Center, Revision 1 prepared for Entergy Nuclear Northeast by Enercon Services, Inc., Section 2.3, Page 2-5, Dec. 2009 Page 8 of 15

Rebuttal Commuter Analyses - Region within 50 miles of IPEC 5.0 Assumptions 5.1 Employment locations are distributed uniformly over the entire land area of each county. (Sheppards Report also uses this assumption.)

5.2 Workers who commute out of a county come from locations distributed uniformly over the entire land area of the county. (Corollary to assumption 5.1.)

5.3 The county population growth rates from 2000 to 2035 used in Reference 4.2 are a conservative estimate of growth in county employment. (Sheppards Report also uses this assumption.)

5.4 The county population growth rates from 2000 to 2035 used in Reference 4.2 are a conservative estimate of growth in the number of people commuting out of the county. (Corollary to assumption 5.3.)

5.5 People who live more than 150 miles outside the 50-mile region do not commute into the region on a daily basis. Rather, these people are considered business travelers. The impact of excluding these business travelers can be approximated by excluding commuters from states other than Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island and Vermont.

6.0 Method of Analysis and Calculations The calculations described below were performed within an Excel spreadsheet entitled Duplicate Sheppard Analysis Spreadsheet.xlsx. The worksheets mentioned below are within this spreadsheet.

6.1 Duplicate Sheppard's commuter calculations.

6.1.1 Verify that the values in columns 2-4 of Table 1 of Sheppards Report agree with Entergys SAMA population estimates in the ENERCON Report.

See worksheet Verify Sheppard Table 1 Input for calculations.

The values in Column 2 of Table 1 of Sheppards Report (Pct within 50 mi.)

are equal to the (Percent within 50-mile zone) values in Table 1.1 of the ENERCON Report. No discrepancies noted.

The values in Column 3 of Table 1 of Sheppards Report (Resident Pop) are equal to the 2035 permanent population projection in Table 2.1 of the ENERCON Report times the Percent within 50-mile zone values. No discrepancies noted.

The values in Column 4 of Table 1 of Sheppards Report (Transient Pop) are equal to the 2035 total population projection in Table 2.3 of the ENERCON Report times the Percent within 50-mile zone values minus the Resident Pop. No discrepancies noted; only minor rounding differences.

6.1.2 For each of the 28 counties with area in the region, copy the records showing the origins for people who work in each county from the U.S.

Page 9 of 15

Rebuttal Commuter Analyses - Region within 50 miles of IPEC Census bureau files to a worksheet with the county name, state abbreviation and the words commute in such as Fairfield, CT Commute In.

Worksheets labeled as described above were created by copying the appropriate lines from 2KWRKCO_CT.xls, 2KWRKCO_NJ.xls, 2KWRKCO_NY.xls, and 2KWRKCO_PA.xls.

6.1.3 In each county worksheet from 6.1.2 add a column entitled Commuters In.

For residence counties completely outside the 50 mile region, Commuters In = count (from the U.S. Census bureau file).

For residence counties with area inside the 50 mile region, Commuters In = count * (100 - % of residence county within 50 miles)/100.

Sum the Commuters In column.

The Commuters In column in each county worksheet accounts for the percentage of the residence county that is within the 50 mile region (S in Sheppards Report.)

6.1.4 In worksheet entitled Section 6.1 Worksheet, calculate the number of commuters into each county in 2000 by taking the Sum of Commuters In column in the county worksheet, multiplying by the % within 50 miles and dividing by 100.

Column E (2000 Commuters In Calculated) in worksheet Section 6.1 Worksheet contains this calculation which accounts for the percentage of the workplace county that is within the 50 mile region (P in Sheppards Report.)

6.1.5 In the same worksheet (Section 6.1 Worksheet), calculate the county population growth rates from 2000 to 2035 using data from Table 2.1 of the ENERCON Report. Apply those growth rates to calculate the year 2035 commuters-in for each of the counties.

Columns F, G, and H in worksheet Section 6.1 Worksheet calculate the population growth rate for each county. Column I (2035 Commuters In Calculated) applies those growth rates to the 2000 Commuter-In values to calculate the 2035 commuters-in for each county.

6.1.6 Compare the year 2035 commuters-in values in Section 6.1 Worksheet to the commuters-in values in Table 1 of Sheppards Report.

The commuters-in values in Table 1 of Sheppards Report were reproduced in this calculation, except for the following discrepancy.

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Rebuttal Commuter Analyses - Region within 50 miles of IPEC x Sheppards Report underestimated the commuters into Union Co.,

NJ by 3,987 because he used an incorrect value for the 2000 resident population (552,541 instead of 522,541). This caused the growth rate for this county to be underestimated resulting in an underestimate of the 2035 commuters-in.

6.2 Assess impact of possible double counting between long-distance commuters and business transients.

The calculations described below were performed within an Excel spreadsheet entitled Rebuttal Commuter Analysis Spreadsheet.xlsx. The worksheets mentioned below are within this spreadsheet.

6.2.1 Commuters originating from within a circle with a radius of 200 miles centered on the IPEC site are within 150 miles of the 50-mile region. This circle includes all or portions of the following states as well as portions of Canada.

Connecticut Maine Massachusetts New Hampshire New Jersey New York Pennsylvania Rhode Island Vermont To simplify the analysis, it was assumed that all commuters from the listed states are counted as commuters-in. This is a conservative assumption since some of the commuters from some of these states are more than 150 miles away from the 50-mile region. The conservatism is mitigated somewhat by the fact that the datasets from the U.S. Census Bureau, County-to-County Worker Flow Files do not account for commuters into the region from Canada.

6.2.2 Copy the spreadsheet used to calculate the commuters into the region in Section 6.1 (Duplicate Sheppard Analysis Spreadsheet.xlsx) to a new spreadsheet entitled Rebuttal Commuter Analysis Spreadsheet.xlsx.

Delete unnecessary worksheet Verify Sheppard Table 1 Input and change the name of Section 6.1 Worksheet to Section 6.2 Worksheet.

6.2.3 Within each of the county worksheets (such as Fairfield, CT Commute In),

delete line items for commuters coming from states other than those listed in Section 6.2.1.

6.2.4 Compare the year 2035 commuters-in values in worksheet Section 6.2 Worksheet to the commuters-in values in Table 1 of Sheppards Report.

Page 11 of 15

Rebuttal Commuter Analyses - Region within 50 miles of IPEC These results reflect the population values if the commuters from far away are not included. (They also correct the underestimate in the Sheppards Report values for Union Co., NJ mentioned in Section 6.1.6. The italicized, underlined values in the following table are the corrected Sheppards Report values.)

The number of commuters-in decreased slightly to 964,093. See the following table.

% 2000 Sheppard Sheppard 2035 within Commuters Revised County Report Table Report Table Commuters 50 In Total Pop 1 Commuters 1 Total Pop In Revised miles Calculated Fairfield, CT 100.0 52,388 990,917 48,605 50,590 989,119 Litchfield, CT 41.5 20,633 112,328 17,237 20,559 112,254 New Haven, CT 32.9 85,165 386,459 78,069 84,924 386,218 Bergen, NJ 100.0 30,893 1,152,826 23,190 28,575 1,150,508 Essex, NJ 100.0 62,809 966,290 53,508 58,571 962,052 Hudson, NJ 100.0 30,913 747,242 26,379 29,931 746,260 Middlesex, NJ 1.8 7,739 27,325 5,483 7,700 27,286 Morris, NJ 80.8 83,176 625,317 58,800 81,682 623,823 Passaic, NJ 100.0 12,135 584,721 10,327 11,686 584,272 Somerset, NJ 4.5 9,169 30,950 5,766 9,112 30,893 Sussex, NJ 93.9 9,762 219,456 6,364 9,621 219,315 Union, NJ 92.9 73,433 640,302 64,280 72,654 639,523 Warren, NJ 0.5 256 1,056 168 255 1,055 Bronx, NY 100.0 6,683 1,698,759 5,126 6,288 1,698,364 Dutchess, NY 88.9 18,957 311,096 16,417 18,716 310,855 Kings, NY 100.0 34,740 2,736,073 31,312 33,257 2,734,590 Nassau, NY 97.9 78,710 1,341,063 81,881 76,794 1,339,147 New York, NY 100.0 154,793 1,768,987 140,883 143,950 1,758,144 Orange, NY 100.0 14,410 472,498 10,684 13,934 472,022 Putnam, NY 100.0 1,251 125,106 924 1,166 125,021 Queens, NY 100.0 47,269 3,165,154 30,945 41,985 3,159,870 Richmond, NY 65.4 37,816 480,305 25,002 37,348 479,837 Rockland, NY 100.0 1,779 289,195 1,559 1,516 288,932 Suffolk, NY 21.3 87,491 414,106 83,046 87,223 413,838 Sullivan, NY 36.3 6,724 41,835 5,269 6,700 41,811 Ulster, NY 58.1 19,466 152,360 15,496 19,411 152,305 Westchester, NY 100.0 8,702 953,440 7,521 7,452 952,190 Pike, PA 18.7 2,503 25,108 1,115 2,492 25,097 Total 999,765 20,460,274 855,357 964,093 20,424,602 6.3 Evaluate impact of commuters traveling in and out of each county, and each partial county, in the 50-mile region.

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Rebuttal Commuter Analyses - Region within 50 miles of IPEC The calculations described below were performed within an Excel spreadsheet entitled Rebuttal Commuter Analysis Spreadsheet.xlsx. The worksheets mentioned below are within this spreadsheet.

6.3.1 For each of the 28 counties with area in the region, copy the records showing the work destinations for people who live in each county from the U.S. Census bureau files to a worksheet in Section 6.3 Spreadsheet.xlsx.

Name each worksheet with the county name, state abbreviation and the words commute out such as Fairfield, CT Commute Out.

Worksheets labeled as described above were created by copying the appropriate lines from 2KRESCO_CT.xls, 2KRESCO _NJ.xls, 2KRESCO

_NY.xls, and 2KRESCO _PA.xls.

6.3.2 In each Commuters In county worksheet created in Section 6.1, sum the commuters into the county and subtract the commuters from the county being analyzed.

Commuters originating from Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island and Vermont were retained as commuters. Workers originating from other states were considered business travelers and were not counted as commuters.

The commuters-in from counties that are only partially within the 50-mile region are not adjusted as was done in Sheppards Report because that adjustment results in the workers remaining in their residence county. To get an accurate representation of the work day population in each county, the commuters are moved to their workplace county in this analysis.

The commuters who live and work in the same county are not included in the calculation because there is no net change and these workers have already been included in the permanent population.

6.3.3 In each Commuters Out county worksheet, sum the commuters out of the county and subtract the commuters from the county being analyzed.

All commuters leaving the county were counted as commuters out of the county. Workers going to places other than Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island and Vermont are actually business travelers. But, since the original Entergy population estimates did not consider these business travelers, they are considered here to get a more accurate representation of the work day population in each county.

The commuters who live and work in the same county are not included in the calculation because there is no net change and these workers have already been included in the permanent population.

6.3.4 In worksheet entitled Section 6.3 Worksheet, calculate the net number of commuters into each county in 2000 by subtracting the commuters-out for Page 13 of 15

Rebuttal Commuter Analyses - Region within 50 miles of IPEC the county from the commuters-in for the county and multiplying by the fraction of the county within the 50-mile region.

Column E (2000 Net Commuters In Calculated) in worksheet Section 6.3 Worksheet contains this calculation which accounts for the percentage of the workplace county that is within the 50 mile region.

6.3.5 In the same worksheet (Section 6.3 Worksheet), calculate the county population growth rates from 2000 to 2035 using data from Table 2.1 of the ENERCON Report. Apply those growth rates to calculate the year 2035 net commuters-in for each of the counties.

Columns F, G, and H in worksheet Section 6.3 Worksheet calculate the population growth rate for each county. Column K (2035 Net Commuters In Calculated) applies those growth rates to the 2000 net commuters-in values to calculate the 2035 net commuters-in for each county.

6.3.6 Compare the 2035 Net Commuters In Calculated values in worksheet Section 6.3 Worksheet to the commuters-in values in Table 1 of Sheppards Report.

These results reflect the population values if the commuters and business travelers out of the region are not included. They also assume that commuters-in from far away are not included. (They also correct the underestimate in the Sheppards Report values for Union Co., NJ mentioned in Section 6.1.6. The italicized, underlined values in the following table are the corrected Sheppards Report values.)

The revised number of commuters decreased to 110,663. See the following table.

The revised analysis resulted in a more accurate estimate of the work day population distribution within the 50-mile region. The following observations can be made.

x The four counties closest to IPEC (Orange, Putnam, Rockland, and Westchester), where doses would be higher, show a net reduction of over 100,000 commuters.

x Seven counties in the 50-mile region show a net increase in commuters. Of these seven counties; New York, NY county has a net increase of about 1.4 million commuters; Morris, NJ county has a net increase of about 40,000 commuters; Fairfield, CT and Essex, NJ counties each have a net increase of about 24,000 commuters; and the other three counties (Bergen, Middlesex, and Somerset, NJ) have a combined net increase of about 7,000 commuters.

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Rebuttal Commuter Analyses - Region within 50 miles of IPEC Sheppard Sheppard 2000 Net 2035 Net

% within 50 Report Report Commuters Commuters Revised County miles Table 1 Table 1 In In Total Pop Commuters Total Pop Calculated Calculated Fairfield, CT 100.0 52,388 990,917 22,985 23,923 962,452 Litchfield, CT 41.5 20,633 112,328 -9,849 -11,748 79,947 New Haven, 32.9 85,165 386,459 -8,750 -9,518 291,776 CT Bergen, NJ 100.0 30,893 1,152,826 5,255 6,475 1,128,408 Essex, NJ 100.0 62,809 966,290 22,101 24,192 927,673 Hudson, NJ 100.0 30,913 747,242 -30,716 -34,852 681,477 Middlesex, NJ 1.8 7,739 27,325 91 128 19,714 Morris, NJ 80.8 83,176 625,317 28,922 40,178 582,319 Passaic, NJ 100.0 12,135 584,721 -37,557 -42,499 530,087 Somerset, NJ 4.5 9,169 30,950 458 723 22,504 Sussex, NJ 93.9 9,762 219,456 -30,872 -46,672 163,022 Union, NJ 92.9 73,433 640,302 -9,536 -10,779 556,090 Warren, NJ 0.5 256 1,056 -65 -99 701 Bronx, NY 100.0 6,683 1,698,759 -134,458 -164,938 1,527,138 Dutchess, NY 88.9 18,957 311,096 -12,731 -14,515 277,624 Kings, NY 100.0 34,740 2,736,073 -234,946 -249,536 2,451,797 Nassau, NY 97.9 78,710 1,341,063 -65,769 -61,684 1,200,669 New York, NY 100.0 154,793 1,768,987 1,326,196 1,355,065 2,969,259 Orange, NY 100.0 14,410 472,498 -25,195 -32,861 425,227 Putnam, NY 100.0 1,251 125,106 -24,242 -30,570 93,285 Queens, NY 100.0 47,269 3,165,154 -339,054 -460,013 2,657,872 Richmond, NY 65.4 37,816 480,305 -46,683 -69,735 372,754 Rockland, NY 100.0 1,779 289,195 -31,597 -30,721 256,695 Suffolk, NY 21.3 87,491 414,106 -23,091 -24,253 302,362 Sullivan, NY 36.3 6,724 41,835 -2,155 -2,740 32,371 Ulster, NY 58.1 19,466 152,360 -9,919 -12,425 120,469 Westchester, 100.0 8,702 953,440 -25,396 -25,162 919,576 NY Pike, PA 18.7 2,503 25,108 -2,105 -4,703 17,902 Total 999,765 20,460,274 301,320 110,663 19,571,172 Page 15 of 15

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