ML13267A234

G20130629 - Pilgrim Watch'S 2.206 Petition to Pilgrim'S Emergency Preparedness Plans (MF2656)

ML13267A234
Person / Time
Site:	Pilgrim
Issue date:	08/30/2013
From:	Lampert M Pilgrim Watch
To:	Borchardt R W NRC/EDO
Morgan N S
References
2.206, G20130629
Download: ML13267A234 (30)

Text

Mr. J ames Borchardt Executi ve Director for Operations U.S. Nuclear Re g ul atory Comm i ssion Washington , DC 20555-000 1 August 3 0 , 2013 B y Ma il & E m a i l: NrcExecSec@

nr c.gov PILGRIM WATCH'S 2.206 PETITION TO MODIFY , SUSPEND, OR TAKE ANY OTHER ACTION TO THE OPERATING LIC EN SE O F PILGRIM STATION UNTIL THE NRC CAN ASS U RE EMERGENCY PREPAREDNESS PLANS ARE IN PLACE TO PROVIDE REASONABLE ASSURANCE P UBL IC HEALTH & SAFETY ARE PROTECTED IN TH E EVENT OF A RADIOLOGICAL EMERGENCY I. I NT ROD UC TION Pursuant to §2.206 of Title 10 m the Code of Federal Re gula ti o n s, Pilgrim Watch (H ere i nafte r " PW") on behalf of its member s a n d members o f the P ilgrim Coa li tion, Proj ect for Entergy Accountabilit y, Cape Cod Ba y Watch , Eco Law , Beyond Nuclear, G r eenpeace, and ot hers request that t h e Nuclear Re g ulat ory Co m mission (NRC) to institute a proceeding to m od i fy, suspend or take a ny o ther action 1 as may be proper t o the o p e r ati n g licen s e of Pilgrim Stat ion in order t hat the NRC can assure Pil gri m's Radio l ogica l Emer ge n cy Plan and Standard Operating Pr ocedu r es/G u idelines are based on accurate a nd credible Evac u a ti on T im e Estimates (E TEs). E T Es pro v ide i nf o rmation for use in th e formulatio n of a licen see's protective action recommendation and the ORO's pr otect i ve act i on decisions.

It is im portant that the time required 1 NRC Enforcement actions include: notices ofviolation, civil penalties, o rders , noti ce of nonconformance, confi r matory action lett e r s, letters of reprimand , and demand fo r action. EDO --G20130629 to evacuate the public is both clearly understood and re l iable to ensure appropriate protective action is implemented.

Because Pilgrim's ETE underestimates evacuation times there is no reasonable assurance "to ensure appropriate protective action is implemented;" the popu l ation will achieve a timely evacuation; that pub l ic health and safety will be protected in the event of a radiological emergency; or that the NRC can satisfy its statutory requirement to protect public health and safety. The primary basis for this petition is two recent documents prepared by KLD for Entergy: The KLD Pilgrim Evacuation Estimate December 12, 2012 Final Report KLD-TR-5Irf (Hereinafter, "ETE" ) and the attached KLD MEMO to John Giarrusso (MEMA) from Chris Chaffee (KLD) Regarding the Cape Cod Telephone Survey Results, July 25, 2013, attached (Hereinafter, "Cape Survey");

and the attached August 16, 2013 Letter from Senator Markey and Senator Warren regarding Pilgrim's ETE and Cape Telephone Survey to Leo Denault (Entergy) and forwarded to Chairman MacFarlane's Office. These documents show that Entergy's Evacuation Time Estimates (ETEs) for Pilgrim Station are based on inaccurate assumptions and simply are not credible.

The ETE's fundamental flawed assumptions and data explain the ETE's absurd conclusion that even in the worst case scenario everyone in the EPZ will be evacuated in about six hours. 2 NRC Electronic Library, Accession Number ML13023A031 2

Inaccurate Assumptions Underestimate Demand-Total Number People & Vehicles Evacuating

l. ETE, unlike the Cape Survey, relied on a Telephone Survey that did not inform survey respondents that the questions related to a nuclear emergency, and thus significantly underestimated how many would evacuate.

2. Th e ETE's Shadow Evacuation assumptions incorrectly assume that only 20% of thos e instructed not to evacuate will voluntarily evacuate anyway. 3. The ETE incorrectly assumes that those in the EPZ will follow a staged keyhole evacuation. (ETE, 7.2) 4. Th e KLD ETE underestimated demand by failing to tak e proper account of the Summer Transient Population.

5. The ETE Study underestimated employees, thus Lowering Demand Estimates 6 Evacuation of the school population

& transportation dependent at nursing/group homes were underestimated.

Inaccurate Assumption/Estimates Regarding Road Capacity 7. The ETE fails to account for chronically heavy traffic over Summer weekends & special events that sign ific antly increases travel times. 8. ETE assumptions about traffic flow during inclement weather & peak commuter/holiday traffic are not credible.

9. The ETE's est imates for specific roadway capacity are not credible I 0. Emergency Personnel:

The ETE assumes, absent factual support, that emergency personnel will be available in sufficent number to assure timely traffic flow. 3 Inaccurate Assumptions Regarding Trip Generation Times 11. Tri p generation tim e relied on flawed telephone s urve y & assumptions.

12. The ETE inc orrectly assumed a rapidly escalating accident, and t ha t mobilization ofthe general population will commence w it hin 15 minutes after siren notification.

13. KLD failed to consider the impact of delayed staffing tra ffic control points on the ETE. 14. The ETE incorrectly assumed that 25% of the E P Z households wi ll await the return of a commuter prior to evacuating und e res t imating vehicles.

15. The ETE incorrec t l y assumes that 50% of the transportation dependent population will rideshare.

16. The ETE incorrect l y assumes timely evacuation of transportation dependent.

1 7. Th e ETE assumptions about mobilization times for school population

& special facilities are not c re dible. 18. Th e ETE assumptions about trip generation for populations on boats are not credible.

19. The ETE ignores the impact of voluntary evacuations from Cape Cod that would have a large impact on traffic in the EPZ; and ign ores the effec t of voluntary evacuation s within the EPZ and shadow e vacuation that would slow E P Z evacuation times. ll. FACTUAL BASIS The ETE covers demand estimation , estimation of roadway capaci t y, and development of evacuati o n time estimates for various subgroups

-estimation of t rip mobili zation time and trip generation time, and evacuation time estimates.

Every section of th e ETE is flawed and accounts for the absurd conclusion that an evacuat i o n in a radiolo gical emergency at Pil grim will be accomplished in six hours. 4 A. DEMAND ES TIM ATES UNDERESTIMATE D The assessment of demand estimation provides the total number of people and vehicles to be evacuated for each of the population groups. Both the ETEs and the Cape Survey underestimated demand. 1. ETE, Unlike the Cape S urvey , Relied On a Te l ep hone Survey That Did Not Inf orm Survey Resp onde nts That th e Qu estio n s Related to a Nuclear Emerge ncy thusSignificantly Underestimating How Many Would Evacua te The EPZ Telephone Survey sampled on1y those within the EPZ. By design , its question s never used t he words "nuclear" or "radiological." They s impl y refer to "an emergency." The ETE (ETE Attachment A, F-14) interviewer instructions refers to " emergency planning," not to a nuclear or radiological emergency.

Telephone Survey Instrument Hello, my name* is and f tn cond ucdn ,g a s:urvey for Ifill Emergeru:y Man;r:ement Apncies of Ca.rwr, DuxbufV, Marshfield and Pl>,*mouth The inform a ti on you will be *01* em..-: eru:y piaonlng to M hance IOC'il l response plans.

plar>ning; for some bi za rds ma y require t"JJcua.tior.t.

You-r to my qu*e stions. will ,r .. atf y to 'this .tfor.t. I wi H not fot your name. £QU .QQb.1 COl.. 4 COLS Se< Unused Unu>e<l UnuS<td U nu se-d Unused C0t.8 l 2 Fema l e The only ETE questions relating to t hi s Pe tition are Questions 13A and 13 B (E TE Attachment A, F-21) and lik ewise they do not refer to a radiological or nuclear eme rg ency, simply an emergency.

5 BA. Emergei\CY officials advise you to take shelter at home in an COL 52 emergency.

'Nould you: fREAD 1 A A S:HELTER; or* 2 B B. EVACUATE officials advise you to tale .shelter at home now i n :an emergency am:f possib l y evacuate l ater*whife people i n othe;r are .. s an!' advised to evacuate now. Would you: (READ ANSWERS) A. SHEL TER; or B. EVACUATE X 001\l'T KNOW/REFUSED COL 53 1 A 2 B X 001\l'T KNOW/REFUSED The Cape Telephone Survey sampled residents throughout the Cape, not simply those in the 10-15 mile zone. Unlike the ETE, the Cape Telephone Survey asked the respondent what s/he would do if there was "an incident at the Pilgrim Nuclear Power Station, " rather than saying nothing about the type of "emergency" involved.

The difference in the results of the two telephone surveys clearly demonstrated that any telephone survey designed to obtain reliable information from respondents must tell the respondent upfront that the su rvey is for an accident at the nuclear power plant. The EPZ Telephone Survey failure to te ll respondents that the survey was for a nuclear accident, was designed to confirm KLD's and federal guidance assumption that only 20% of the population would self evacuate and they would follow a segmented evacuation.

Question 13A (EPZ Survey F-10) asked: "Emergency officials advise you to take shelter at home in an emergency.

Would you?" This question i.s designed to elicit in formatio n regarding compliance with instructions to shelter in place. The results indicate that 81 percent of households who are advised to shelter in place would do so; the remaining 19 percent wou.ld choose to evacuate the area. Note the baseline Elf study assumes 20 percent of households will not comply with the shelter ad visory, as per Section 2.5.2 of NUREG/CR-7002.

Thus, the data obtained above is in good agreement with the federal J,!uidance. The Cape Cod Te l ephone Survey could not more clearly show that if potentially affected respondents were asked "would you evacuate" "if they were an incident at the Pilgrim Nuclear Power Station," 70% (not the 20% assumed by the NRC or the 19% of the ETE) would do so. 6

1. Suppose there were an incident at the Pilgrim NIJ('/ear Power S tation (PNPS) and you were Infor med that people in the Emergency Planning Zone were advised to evacua t e , would you evacuate?" Appro xima t ely 7 0'l6 perce n t of cape Cod resi d ents indica te d t hey would evacua te dve to a n v d ea r l ntidenl at PNPS.

"" l I 80!< ! t 60H I 1 I 4010 I J f 0* L ......... ---------------* C..pe C od lnfftc: Study Kl.D Engineering.

P .C. REY.O 0 1{ you we re told that Cape Cod is not* in the Emergency Planning Zone fw the Pl1grim Nuclear Power Slot/on, would you still evacuat e?" Approxi.ll'.ately SO"h percent of cape Cod resi dents indicated they w o u l d evacua te due to a n u dea r inciden t at PNPS , eve n k no w ing they are not in the Emergency Plan n i ng Zo n e (EPZ) * ..............................

_, ___ , ..................................

....................................................

......... . Voluntny Nuclear E vacuation .------"'"'''''' ................

................................................

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!S ! 3 0!6 0 i t ... 10!i Sheltlir ................. fi,;un ). Voluntary E v-acu:rtiol\

Ou* to a n l nc.id t nt a.t P N PS It is hard l y surprising t hat many more respondents said they would evac ua te when they were told that that there had been a nuclear incident at Pilgrim than if neither Pilgrim, nor nuclear, nor radio l ogical were even m ent i oned. Th e Cape Telephone Survey c l early demonstrates that the E T E Te l ephone Survey, that intentionally did not tell respondents upfront that the question r efers to what th e y woul.d do if t her e was an accident at the nuclear power plant, is not credible and cannot provide any bas i s for Pilgrim's evacuation time estimates.

7 This indisputable conclusion is completely consistent with the previous experience and studies 3 that equally clearly show that people view a nuclear accident very differently than a weather-related evacuation order; and they evacuate in far greater numbers and with Jess regard for official instructions.

2. The ETE's Shadow Evacuation Assumption is Wrong. It incorrectly assumes that only 20% of those not instructed to evacuate will voluntarily evacuate anyway. The ETE's Study Methodological Assumption 5 says: "As indicated m Figure 2-2 of NUREG/CR-7002 , 100% of the people in the impacted keyhole evacuate.

20% of those within the EPZ, not within the impacted keyhole, will voluntarily evacuate.

20% of those people within the Shadow Evacuation will voluntarily evacuate." (ETE, 2-2) 3 Studies regarding "shadow evacuation

inside and outside the EPZ indicate that the publ ic will respond once they become aware. Examples:

Three Mile Island: the Pennsylvania Governor issued an evacuation advisory (note, it was not an order). It was expected to have precipitated the flight of only 3,400 people (pregna nt women and pre-school children within five miles of the plant); instead, a total of 144,000 people (a government figure) evacuated the surrounding region. Subsequent surveys in New York by Dr. Zeigler indicated that the public outside the 10-mile EPZ would evacuate once they heard there was a nuclear e m e rg ency. Recognizing that the public has a greater fear of radiation than natural disasters , a shadow evacuation occurred during Hurricane Floyd in 1999 and Hurricanes Katrina and Rita. Again in a chemical accident, the shadow evacuatio n was studied and documented in the Graniteville South Carolina chlorine spill in 2005. (Zeigler, Donald, Johnson , James , Jr., "Evacuation Behavior In Response To Nuclear Power Plant Accidents," The Professional Geographer, May, 1984; Zeigler, Donald, Testimony Prepared for Westchester County Legislature, Dec 13, 2001, http://www.closeindianpo int.or g/evacuation testimonial.htm; Witt , James Associates, "Review of Emergency Preparednes s of Areas Adjacent to Indian Point and Mi lls tone ," James Lee Witt Associates , March 2002, http://www. wittassociates.com/index.xml http://www.nirs.org/reactorwatch/emergency

/epwittrot2003.pdf; Seminole Cou nty Division of Emergency Management, Evacuation Plans, http://www.seminolecountyfl.gov

/dps/em/emprep evacuation.a sp; Duhe,Duke, Evacuation Behavior in Response to the Graniteville, South Carolina, Chlorine Spill, Hazards Research Lab, University South Carolina, 2005, http://www.colorado.edu/haza rd s/research/gr

/grll78/grl78.html)

Th ird, it is essential for planning that the public trust the authorities in order for there to be some assurance that the public will follow directions.

If th e authorities only inform some of the population, irrespective of intentions, they will lose all credibility , increas in g the likelihood of a chaotic response.

8 Figure 2-1. Voluntary Eva c uation Methodology E T E's assumption is based on NRC's NUR E G/CR-7002; a n d was co n firmed by the ETE Telephone Survey only when t h at s u rvey neve r told respo n dents the q u estions pertained to a nuc l ear incident at P i l grim. In the ETE Telephone Survey relative l y few respondents said they would n ot follow "emergency offic i als" advice "to s h e lt er" when t hey were told noth i ng abou t w h a t the supposed emergency invo l ve d. ETE, F-10: "Emergency officials advise you to at home in an emergency. Would youl" Th i s que5t i on i s designed to elicit Info r mation regarding comp li a n ce w i th lnstruct l ons to shelter in place. Th e r*esults indicate that 81 percent of househo l ds who are advised to shelter in p l ace would do so; the remaining 19 percent w ou l d choose to evacuate t h e area. Note the b ase l i ne ETE study a.s.sumes 20 perce n t of households will not co m ply with t h e .shelter adv i sory. as per Section 2.5.2 of NUREG/CR-7002. Thus, the data obtained above is in good agreement with the federal gu i dance. "Emergency of/idols advise you to toke shel.ter at home now in on eme r gency and possibly evacuate later wh i le people in other aJ"I!as ore advis-ed to evacuate now. Would you?H Th i s quest i on is designed to elicit in formation sp-ecifically related to the possi'bi lity of a staged ev a cuat i on. That is, a*sking a popu l ation to sh e lter in p l a ce now and th e n to e vacuat e after a specified period of time. Results ind i cate that 71 percent of househo l ds wou l d follow ins t ructions and d-elay the start of evacuation until so advised , while the balanc:e of 29 percent w o uld choose to begin evacuating i mmed i ately_ 9 The Cape Survey, in stark contrast, told respondents the purpose of the survey and because it did the shadow evacuatio n estimates were very large. Th e Cape Survey spec ifi cally asked respondents , "If you were told that Cape Cod is not in the E mergency Planning Zone for the Pilgrim Nuclear Power Station, would you s till evacuate? (Cape Survey Question 3B), "App r oximat ely 50 percent of the Cape Cod residen t s indicated that they would evacuate due to a nuclear incident at P N PS , even knowing they we r e not in the Emergency Planning Zone (EPZ (Cape Survey, 4) HSuppose the re were an incident at the Pilgrim Nu<leor Power Station (PNPS} and you were informed that people in the Emergem:y Planning Zone were advised to evacuate, would you evawate?" Approximately percent o f Cape Cod res id ents in d icated they would evacuate due to a nudear incident :at PNPS. C-op o Cod Traffi( Study .....................................

.... ...... *-------------, Evacuat.e due to Nuclea r rnci dent at PNPS Ffc,vre 2..

Ou-t: t o in<idtot KLO En,ineerlnc. P .C. Rev.O The results of the Cape Survey show, at a 95% confidence le vel, that t he ETE's assumption that no more than 20% will evacuate is not j u st wrong; it is l ud i crous. I t cannot properly be used to dete rm ine P i lgr im's evacuation time estimates.

The Cape Survey also showed that the ETE's assumption t ha t the "s h a dow evac uat ion" include s only the 10-15 mil e r egion is incorrect. The Cape survey included res id ent respondents throughout the Cape, out to 25 miles. It showed at the 95% confidence l evel that approximately half of those w i thin 25 miles of P i lgr im wou l d evacuate, even if they knew that they were not in Pilgr im's Emergency Planning Zone. 10 The Cape Survey demonstrates that, in determining evacuation demand and evacuation time estimates, those living more than 15 miles from Pilgrim cannot be ignored. Those living up to 25 miles away must be expected to evacuate.

And, consistent with the previous studies and experience cited above, the percentage of those in the shadow region" that must be expected to evacuate is at least 2.5 times that assumed by KLD's ETE, the NRC, and the current evacuation time estimates.

Half. not "20 percent," "of households will not comply with the shelter advisory." Comparing the Cape Telephone Survey (and experience and studies) with the ETE Telephone Survey (and NUREG/CR-7200) proves that none ofthe ETE's 20% estimates of how many would evacuate, and none of Pilgrim's evacuation demand or evacuation time estimates are valid. They also show that the NUREG and ETE estimates of how many would evacuate in the event of a nuclear incident or emergency are indisputably wrong -and they are wrong because they are based on surveys that were intentionally designed to not to tell any respondent what type of emergency was really at issue, and to provide the answer that the industry wanted, rather than any real answer. At a 95% confidence level and with essentially identical possible sampling errors, the Cape Telephone Survey shows that any honest and realistic time estimates must assume that that the number of people who will evacuate within the EPZ is more than three (3) times what the NRC and ETE assumed, and that "shadow evacuation" outside the EPZ will be more than two and a halftimes the NRC's and ETE's unrealistic assumptions.

There can be no doubt that a 250% to 300% increase in the number of evacuees from within the EPZ will have a dramatic increase in traffic density and speed, and itself will dramatically increase the time necessary to evacuate.

There also can be no doubt that a large scale evacuation from Cape Cod will al so dramatically increa se KLD's faulty evacuation time estimates; t raffic 11 from Cape Code h as n ow h e r e to go exce pt o n to the evacuation r ou t es fo r t h e EPZ. (See 19, below) 3. T h e E T E In cor r ec tl y As s um es That T h o s e In T h e E PZ W ill Fo ll ow A Staged Ke y h o l e E vac u a t i o n (ETE, 7.2) A Staged Evacua t ion i s where o ne a r ea is to l d to evac u ate and ot h er areas are t o ld t o shelter-in-place unt il d i r ected to evac u at e. (NU RE G/C R-7 00 0 2, 1.31) T h e ETE study (ETE, 7.6) showe d that "t h e staged evacua ti o n o pti o n p rovid es n o b enefi t s a nd a d ve r se l y i m p ac t s m a n y evacuee s l ocate d beyo nd 2 mil es f ro m PNP S." 7.6 Staged Evacuation Table 7*3 and Table 7-4 present a compi!lrison of the ETE compiled for the concurrent

{un* staged) and staged evacuation s tudies. Note that Regions R22 throueh R27 are the same geographic areas as Regions R02 a nd R04 th rough R08, respectively. To determ i ne whether the staged evacuat i on strategy is worthy of cons i derat i on, one must show that the ETE for the 2 Mile region c a n be reduced without sign i ficantly affect i ng the reg i on b e tween 2 m il es and 5 m il es. In a ll cases , as shown i n these tables , the ETE for the 2 m il e reg i on is unchanged when a staged evacu a tion i s implemented. The reason for th i s i s that the congestion within the S*mile area does not extend upstream to the extent that it penetrates to with in 2 miles of the PNPS. Consequently.

the impedance, due to this congest f on with i n the m il e are a , to evacuees from w ithin the 2-m il e area is not sufficient to influence the gotlo percentile ETE for the 2-mfle a rea. Therefore , staging the evacuat i on to sharply reduce congestion w i thin the S-mile area, provides no benefits to ewcuees from within the 2 mile reg i on and unnecessarily dela y s t he ev acui!ltion of those beyond 2 miles. While failing to pro vid e as.sis ta nce to evacuees from with in 2 m il es of the P N PS, stagi n e produces a negati ve im pa ct on t h e ETE for those ev a cuat i ng from wit h in the 5-mile area. A comparison of ETE be t w een R eg io ns. R22 a n d R02; R23 and R04; R2 4 and ROS; R 25 a nd R06; R26 and R07; and R27 a n d R08 r eveals tMt s t!lg in g r eta r ds the 90 1 h percentile evacuat i o n t im e for those fn th e 2 to S-mile are a by up to 40 minutes for non-snow sceharios and 1 hou r a nd 2 0 minutes for snow scenarios

{see Table 7*1). This extending of ETE i s due to the delay in beg i nn i ng the ewcuat i on trip, e.xperrenced by those who s helter , plus the effe*ct of the tr i pgeneration

• spike* {significant volume of traffic beginning the evawat i on trip at the same t i me) that follows their eventua l ATE. in creating congestion with i n the EPZ area beyond 2 miles. In summary , the staged evacuation option provides no benefrts and adverse l y impacts many evacuees located beyond 2 miles from the PNPS. The Cape Telephone Survey's fi n d i ng that 50% of t h e population wo u ld self-evacuate even if t h ey were told that t h ey were n o t in the EPZ shows t h at t he po pul at i o n w ill not fo ll ow a staged evacuation; f ar l arger n u m bers w i ll ev a cuate an d traffic est i mates co n si d erab ly s l owed. 1 2 The ETE's findings have broad significance for emergency p lannin g. The Staged Evacuation concept appears to be NRC's and th e lic ensee's solution to the problem that population has dramatically increased since Pilgrim was licensed in 1972 and the infrastructure is inadequate to support a lar ge evacuation in a timely manner. For example, Plymouth's population has increased three-fold since Pilgrim was constructed-from 18,606 into 56,132 in 2012 4. 4. The KLD ETE U nderestimated Demand by Failing to Take Proper Account of the Summer Transient Population In estimating how many summer transients would evacuate, the KLD ETE inaccurately estimated the size of the summer tran sient population, and i ncorrectly assumed that the percentage of summer transients that wou ld choose to self evacuate would be the same as the percentage of year-round residents.

a. The ETE Underest ima tes Summer Transient Population:

Th e EPZ ETE section 3.3.1 Seasonal Transient Population explains that: "It is assumed that seasonal residents will be renting homes near the shoreline.

Using only those Census blocks that are within half a mile of the waterways, the number of seasonal homes was calculated by determining the percentage of vacant households and subtracting out the average vacant household percentages (24%) within the EPZ. An average household size of 2.5 persons per household is used to determine the seasonal transient population, and the 1.37 transient vehicles.

These numbers are adapted from the telephone survey results." (see Appendix F) The methodology s i gni ficantly underestimates t he transient population.

It ignored for example, that summer rentals are not lim ited to Y2 mile from the shore where rental rates are highest and that many summer transients are home owners that want to use their property , not rent it, during the summer. 4 www.mass.gov/dhcd/iprofile

/239.pdf. 13 Research shows that transients have high levels of spontaneous evacuation and will prepare to evacuate more quickly than residents 5* The New Jersey Hurricane Evacuation Study, for example, found that "it is reasonable to assume that 90% to 95% of vacationers will evacuate their accommodations if evacuation orders are i ssued . . . "90% of vacationers will return home when they evacuate . . . (and) more than 95% of vacationers

.... drive from homes (and) [t)hey will use their own vehicles when evacuating

." The 2004 KLD estimated transients with in the EPZ at 42 , 215; the 2012 KLD inexplicably estimated only 20,745. (ETE, 1-10) The overall population has increased in Massachusetts , as have the number of visitors.

Ne ither has decreased by more than half. And, Marshfield

's population data alone s hows that KLD's estimated are less than half what they should be. KLd estimated Marshfield summer transient population to be 6 , 102 (ETE, Tabl e 3-4, pg., 3-1 1); the Boston Globe reported that Marshfield's summer transient population was 12,000, 6 twice KLD's estimate. b. The Cape Telephone Survey was limi te d to residents and ignored the large number of transients on Cape Cod and its effect on the ETE Senators Markey and Warren's letter pointed out t hat "Cape Cod is a unique geographical area, withover 200,000 permanent resid ents and as many as 300 , 000 vacationers in th e summer." (Letter at 1-2) In other words, the kld ignores 60% of th summer population.

The only routes off the Cape cross the Sagamore and Bourne bridges, which consequently take evacuees onto roadways used by evacuating residents of the Emergency Plannign Zone. 5 New Jersey Hurricane Evacuation Study Transportation Analysis, Technical Memoranda, Prepared for US Army Corps of Engineers Philadelphia District, by PBS&J Tallahassee FLA, June 2007 (http://www .re ady. n j. gov/p lan/p df/ma ps/hurrevacution study. pd!) 6 Boston Globe, Globe South, Don't Love that Dirty Water, Jessica Bartlett, August IS, 2013, pg., 6 14 Based on the telephone Survey of Cape r esidents, it i s safe to predict over 70% of the vacationers w i ll evac uate if they leave in a Pilgr i m emergency and m o re than 50% wi ll evacuate even if told not to do so. The reason that their numbers are li kel y to be h i gher than residents is that transients away from their res i dence are l ikely to elect to evacuate to their home on the mai n land. Home is associated with safety. 5. T h e ETE S tud y U nd e r es ti ma ted E mplo yees, thus L ow e rin g D e m a nd Es timate s The ETE on l y accou n ts for non-residents who work in the EPZ for l arger employers (15 employers a nd t h e schoo l s); t h at resu l ted in o nly 1 , 146 employees and l ,092 veh i cles.7 The estimate fa i ls to account for the ma n y sma ll er emp l oyers in the EPZ who employ non-E P Z re si dent s. While each business may only employ a few n o n-EPZ r es idents , there a r e many small businesses and the se po t ential evacuees add up and need to be accounted for. The numbers are l argest in the sum mer months to service the tou r ism industry and th ose employees are l ilkey to commute in t heir own vehicles adding to demand data and traffic congestion.

The Cape Suvey also does not include non-re si dent employees, a number that increases dramatically o v e r the summer months to service the tourism indu st ry. Larger numbers of evacuees will slow evacuat i on of t he E PZ sharing and slowi n g the same mai n land evacuation routes. Many of t h e seasona l and low-wage jobs are fi ll ed by stude n ts and tempo r ary foreign workers, who migrate to the Cape during the tourism season , specifica ll y for temporary employment (http://www.sustaincapecod.org/indicators

/Bu siness) 7 ETE, Table 3-5, pg., 3-15 , Sum mary of Non-EPZ re sident Employees and Employee Vehic l es total EPZ 1 5 6 Evacuation of School Population

& Transportation Dependent at Nursing/Group Homes-Underestimated Th e ETE incorrectly assumes that parents will not attempt to pick up their children from schools, and that students will be evacuated by bus in an obvious effort to lower the number of vehicles evacuating.

It ignores that high school students with cars will self evacuate, with younger siblings.

It ignores that family members are likely to go to elderly housing complexes, nursing homes, and group homes to gather their loved ones. As a consequence, a far larger number of vehicles will be on roadways than modeled. For example, the Town of Duxbury recognized that parents will go to schools in the event of an emergency and before a general emergency to pick up. Therefo r e a protocol for picking up students is in the School Department's Standard Operating Procedure (SOP).8 B. INACCURATE ASSUMPTIONS

/ESTIMATES ROAD CAPACITY (ETE, Ch., 4) Roadway capacity is defined as the maximum rate at which vehicles can be expected to traverse a secton of roadway during a given time period under prevailing roadway traffic and control conditions. Roadway capacity influences evacuation travel time particularly as traffic demand approaches or exceeds capacity-such as in a nuclear disaster.

Capacity is impacted by, for example: structural characteristics of the roads, adverse weather, and intersection control. (NUREG/CR-70002) 7. The ETE Fails To Account For Chronically Bad Traffic over Summer Week-Ends & Special Even ts that increases travel times The ETE fails to consider the truly bad traffic jams that occur in the region. During the 2013 July 4 1 h week-end, for example, traffic backed up on Cape Cod for 25 miles ahead of the Sagamore Bridge, and it took as long as eight hours to drive from t h e Cape to Boston, trave lin g 8 http://www.town.duxbury.ma.us/Public

_Documents/DuxburyMA_EMA!Dux-06%20Schooi%20Department_July20 1 O.pdf 16 over the major evacuat i o n rout es for the E PZ.9 If a nuclear accide nt occ urr e d during s uch traffic co n gest i o n , a ll t h e traffic wou ld n eed to be rerouted over alt e rn at i ve road s that are n ot in cluded in the current estimate o f evacuation t imes. Durin g Jul y a nd A u g u st o f 2 0 1 2, i nbound traffic ove r t h e Saga m o r e and B ou rn e Brid ges on Frid ay, Satur d ay a nd Sundays ave r aged 230,000 ve hicle s o n a typical s umme r week-end and 255,000 on th e Jul y 4t h weekend 10* Tho se s ame v ehicl es ex it th e Cape o ver evac ua t i on r o utes for the E P Z. T h e ETE s imply m ode led one s pecial event, Pl y m o uth's 4th of Jul y celebration.

Even there, the E T E und erest im ated demand by assuming m ost fami ly members would drive tog ether to the celebration in o ne ca r; it is more lik e l y tha t teenage an d young adu lt family member s wo u ld drive in se p a r ate cars, ad din g to traffic volume. 8. ETE Assumptions about Traffic Flow during Inclement Weather & Peak Commuter/Holiday Traffic Are Not Credible The ETE Evac u ation Sce nari os included: 11<.-nc. ,._._, lm po<t-Lone etc:.u..-e on N8 9 http://www bostonglobe.com/metrol20 13/07/08/capE>-going-nowhere-hol iday-tra ffic-n ightmare-spills

-over-imonda y/g RG9bQkdvOh 7B4 E8Chs 13N/story .htm I 10 http://www.capecodtransit.org

/downloads/CapeFLYER.pdf 17

a. Inclement Weather: The EPZ ETE assumes that roads are passable and that "approriate agencies are plowing roads as th ey would normally" (ETE, 2.2) so that area roads used in an evacuation would be able to handle 80% of th e good weather highway capacity in the event of snow and 90% in the event of rain. The report claim s that, "it is reason ab l e to assume that the highway system will remain passable -albeit at a lower capacity-under the vast majority of snow conditions;" and that snow plow crews would be avialable and the clearing efforts would be highly effective.

In the February 8-9, 2013 blizzard road conditions were so severe that the Massachusetts Governor placed a ban on driving. 1 1 Durin g that storm Duxbury Beach was overtopped and the beach road used for evacuation by Gumet-Saquish and Duxbur y beach residences were impassable. Durin g Hurricane Sandy in late 2012, storm surge overtopped Plymouth Beach and led to the closure of 3A, one of the evacuation routes from Plymouth.

1 2 Severe weather conditions are one of the triggers of a nuclear accident.

Last, it is very likely that snow operators will not appear for duty, but instead will evacuate with their family. Th ey have not been surveyed to determine their response.

It should be done, and anonomously.

Further, as Table 6-2 shows, evac uation scenarios modeled traffic flow during rain and snow midday. KLD avoided peak traffic periods and chose a time period when it is more lik ely that snow plow crews were a t work and best ab le to clear roads. A l so , the ETE failed to account for fog in Pilgrim's coastal region. b. Peak Travel Times Avoided: The ETE fai l s to precisely define " Tim e of day." From the general description , it is clear that peak travel times for commuters and summer travelers are avoided in its estimates. The Pilgrim area is a tourist magnet for visitors to its beaches, ponds/lakes, forests and hi storic sites. 1 1 httpf /www .gazettenet.com/home' 43 5 9892-9 5/ban-inches-road-snow 12 http://www. wickedlocal

.com!plymoutMopstor i

bullet#ax.zz2MKf6CMs I 18 Summer visitors get an early morning start. Midday traffic is the lightest and that is precisely when the ETE estimates were made. Summer evening traffic is at its peak in early evening, before or very shortly after an early dinner; but the ETE fails to say when in the evening they modeled traffic. In "Winter" or non-summer seasons , midday is modeled, avoiding peak commuter traffic; and again "evening" is not defined by providing the hour. 9. The ETE's Estimates For Specific Roadway Capacity Are Not Credib le The ability of the road network to service the demand is a major factor in determining how rapidly the popu l ation can evacuate.

The ETE estimates are not credible.

For example: a. Two-Lane Roads: The E TE assumption tha t on rural roads, narrow lanes and shoulders will not interrupt the free flow of traffic is absurd. I t overlooks that rural 2-lane roads have numerous smaller roads and driveways feeding into them that will slow traffic. b. Multi-Lane Highways:

Route 3 North is the main evacuation route for Duxbury Beach , Saquish Neck , Gurnet Point , Clark's Island (sub-area 4); Duxbury (sub-area 9) and Marshfield, subarea 10. Route 3 south is the major evacaution route for Plymouth subareas 1 , 2 , 3,5 and 6. When route 3 was completed in 1963 it was designed to carry 76,000 cars daily; it is way over capacity now.1 3 The population evacuating over that route in a nuclear disaster will far exceed the design capacity.

c. Choke Points, Not Established:

Roadways have choke points under a variety of conditions.

The E TE fails to establish and record the specific choke point capacity for each roadway used in a radiological emergency at Pilgrim Station. 13 Route 3 widening project is back on track: Weymouth-Duxbury stretch in Romney's transportation plan, Patriot Ledger, Tom Benner, March ll, 2005 19

10. Emergency Personnel:

The ETE Assumes, Absent Factual Support That Emergency Personnel Will be Available In Sufficent Number To Assure Timely Traffic Flow Availability o f emergency personnel are important for intersection control and in general to a s sure traffic flow. The ET E provides no basis to support that emergency personnel will be available in sufficient number to assure the timely movement of traffic in an evacuation during a radiological disaster at Piglrim Station. An anonomous survey of respondents is required to provide reasonable assurance that sufficient personnel would be available.

Recogni z ing the eff e ct of federal , state and local budget cuts on personnel, it also is necessary to see an actual list, a real total count , of e mergency personnel available in the p e rtinent departments.

C. INACCURATE ASSUMPTIONS TRIP GENERATION TIMES (ETE, 5) Development of E TEs (NUREG/CR-70003, Ch. 4) includes trip generation time, evacuation modeling, and estima t es of evacuation times. Pilgrim's ETE underestimated each. 11. Trip Generation Time Relied On Flawed Telephone Survey & Assumptions The ETE followed Federal Guidelines (NUREG/CR-70002) to e s timate the elapsed time the public will take to get ready to evacuate.

ET E's estimates are not credible because: KLD based its data on the telephone survey of only EPZ residents, and failed to tell even resident respondents that the questions were for a nuclear emergency at Pilgrim, and made a number of incorrect assumptions.

Incorrect assumptions and data artificially resulted in the not credible conclusion that a complete evacuation of the EPZ would occur in six hours. 12. The KLD incorrectly assumed a rapidly escalating accident and that mobilization of the general population will commence within 15 minutes after siren notification.

(E TE, 2-5 , 5-1) This ignores provisions in the EPZ Radiological Emergency Plan and Standard Operating Procedures that notifies segments of the general public at the Alert and/or Site Area stage of the 20 emergency, prior to the General Emergency.

See, for example, the duties of the Harbormaster at the Alert in the Town of Duxbury's procedures where beaches are closed and boaters advised to come ashore.14 It is highly probable that information from these advisories will spread to other members of the public with today's readily available rapid communication systems, and that mobilization will begin earlier than th e General Eme rgency. Unplanned early mobilization of the population is likely to lead to a chaotic and unplanned evacuation of the population resulting in accidents and overall time delays, acerbated by unmanned traffic control points until after a General Emergency called. 13. The ETE Failed to Consider Impact Delayed Staffing Traffic Control Points on ETE "Traffic Control Points (TCP) within the EPZ will be staffed over time , beginning at the Advisory to Evacuate." (ETE, 2-5) Therefore TCPs are assumed to be not in place w hen actual evacuations begin prior to the advisory to evacuate, which will not be until a General Emergency.

The function of the TCPs is to "facilitate the movement of all (mostly evacuating) vehicles at the location.'

' Their absence when mobilization occurs before the General Emergency is assured to delay evacuation times. 14. The ETE Incorrectly Assumed That 25% Of The EPZ Households Will Await The Return Of A Commuter Prior To Evac uating Underestimating Vehicles Flawed data on m obi lization times that resulted from the telephone survey included , for example, assump t ions about commuters. "The ETE assumed that 65% of the households in the EPZ have at least (1) commuter; 38% of those households with commuters will await the return of a commuter, prior to beginning their evacuat i o n trip. Therefore 25% of EPZ households will await the return of a commuter, prior to beginning their evacuation trip." (2-5) It should have been obvious to KLD that in a radiological emergency households with commuters are not going to delay evac uation , until a parent gets home, especially considering the lengthy commute tim es many workers exper i ence daily under normal traffic conditions.

It defies reason, for example, to assume a husband or wife would drive more than 35 miles back to Duxbury from Boston toward s the "eye of the storm" to evacuate together with the family. Reception Centers, outside the EPZ, 1 4 http://www.town.duxbury.rna.us/Public

_Documents/DuxburyMA

_EMA/Dux-11 %20Harbormaster

_Jul y20 1 O.pdf 21 functi o n in part i s to r eunite fa m ily members. Th i s lud i crous assumption incorrectly reduces ve hi c le u se, s pr ea ds o ut the number of vehicles o n the evac uati on r o ut es at one time to make the E T Es appear tim e l y. 1 5. T he E T E Inc o rr ec t ly Ass um es Tha t 5 0% o f th e Tr a nsport a ti o n Depend e n t P o pul a t io n Will Ride s h a re (E T E , 2-6) Ba se d o n the te l ephone survey that did not te ll re s po n dent that it was about a nuclea r d i s a s ter , the ETE inc o rrectly con cl uded t h at 50% of the tra n s portat i on dependen t (th ose w i t h out vehic l es at the t i me of t h e ev a cu ati o n) wou l d rides h are, again u nderestimating t raffic l oa d. It i s n ot r e a l i s t i c to assume 50% will rideshare because that 50% figure d oes n o t account for the facts that neighbors ma y not be at home i n the event of an eme r ge nc y t o be ab l e to offer a ride; it does n o t co n side r that evacue es will fill their vehicle w i th family, pets and so me hou se hold item s so that there wou ld n ot be space for others. It doe s n o t consider th e population's natural motivation is a radi o l ogica l di sas t e r , es pec i a ll y po st Fuku s hima , i s t o ge t o ut as soo n as poss i ble without s urve y in g n e i g hb ors i n ne e d of ass i stance; and it d oes n o t consider an overloaded phone system wh e re it would not be possible to call a neighbor for a ride. There wi ll be more traffic, congestion, on the roads beca u se fewer t h an 50% are likely to ride s hare. Those needing a ride wi ll have to wait for b u sses to a rr ive fro m outside the EPZ increa s ing t h e overa ll ET E. 1 6. The E TE I nc o rr e ctl y A ss u mes T im e ly E v a cua t i o n o f Tr a n s port a tion Dependent T h e ETE acknowledges that a second wave of bu s driver s w ill be requ i red to transport the sc h oo l s and s pecia l facilties.

The model for the secon d-wave for Du x bury; for examp l e, assumes that the bu s head s back from the Recept i o n Ce n ter afte r 1 5 m i nte s, returns to the EPZ , and com p l etes the seco nd trip in 79 minutes (E T E , pg., 8-38) T h e t i me s under est imat e what will occur in r ea lit y. T h ey ignor e the time required to deco n tam i nate th e driver and bus; t i me to find 22 substitute dri ve r s, if even possible in a nuclear disaster; t im e to find su b st itute busses and their mobilization times; and the willingness of dri ver to return to a contaminated area in a nuclear disaster.

Bu s drivers , like s now plow and tow truck operators and emerge nc y workers should be anonomously surveyed to determine what fract ion who wi ll choose to stay with their families in a nuclear disaster a nd thus not be available in an e mer ge n cy. Absent suc h a survey, there is no r easonab l e basis to assume that all will show up and will go back for a second trip in a nuclear emergency.

17. The ETE Assumptions About Mobilization Times for School Population

& Special Facilities are Not Credible School Populati on (1) The ETE incorrectly assumes that parents w ill n ot attempt to pick up children from schoo l s and that instead the student populati on wi ll be transported by busses and met by family/guardians at the Host Facilities.

Th e assumption i s n ot supported by Pilgrim's Radiological Emerge nc y Procedures.

Those procedures r ecognize that p are nts wi ll in fact try to pick up their chi ldren and students with vehicls will evacuate themselves with siblings, if appropriate.

The Duxbury School Standard Operating Procedure , for example, pr ovides explicit procedures for parent pick-up in a radiolgoical emergency.

Mor e vehicles than estimated will be on th e ro adways, slow ing ETEs. (2) The es timati o n of trip generation for the Schoo l p op ul at i on i s ludicrous.

The ETE for Duxbury assu m es that the average speed of school buses fr om the EPZ to the Reception Cent er is 40:35 in the rain , and 30 minutes in the snow assuming that 40 mph i s the spee d limit on sta t e roads. ft i s absu rd to s ug gest that in a radiological disaster the speed limit wo uld be achievab l e; K LD arrives at these t i mes by making a host of equally ridiculous assumptions reviewed in this petition.

23 (3) The ETE acknowledges that a second wave of bus drivers will be required to transport the schools and special facilties, discussed above at 11, e. Special facility populations-hospitals.

nursing homes, group homes CETE. 8-1 0) ( 1) The estimation of trip generation for these populations are equally ludicrous.

In the ET E's Duxbury data for medical facilities, for example , the assumed load time for patients is one minute per patient; and the estimated travel time is only to the EPZ boundary, quite unlike the school population that estimates travel time to the host facility/reception center. If the time were modeled to the host medical facility, as it should , ETEs would escalate.

(2) The analysis for the second wave of drivers is flawed as discussed above at 16. 18. The EPZ ETE Assumptions About Trip Generation For Populations On Boats Are Not Credible (ETE, 5-18) The ET E incorrectly assumes t hat boaters will return to marinas within the mobilization t ime for transients in the E P Z (15 minutes).

This ignores the time required for sail boats without motors to get back to their moorigns and ashore and the effect of low tides. KLD 2004 (sec t ion 5-11) in contrast found at 15 minutes only 15% of those on boats were notified; and at 15 minute s only 17% of the baoters were ready to evacuate.

It took 60 minutes for 100% to be ready to evacuate.

The boating population has increased substantially since 2004; it makes no sense that the times to evacuate gone down. 19. The ETE ignores the impact of voluntary evacuations from Cape Cod that would have a large impact on traffic in the EPZ; and ignores the effect of voluntary evacuations within the EPZ and shadow evacuation that would slow EPZ evacuation times. The ETE assumes a rapidly escala t ing emergency, where a General Emergency evacuation order is the first advisory issued. The ETE acknowledges that in a more slowly 24 developing emergency many residents may voluntarily choose to evacuate earlier at the Alert or Site Area emergency.

This is likely because at the Alert or Site Area stage, public parks and beaches are closed at the Site Area and boaters advised to get off the water. This will result in the publci knowing about serious problems at Pilgrim and like ly to choose to "Get out of Dodge." The ETE fails to consider the impact of residents on Cape Cod evacuating voluntarily in that situation.

Such an early shadow evacuation that necessari l y must use the Sagamore or Bourne Bridge to exit the Cape and would add to the congestion faced by re sidents evacuating from the EPZ. Portions of Plymouth (Subareas 1 ,2,3, or 5) evacuation route crosses where Cape traffic arrives on the mainland from the Sagamore and Bourne Bridges 15* Likew ise an early voluntary and shadow evacuation of residents inside the EPZ and a larger percent of the population outide the EPZ will clog the evacuation routes upstream meaning that those downstream or most a risk will experience delays in evacuation times -much l ike a cork placed in a bottle. III. CONCLUSION Faulty assumptions in KLD's ETE for Pilgrim Station show that it is not credible and that there would be much higher levels of congestion, and much longer evacuation times due to far larger voluntary and shadow evacuations, higher transient and worker population,;

poorer road conditions in inclement weather than modeled, slower trip generation estimates; and likely fewer emergency workers than KLD estimated.

These would lead to a significant lengthening of the time required for the EPZ to evacuate. Absent an honest and credible ETE, the population does 15 http://www .mass. gov I eopss/ docs/memalnuclear/20 13-pi lgrim-nuclear-calendar.

pdf 25 not have reasonable assurance.

Pilgri m should n o t be ope r ating until a new ETE with re a list ic evacuat i o n t im e estima te s based on credible assum p tions, i ncluding a telepho ne s u rvey infonning repondents t h at it is for a radiological eme r gency at Pilgrim Stat i on, i s developed and reviewed by t h e E P Z Emergency Manageme nt Age n cies, MEMA an d the p u blic. Severa l mont h s ago, Judge Rosenthal o f the ASLB accurately said that , w i t h one p oss i b l e exception, t h e NRC had n o t granted a sect ion 2.206 petitioner t h e su b sta n t i ve relief it sought fo r at lea s t 37 years. Jud ge Ro se nthal concluded tha t, " where truly s ub sta ntiv e relief is being sought (i.e., some affirmat ive admin i strative acti o n tak e n with respect to th e licen see or lic e n se), t here shou l d be no room for a belief on th e r equester's part that t h e pursuit of suc h a co ur se is e ith er being encouraged by Commission offic ia l d om or ha s a fa i r chance of s u ccess." 16 We truly hope that Judge Rosenthal will be proven wrong and th i s pet it ion will be gran ted. Re spectf ully submitted on behalf of the P eti ti o n e r s, Mary La mp ert Pil grim Watch , Dir ec tor 148 W as hin gto n Street Du xbu ry , MA 0 2332 Tel 781-934-0389 Emai l: mary.lampert

@co mcast.net August 30, 2013 1 6 Memorandum And Order (Denying Petitions For Hearing), LBP-12-14, July 10, 2012, Additional Comments of Judge Rosenthal (See NRC's EHD Docket EA-12-05-/12-51) 26 Joining the Petition Pilgrim Coalition Arlene Williamson 1 03 Surf Drive Mashpee, MA 0649 Project for Energy Accountabil it y PO Box 380083 Cambridge MA 02338 508 259 9154 Cape Cod Bay Watch Karen Vale 58C Main Street Plymouth MA 02360 508-7 46-9400 P aul Gunter, Director Reactor Oversight Project Beyond Nuclear 6930 Carroll A venue Su it e 400 Takoma Park, MD 209 1 2 Tel. 301 270 2209 Jim Riccio Green peace 702 H street NW Washington , DC 20001 27 Project for Energy Accountab ili ty PO Box 380083 Cambridge MA 02338 508 259 9154 EcoLaw 61 Grozier Road Cambr idge MA 02138 617-714-4552 Linda Jacob s-R oy 66 Redwood Drive Halifax, MA 02338 781-293-5219 RichardS W i ckende n II Phyllis J Troia. MD 627 Long Pond Rd Plymouth MA 02360 Janet/Thomas Azarovitz Cape Downwinders 20 Shapquit Bars Circle P.O. Box 58 West Falmouth MA 02574 508-540-3 1 99 APPENDICES r, P.C. Memo To: John GQNilSSO F1om:

CC: Jack Priest, Mike Slobodien, Ke>tin Welnlsdl J uly2S, 2013 R.e: Clpe *Cod Telephone Survey 'Results T£L£PHONE SURVEY 1.. Introduction At the request of the Massachusetts Emergency Manacement

"<<encv and Entercv, I<.LO conducted a

survey to obtain democraphic lnformatlon about cape C.od resk!ents recard l nc planni!lll.

This memo documents the telephone survey result$. The surwy designed to elic:lt lnformatlon from the public concrrnlnc household and reactions durlnll emereerodes.

Information will be included In the Cape Cod Traffic Study final report and Is encouralled to be used by emeraency planMrs. A draft of the survey 1nsttu1nent w.u to stakeholders.

After recetvlne comments, It modifled accordlne!Y prior to conductfnc the survey.

A presents the final S<Jtvey instrument used In this study. The suNey sampling plan was developed by taldnc representalllle samples from each zip code In cape Cod, proportional to the zip code's population. The PQ91Jiation est i mate and number of hooseholds in each area were determined by overta'lfna CenS<Js data and cape Cod's boundary ustnc GIS software.

The number of desired comple t ed survey lnteflllews for e<lch area wu Identified, as shown In T able 1. The sample size of 500 mmplrta! survey form s yields results w i th a sampling error of approximately

.14.4" at the 95" confidence level. The completed survey :adhtl'ed to the sampling plan. (apt CCd Traffic Study I(L O En&l.-inc.

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