ML12228A655
| ML12228A655 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/29/2012 |
| From: | Lemay F J International Safety Research, State of NY, Office of the Attorney General |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 23294, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 | |
| Download: ML12228A655 (56) | |
Text
Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 1 UNITED STATES 1 NUCLEAR REGULATORY COMMISSION 2 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3 -----------------------------------x 4 In re: Docket Nos. 50
-247-LR; 50-286-LR 5 License Renewal Application Submitted by ASLBP No. 07
-858-03-LR-BD01 6 Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 7 Entergy Nuclear Indian Point 3, LLC, and 8 Entergy Nuclear Operations, Inc.
June 29, 2012 9 -----------------------------------x 10 PRE-FILED WRITTEN REBUTTAL TESTIMONY OF 11 DR. FRANÇOIS J. LEMAY 12 REGARDING CONSOLIDATED CONTENTION 13 NYS-12C (NYS-12/12A/12B/12C) 14 15 the Office of the Attorney General hereby submits the following 16 rebuttal testimony of François J. Lemay regarding Consolidated 17 Contention NYS-12C (NYS-12/12A/12B/12C).
18 I. INTRODUCTION 19 Q. Please state your full name.
20 A. François Jean Lemay.
21 Q. Dr. Lemay, could you briefly summarize the testimony 22 you provided on December 21, 2011?
23 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 2 A. ISR was retained by 1 olidated Contention 12C. 2 3 and conclusion that Entergy and Nuclear Regulatory Commission 4 (NRC) Staff underestimated the total economic cost of a severe 5 nuclear accident at Indian Point (IP). This underestimation is 6 primarily a result of their use of Sample Problem A input 7 values, which are not specific to the conditions at IP because 8 they include costs and times for decontamination that are 9 unrealistic given current known decontamination data and the 10 complexities of an urban to hyper-urban area such as that 11 surrounding IP. 12 Q. What is the purpose of this rebuttal testimony you are 13 now providing? 14 A. 15 onsolidated 16 Contention 12C. 17 Q. Have you read the testimony submitted by Entergy and 18 19 A. 20 -Filed Written Testimony (ENT000450) 21 (Entergy Testimony), and the supporting exhibits filed by 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 3 1 -Filed Written 2 Testimony (NRC000041) (NRC Staff Testimony), and the supporting 3 exhibits filed by NRC Staff on March 30, 2012. 4 Q. What are your overall conclusions regarding NRC Staff 5 6 A. Neither Entergy nor NRC Staff have provided a 7 documented basis for the cost of the decontamination value used 8 in their calculation of the economic costs associated with a 9 severe accident at IP. The decontamination time value selected 10 by Entergy represents a scenario that appears unreasonable and 11 unrealistic, based on past experiences and especially in light 12 of the currently unfolding experience at Fukushima. 13 Even after performing additional calculations to account 14 for some of the relevant points raised by Entergy and NRC Staff, 15 ISR concludes that the values used by Entergy lead to an 16 underestimation of the offsite economic cost risk (OECR) by a 17 factor between 3 and 7 for IP2. Furthermore, ISR concludes that 18 a similar underestimation factor range applies to IP3. 19 20 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 4 II. PREPARATION FOR REBUTTAL TESTIMONY 1 Q. Have you reviewed any additional documents since your 2 December 21, 2011 testimony in preparation for this rebuttal 3 testimony? 4 A. Yes. 5 Q. I show you Exhibits NYS00422A through NYS000431. Do 6 you recognize these documents? 7 A. Yes. These are true and accurate copies of the 8 documents that were referred to, used and/or relied upon in 9 preparing this rebuttal testimony. They include documents 10 prepared by ISR in support of this testimony, documents prepared 11 by government agencies, peer reviewed published articles, recent 12 reports related to Fukushima, and documents prepared by Entergy, 13 Sandia National Laboratories, Pacific Northwest Laboratory, NRC 14 or the utility industry. 15 Q. How do these documents relate to the work that you do 16 as an expert in forming opinions such as those contained in this 17 testimony? 18 A. These documents represent the type of information that 19 persons within my field of expertise reasonably rely upon in 20 forming opinions of the type offered in this testimony. 21 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 5 III. SCOPE OF CONSOLIDATED CONTENTION NYS-12C 1 Q. 2 scope of work ISR completed for NYS. Did NYS ask you to perform 3 an independent Severe Accident Mitigation Alternatives (SAMA) 4 analysis for IP? 5 A. No, the ISR report (NYS000242) was not intended to be 6 an alternative SAMA analysis. 7 Q. What was the scope of your analysis in connection with 8 NYS 12C? 9 A. The purpose of our analysis, as stated on the first 10 page of the ISR report (NYS000242), 11 of the [MELCOR Accident Consequence Code System 2] MACCS2 code 12 o review and 13 14 economic costs associated with a severe accident at IP, and to 15 16 relied upon those economic costs, as part of the Final 17 Supplemental Environmental Impact Statement (FSEIS). NYS asked 18 ISR to assess whether the MACCS2 input values related to 19 economic costs at IP were reasonable and, if not, to provide a 20 reasonable range of input values. 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 6 Q. Does the ISR report (NYS000242) offer a critique of 1 the MACCS2 code itself or suggest that the code should not have 2 been used? 3 A. No. ISR has not commented on the use of the MACCS2 4 code itself or any limitations of the MACCS2 code. Instead, 5 ode that are 6 used to calculate the costs associated with a severe accident. 7 Q. How did ISR conduct its analysis of the MACCS2 code 8 input values used for IP? 9 A. 10 critical input parameters on the total economic cost of a severe 11 nuclear accident. After performing a sensitivity analysis to 12 identify the input parameters that had the largest impact on the 13 calculated 14 from data produced by other analysts in the field. In other 15 16 input values against others values and to provide a range of 17 reasonable, site-specific, and appropriate input values. This 18 concept of benchmarking is not foreign to the IP SAMA Analysis 19 since it was used by Entergy to compare its SAMA candidates with 20 those for other operating plants that have submitted license 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 7 renewal applications as discussed in Appendix G of the FSEIS 1 (NYS00133I at G-1). 2 Q. What do you mean by benchmarking? 3 A. Benchmarking is often used to validate codes and 4 methodologies when an exact solution or experimental data is 5 available. It is also used when there is no unique solution to a 6 problem, or when considerable uncertainty is associated to a 7 result. 8 In that context, benchmarking consists of establishing 9 10 what others in the field are doing. In the nuclear industry, 11 benchmarking is an essential exercise because it provides for an 12 important exchange of information amongst experts in the field, 13 leading to the use of the best data and methodologies. 14 Q. -15 derived values? 16 A. We relied on our experience and also reviewed the 17 literature to identify and calculate a range of site-specific 18 input values that experts in the field of accident mitigation 19 would use to calculate the economic costs associated with an 20 accident at IP. For many sensitive input parameters, ISR found 21 that the input values used by Entergy and accepted by NRC Staff 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 8 were outside the range of reasonable values identified in the 1 literature. Because of this, Entergy and NRC Staff 2 underestimated the total OECR by a factor of at least 3 to as 3 much as 7. 4 Q. Did either Entergy or NRC Staff perform a benchmarking 5 6 A. No, neither Entergy nor NRC Staff have attempted to 7 benchmark (i.e., quantify the reasonableness) the MACCS2 input 8 parameters used to calculate the OECR. This is inconsistent 9 with Enter10 analysis. 11 Q. Please explain how Entergy's lack of benchmarking for 12 the MACCS2 input parameters is inconsistent with their work on 13 other parts of the SAMA analysis. 14 A. As NRC Staff explained, their SAMA analysis for Indian 15 Point uses probabilistic risk assessments (PRA). 16 The PRA for a commercial power reactor has traditionally 17 been divided into three levels: Level 1 is the evaluation of the 18 combinations of plant failures that can lead to core damage; 19 Level 2 is the evaluation of core damage progression and 20 possible containment failure resulting in an environmental 21 release for each core-damage sequence identified in Level 1; and 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 9 Level 3 is the evaluation of the consequences that would result 1 from the set of environmental releases identified in Level 2. 2 All three levels of the PRA are required to perform a SAMA 3 analysis, and the MACCS2 code is used to perform the consequence 4 analysis in the Level 3 portion of the PRA. 5 NRC and Entergy expended considerable effort to verify the 6 source term and core damage frequency used in accident 7 assessmentLevel 1 and Level 2. This is explained in Appendix G 8 of the FSEIS (NYS00133I at G-1 to G-10). Entergy conducted peer 9 reviews and benchmarking to verify the reasonableness and 10 robustness of the Level 1 and Level 2 PRA as described in 11 Attachment I to NL-08-028 (ENT000460). These initiatives 12 allowed Entergy to quantify the uncertainties on the key 13 parameters of the Level 1 and Level 2 PRA and to account for 14 these uncertainties with multipliers. Specifically, Entergy 15 applied a multiplier of 8 to account for internal and external 16 events (i.e. PRA Levels 1 and 2) and the corresponding 17 uncertainty (Entergy Testimony A62). 18 There is no evidence that Entergy's calculation of the cost 19 and duration of the decontamination for IP has been documented 20 and that Entergy performed the same peer review or benchmarking 21 for the Level 3 PRA, with the exception of the VALWNF value, 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 10 which was later revised by Entergy to address the loss of 1 tourism and business. Entergy has not explained why they 2 conducted the benchmarking exercise for the Level 1 and Level 2 3 PRA, but not the Level 3 PRA. 4 Q. What effect does the lack of Level 3 benchmarking have 5 on the SAMA analysis? 6 A. Without this benchmarking, Entergy and NRC have not 7 quantified the reasonableness and the uncertainty of the key 8 9 SAMA analysis is not defensible because the portion of the SAMA 10 analysis that relies upon the MACCS2 code lacks a documented 11 cost basis, a robust peer review, and a benchmarking exercise. 12 Q. But in A613 14 15 margin accounts for uncertainties in all three levels of the 16 PRA. Do you agree with this assertion? 17 A. No. The multipliers for the Level 1 and 2 analyses do 18 not account for uncertainties in the Level 3 assessment, such as 19 those for the decontamination cost or time. As I just 20 explained, Entergy and NRC have not attempted to quantify the 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 11 uncertainty of the Level 3 PRA and therefore, cannot account for 1 the magnitude of the uncertainty. 2 IV. A 3 REPRESENTS A WORST-CASE SCENARIO AND IS NOT RELEVANT 4 Q. Dr. Lemay, please explain how the MACCS2 code models 5 severe accidents and ultimately calculates OECR. 6 A. The MACCS2 code models eight different categories of 7 severe accidents, called release categories. As I explained in 8 my December 21, 2011 testimony and report, the OECR calculated 9 by the MACCS2 code is a frequency-averaged cost. The OECR is 10 obtained by adding the total offsite economic cost for each of 11 eight release categories after weighting them by their 12 respective frequencies. 13 Q. Are the eight release categories defined by the user? 14 A. Yes. Typically, the eight release categories are 15 selected by the user to represent a range of severe accidents, 16 from lower consequence/higher probability accidents to higher 17 consequence/lower probability accidents. In the case of the IP 18 SAMA analysis, the eight release categories were defined by 19 Entergy. 20 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 12 Q. Dr. Lemay, how do the eight release categories, as 1 2 Fukushima? 3 A. The bar chart below was created by ISR for this 4 testimony. It shows the activity of Cs-137 released during the 5 Fukushima accident compared to that of each release category 6 used by Entergy (ENT000464). 7 8 The source of the Fukushima release used in the bar chart 9 are the reports by the Investigation Committee on the Accident 10 at Fukushima Nuclear Power Stations of Tokyo Electric Power 11 Company, Chapter 5, December 26, 2011, attached hereto as 12 Exhibit NYS00422A-NYS00422C; and Institut de Radioprotection et 13 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 13 1 hereto as Exhibit NYS000423. 2 As shown in the chart of the 8 release categories modeled 3 by Entergy, the activity of Cs-137 released at Fukushima is 4 actually six to ten times lower than the activity that Entergy 5 6 Q. Do you agree with Entergy and NRC Staff's criticism of 7 -8 9 A. No. Fukushima is severe, but not worst-case. As I 10 previously explained and as seen on the bar chart, Fukushima 11 fits within the range of severe accidents defined by Entergy. 12 Q. Dr. Lemay, why did you use data from the Fukushima 13 accident to estimate consequences at IP? 14 A. The accident at Fukushima gives us the most recent 15 information available on the timeline and the magnitude of 16 decontamination efforts following a severe accident. It is a 17 real-world point of reference for assessing the cost of a severe 18 accident at IP. 19 Q. What impact do the eight release categories have on 20 OECR? 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 14 A. Some of the eight release categories have a relatively 1 small economic impact, while some have a relatively large 2 economic impact. Tables 5 and 6 from ENT000464, reproduced 3 below, show the contribution of each release category to the 4 total OECR. 5 6 7 8 9 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 15 1 As can be seen from the numbers circled in red, release 2 3 4 contribute over 90% to the total OECR. 5 6 7 to the total OECR for IP2 and IP3. 8 Q. Do you agree with NRC Staff, that input parameters 9 that represent an average of all the release categories are 10 appropriate to use, as they suggest in NRC Staff Testimony A6d? 11 A. No, particularly if the use of average parameters 12 gives unrealistic results for the release categories that 13 contribute the most to the OECR. In general, Entergy selected 14 input parameters that are appropriate for the release category 15 being modeled (release fractions, release duration); however, 16 for TIMDEC and CDNFRM, they used the same values derived from 17 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 16 Sample Problem A for every release category. The suggestion by 1 NRC Staff that it is acceptable to average input parameters over 2 all release categories is wrong. In fact, the relative 3 contribution of all release categories is determined when the 4 Offsite Economic Cost is multiplied by the frequency to obtain 5 the OECR. 6 If Entergy and NRC Staff insist on using a single value for 7 the input parameters related to the cost of decontamination, it 8 would be appropriate to use input parameters that more closely 9 align with the more severe end of the release spectrum because 10 the three most severe release categories make the largest 11 contribution to the total OECR. 12 V. 13 HISTORY AND PEDIGREE OF NUREG-1150 14 Q. In their testimony, both NRC Staff and Entergy argue 15 that the only appropriate values for decontamination time and 16 costs which should be used to analyze offsite economic costs in 17 the area around IP come from NUREG-1150 (NRC Staff Testimony at 18 A39, Entergy Testimony at A51). Are they referring to the 19 20 (NYS000242)? 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 17 A. Yes. The Sample Problem A values are the same as the 1 values for the Surry nuclear power plant in NUREG-1150. 2 Q. What is your understanding regarding NRC Staff and 3 lues from Sample Problem A? 4 A. NRC Staff and Entergy focus on what Entergy calls the 5 -1150 (Entergy Testimony at A26, A72, A76, 6 A95). They argue that the Sample Problem A values found in 7 NUREG-1150 are widely recognized and accepted in the nuclear 8 community. Both parties also justify the appropriateness of the 9 values found in Sample Problem A by stating that NUREG-1150 was 10 subject to extensive peer review and public comment (Entergy 11 Testimony at A26; NRC Staff Testimony at A39). 12 Q. Were the Sample Problem A values from NUREG-1150 13 developed specifically for IP? 14 A. No. As I explained in my previous testimony 15 (NYS000241) and the ISR report (NYS000242), these values were 16 developed for the Surry site surrounded by farmland in rural 17 Virginia. 18 Q. NRC Staff (A39) supports the use of values from Sample 19 Problem A by discussing the fact that NUREG-1150 was properly 20 vetted because it was subject to public comment. Have you 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 18 evaluated whether any public comments were received on the 1 economic cost portion of NUREG-1150? 2 A. Yes, the following comments were included in NUREG-3 1150d (NYS00252D at D-31 to D-32): 4 [PUBLIC] COMMENT: The models used in calculating 5 the cost of a severe accident lack many factors 6 that should be taken into account. Many of the 7 assumptions are questionable and unfounded. The 8 models have not been benchmarked. Some 9 interpretations and conclusions that were made in 10 draft NUREG-1150 are questionable. The cost 11 estimates need to be more thoroughly documented 12 to understand and evaluate the calculations. 13 [NRC] RESPONSE: The present version of NUREG-1150 14 provides a limited set of risk-reduction 15 calculations, principally related to the 16 potential benefits of accident management 17 strategies in reducing core damage frequency. It 18 does not assess the costs of these or other 19 improvements. Such analyses are more properly 20 considered in the context of specific regulatory 21 action. 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 19 * *
- 1 [PUBLIC] COMMENT: Decontamination costs used in 2 the calculations may be based on decontamination 3 of test sites in deserts instead of agricultural, 4 residential, and commercial property. 5 [NRC] RESPONSE: The draft NUREG-1150 cost/benefit 6 analyses reflected the conventional NRC methods 7 for assessing costs and benefits. Because 8 cost/benefit analyses are more properly 9 considered in the context of specific regulatory 10 activities, they are not provided in this version 11 of NUREG-1150. 12 Q. Do the public comments and NRC's responses to comments 13 on NUREG-1150 shed any light on how economic costs associated 14 with a severe accident should be calculated? 15 A. Yes, NRC's responses to the comments I just cited 16 suggest that the authors of NUREG-1150 expected NRC Staff to 17 require site-specific assessments of the costs of 18 19 e currently being conducted at IP. The 20 responses from the authors of NUREG-1150 do not justify the use 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 20 of the Sample Problem A inputs at IP or any other particular 1 reactor. 2 Q. What is NUREG-3 Problem A decontamination times of 60 days and 120 days for 4 light and heavy decontamination, respectively? 5 A. NUREG-1150d, page D-30 (NYS00252D) states: 6 A reduction by a factor of three was assumed 7 to require 60 days of decontamination work; 8 a reduction by a factor of 15 was assumed to 9 require 120 days of decontamination work. 10 The decontamination efforts were assumed to 11 commence at the end of the 7-day emergency 12 phase. 13 NUREG-1150 has no further justification for the use of the 14 decontamination times in Sample Problem A. 15 Q. What other support does NUREG-1150 have for the Sample 16 Problem A cost and decontamination time values? 17 A. NUREG-1150 (NYS00252A) states on p. 2-18 reader seeking extensive discussion of the methods used is 19 directed to [r]eference [NUREG/CR-4551 (NRC000057), a companion 20 study published in December 1990] and [r]eference [NUREG/CR-21 4691, the MACCS manual] which discusses the computer code used 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 21 to perform the offsite consequence analysis (i.e., the MELCOR 1 2 Q. Did you review NUREG/CR-4551, referenced by NRC Staff 3 (A39, A61, A81) and Entergy (A35, A36, A70, A72, A76, A77, A88, 4 A107), for documentation on how the Sample Problem A 5 decontamination times and costs were derived? 6 A. Yes, the document only contains the Sample Problem 7 input files for each of the five sites (including the Surry 8 Site). NUREG/CR-4551 discusses many of the MACCS2 input 9 parameters, but does not discuss how the decontamination time 10 and cost of decontamination were obtained. 11 Q. Do NRC Staff and Entergy cite any other documents to 12 support the pedigree of NUREG-1150 and the decontamination times 13 they used from Sample Problem A? 14 A. Yes. While NUREG-1150 and NUREG/CR-4551 provide no 15 detailed explanation for decontamination times, in A81 of NRC 16 Sta17 in April 1984 as support. This document is NUREG/CR-3673, 18 19 NUREG/CR-3673 does describe a timeline for the duration of 20 decontamination, but its description in Figure 4.2 (NRC000058 at 21 4-5) is not entirely consistent with the description contained 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 22 in NUREG-1150. In NUREG/CR-3673, the first 30 days after the 1 2 dose-rate info3 decontamination starts at 30 days and ends at 120 days. In 4 NUREG-1150, decontamination starts at 7 days. This discrepancy 5 illustrates that there is no single documented basis for the 6 cost and time of decontamination. 7 Q. Did you make any observations regarding the timeline 8 for the duration of decontamination which was discussed in 9 NUREG/CR-3673? 10 A. Yes, I have concluded that the assumptions made in 11 NUREG/CR-3673 are unreasonable for a severe accident at IP. 12 To conclude that average clean-up at Surry would take 90 13 days with approximately 46,000 workers, NUREG/CR-3673 (NRC00058 14 at 4-20) assumed labor comprises half the cost of 15 decontamination and that a worker would cost $30,000 per year. 16 Applying the same methodology as NUREG/CR-3673 to the cost 17 18 release category at IP2, a total of 1.5 million workers (363,000 19 worker-years) would be required to decontaminate the affected 20 area in 90 days. It is not reasonable to conclude that 1.5 21 million workers would be available and therefore, used to 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 23 decontaminate an affected area after a severe accident. 1 Therefore, the assumptions regarding the timeline in NUREG/CR-2 3673 are invalid. 3 Even if we assumed that decontamination will take a full 4 year, 363,000 workers would still be required. This too is 5 unlikely and leads me to conclude that the average time for 6 decontamination would be more than a year. 7 ISR created an exhibit containing the details of the 8 analysis I just explained, which is attached hereto as Exhibit 9 NYS000431. 10 Q. Does NUREG/CR-3673 provide any support for the Sample 11 Problem A decontamination cost? 12 A. On page 4-15, NUREG/CR-3673 (NRC00058) gives 13 approximate costs of decontamination that, once adjusted for 14 CPI, match the values used in Sample Problem A. It further 15 states: 16 The cost estimates used in this study for 17 various levels of decontamination effort in 18 an area are taken from a detailed review of 19 decontamination effectiveness and costs 20 performed at Sandia National Laboratories 21 (SNL) [Os84]. 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 24 There is no further discussion of the cost estimates in the 1 NUREG/CR-3673 document. It thus appears that the costs 2 contained in Sample Problem A are documented in the document 3 4 The references section of NUREG/CR-3673 lists [Os84] as 5 6 Decontamination Costs and Effectiveness for Accident 7 Radiological Releases. Albuquerque, N.M.: Sandia National 8 Laboratories, to be publis NRC00058 at 8-8. 9 Q. Does Os84 shed light on what data the Sample Problem A 10 values were based upon? 11 A. The document [Os84] upon which the Sample Problem A 12 cost estimates are based, as stated in NUREG/CR-3673, does not 13 appear to exist in a published form and therefore was not likely 14 to have been subject to peer review or public comment. 15 Therefore, it is not a reliable source upon which experts in 16 this field would base any findings. 17 We conducted a search and could not locate [Os84]. We 18 asked NYS for a copy, but NYS was not able to locate the 19 reference. 20 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 25 Q. Has Entergy or NRC Staff offered any document that 1 shows the calculations and/or data that support the use of the 2 values found in Sample Problem A? 3 A. No. 4 VI. -SPECIFIC ANALYSIS OF 5 DECONTAMINATION FOR INDIAN POINT 6 Q. Other than the ISR report (NYS000242), are you aware 7 of any site-specific analysis of the economic costs associated 8 with a severe accident at IP? 9 A. I am not aware of any site-specific analyses performed 10 by Entergy. 11 However, while researching th-1150 we 12 learned that in the 1980s NRC Staff contracted with Battelle 13 Pacific Northwest Laboratory (PNL) to conduct a case study of 14 the economic costs associated with severe accidents at IP. This 15 site-specific case study is described -16 5148 Property-17 1990 and attached hereto as Exhibit NYS00424A-NYS00424BB. 18 Q. How did you locate NUREG/CR-5148? 19 A. When attempting to respond to NRC's testimony 20 regarding the appropriateness of Sample Problem A and its roots 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 26 -1150, ISR researched the origins of 1 the economic cost parameter input values reported in NUREG-1150. 2 NUREG-1150 contained a citation to a document which 3 appeared to form the basis of the Sample Problem A values 4 -3413 Off-Site Consequences of Radiological 5 6 which was completed in November 1984, published in August 1985, 7 and is attached hereto as Exhibit NYS00425A-NYS00425G. 8 NUREG/CR-3413 explains the results of a PNL study commissioned 9 by NRC following the accident at Three-Mile Island. It further 10 describes a database and computer program called DECON that was 11 developed to conduct a decontamination analysis of a large, 12 radiologically contaminated area. DECON was designed to be used 13 with CRAC2, a predecessor to the MACCS2 code. The methodology 14 used by DECON appears to be very similar to that of CONDO 15 (NYS000250). 16 ISR was interested in learning more about the database and 17 DECON program, but could not find any use or mention of the 18 DECON code past the mid-1980s. Through internet searching, ISR 19 located an email address for one of the NUREG/CR-3413 authors, 20 J.J. Tawil. On May 2, 2012, ISR sent Dr. Tawil an email 21 inquiring about the history of the DECON program and what became 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 27 of it. Our email exchange with Dr. Tawil is attached hereto as 1 Exhibit NYS000426. 2 Dr. Tawil wrote: 3 I think the primary difficulty was that my 4 last project for the NRC was to characterize 5 the off-site consequences of reactor 6 accidents . . . for three reactor sites, one 7 of which was Indian Point . . . . I think 8 the NRC was a little shocked at the 9 magnitude of the off-site consequences of an 10 SST-5 at Indian Point and decided not to 11 publish the report. 12 After receiving this email from Dr. Tawil, we shared it 13 14 to locate NUREG/CR-15 email and a reference to a to-be-published 1990 document in 16 Sandia Site Restoration. 17 Q. How do the decontamination values in the NUREG/CR-5148 18 19 using CONDO? 20 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 28 A. The methodology employed by PNL using the DECON code 1 provides further support for using data to develop site-specific 2 MACCS2 input values. 3 It is not possible to directly compare the decontamination 4 costs contained in NUREG/CR-5148 with those calculated by 5 Entergy because they use different habitability criteria, 6 different decontamination factors (DFs) and different source 7 terms. 8 However, the detailed calculations performed by Dr. Tawil 9 (NYS00424A-NYS0424BB) show that in urban areas, the cost of 10 decontamination of building contents can exceed the cost of 11 decontamination of land and structures (NYS000424G, Figure 4.3, 12 at 4.26 - 4.28). He also finds that in urban areas, 13 decontamination of building contents is labor intensive and 14 labor costs are a large fraction of the cost of decontamination 15 (NYS000424B - NYS000424E, Section 2.4, at 2.8 - 2.71). 16 Q. Has either Entergy or NRC Staff explained why they did 17 not rely on the database and DECON program developed by PNL or 18 NUREG/CR-5148 IP case study to develop site-specific inputs for 19 the IP SAMA analysis? 20 A. No. 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 29 Q. Given the history and lack of documented support for 1 the Sample Problem A values, is it reasonable for Entergy and 2 NRC Staff to rely on Sample Problem A and ignore the data and 3 literature cited in the ISR report and the NUREG/CR-5148 IP 4 site-specific case study commissioned by NRC? 5 A. No. At a minimum, Entergy and NRC Staff should have 6 benchmarked the Sample Problem A values from NUREG-1150, to 7 verify their robustness when applied to determine the OECR at 8 IP. Such a benchmarking exercise cannot replace a detailed 9 calculation of the cost or time of decontamination, but it can 10 give confidence that the values are reasonable. 11 ISR conducted such a benchmarking exercise. However, 12 Entergy and NRC Staff have dismissed the wealth of other 13 relevant literature and data upon which ISR relied: 14 Experience at Chernobyl (NYS000249, NYS000250, 15 NYS000251, NYS000263) 16 Experience at Fukushima (NYS000264, NYS000265, 17 NYS000266, NYS000267, NYS000268, NYS000269) 18 Data from CONDO Report (NYS000250) 19 Data from RISO (NYS000251, NYS000253) 20 Data from Luna Report (NYS000255) 21 Data from Site Restoration Report (NYS000249) 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 30 Data from Reichmuth Report (NYS000256) 1 Q. 2 basis for the NUREG-4551 cost estimate for farm decontamination 3 is not fully explained in that document, we know of no more 4 appropriate decontamination data that is readily available to 5 6 A. No. As shown in the ISR report, many other data 7 sources exist that Entergy could have relied upon for 8 benchmarking purposes or to generate site-specific input values. 9 VII. 10 MACCS2 INPUT CALCULATIONS 11 Q. Are there any topics discussed in NRC Staff or 12 13 A. Yes, in their testimony, NRC Staff and Entergy discuss 14 some points that are not part of Contention 12C or that have no 15 impact on the conclusions of reached by ISR. In reaching its 16 conclusions, ISR did not rely on challenges to the following 17 points: 18 MACCS2 code (Entergy Testimony at A26, A37 to A52; NRC 19 Staff Testimony at A60): Contention 12C does not 20 contest the use of MACCS2 for SAMA analysis. ISR 21 agrees that MACCS2 input parameters represent suitable 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 31 averages for the cost and decontamination time in a 1 grid element. 2 Dose reduction factor (Entergy Testimony at A87; NRC 3 Staff Testimony at A52): and deposition velocity (NRC 4 Staff Testimony at A41 to A43). 5 used the same dose reduction factors (3 and 15) as 6 Entergy uses. ISR did not modify or contest the use 7 of the deposition velocity chosen by Entergy for its 8 calculations. In fact, ISR agrees that MACCS2 uses 9 dose reduction factors that are related, but not 10 identical to DFs. 11 Cesium (Entergy Testimony at A126; NRC Staff Testimony 12 at A20 and A21): ISR recognized and agreed that Cesium 13 is the most important radionuclide of consideration 14 for decontamination following a severe accident at a 15 nuclear reactor. 16 Q. 17 at 27-timates average consequence 18 results for the entire 50-mile radius region around the IP site 19 (an area of approximately 7,854 square miles), not just the 20 comparatively small region of New York City, which comprises 21 pt[s] to scale up 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 32 certain cost estimates related to the New York City portion 1 without including commensurate scaling down of estimates for the 2 98% of the SAMA analysis region that is outside of New York 3 4 A. We disagree with Entergy. Using the data from Site 5 Restoration as a starting point, there is no need to scale down 6 the cost of decontamination in the region outside of New York 7 City because the population density (790 pers per km2) is 8 comparable to the density around Albuquerque (700 pers per km2). 9 In our original calculation, the NYC area accounted for 2% 10 of the 50 mile area around IP. After removing the surface area 11 which could be accounted for by water and farmland, our revised 12 calculations show that the area with more than 10,000 persons 13 per km2 (i.e. what we classified as the NYC metro area) is 4% of 14 the total non-farmland area. 15 ISR is well aware that the SAMA analysis estimates average 16 consequences for the entire 50-mile radius region and we have 17 averaged the costs on the basis of land use area. To be clear, 18 ISR did not apply the same cost to the 4% non-farmland area that 19 represents NYC as to the remaining 96%. We only assigned the 20 high cost per km2 for decontaminating NYC to a very small area 21 (4%). We assigned the lower cost of decontaminating the 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 33 remaining urban or semi-urban area to the rest of the 50 mile 1 area around IP that is not farmland or water, an area that is 2 76% of the total area. The other 20% accounting for water and 3 farmland is not included in our calculation. 4 A. to Testimony Regarding the Calculation 5 Of Population Dose Risk (PDR) 6 Q. In A82, Entergy claims that ISR should have considered 7 not only OECR, but also the changes in Population Dose Risk 8 (PDR). What is your response? 9 A. ISR provided all of the MACCS2 output files, which 10 also contain the population dose results for the calculations of 11 PDR. 12 ISR agrees that changes in some of the input parameters may 13 affect PDR, and the costs associated with PDR, in a different 14 manner than how they affect OECR. In response to Entergy and 15 16 parameter changes discussed in the ISR report on the dollar 17 value equivalent of PDR. 18 Q. What is the effect of the changes to input parameters 19 discussed in the ISR report on PDR? 20 A. For all of the MACCS2 runs that we used to justify our 21 conclusions, we have now calculated the present dollar value 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 34 equivalent of the total off-site population dose from the PDR 1 and the total OECR using the equations provided in the Entergy 2 report: Re-Analysis of IP2 and IP3 SAMAs (ENT000459). The total 3 4 values (NYS000242, Table 13), decreases from $17.8M to $17.1M if 5 the cost associated with the decrease in PDR is included. 6 In summary, the change in PDR as calculated in our MACCS2 7 runs has no impact on our conclusions. It changes the total cost 8 by less than 4%. 9 Q. 10 A. No. In the ISR report (NYS000242), ISR ran the MACCS2 11 code for IP2 to illustrate the changes in the calculated OECR 12 when the sensitive inputs are changed. 13 In A27 and A28, NRC Staff challenged this by saying that 14 IP2 has a higher source term than IP3. As I explained above, the 15 source term is the activity released during the accident and in 16 MACCS2, it is specified as a release fraction of the core 17 inventory in units called Becquerel. For the SAMA analysis, the 18 activity of Cesium-137 released is the parameter of interest. 19 20 e that IP3 has higher release mode (or release 21 category) frequencies. The release mode frequency is a measure 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 35 of the likelihood of this particular release mode (or release 1 category) and it multiplies the off-site economic cost to obtain 2 the OECR. The effect on OECR by the higher source term for IP2 3 is offset by the effect of the higher release mode frequencies 4 for IP3 and, therefore, the resulting OECR values for IP2 and 5 IP3 are comparable. They are $2.12E+05/yr for IP2 and 6 $2.61E+05/yr for IP3. 7 In response to Entergy's and NRC staff's testimony, ISR re-8 ran the MACCS2 simulations using the ATMOS input file for IP3 9 10 to verify that there is no material difference between IP2 and 11 IP3. The results for IP3 were comparable to IP2. The 12 underestimation of the OECR calculated by Entergy resulted in a 13 factor between 3.2 and 7.6 for IP3, compared to 3.0 and 6.9 for 14 15 adjusted to account for the comments made by Entergy and NRC 16 Staff. 17 B. 18 Decontamination Cost (CDNFRM) 19 Q. Did ISR evaluate whether assumptions regarding CDNFRM 20 raised by Entergy and NRC Staff would affect the ultimate 21 calculation of OECR? 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 36 A. ISR determined that although much of the testimony 1 presented by Entergy and ISR had no bearing on our analysis, 2 some of the testimony required further analysis in order to 3 determine whether the ultimate calculation of the OECR would 4 change based on the assumptions Entergy and NRC Staff provided 5 in their testimony. We performed further analysis of several 6 parameters (e.g., the cost of decontamination per unit area) 7 used to calculate CDNFRM. 8 Q. 9 Staff A64 and A65 that the area ISR used to calculate CDNFRM 10 improperly includes surface water and farmland? 11 A. 12 surface water and farmland should not be included in the area 13 used to calculate CDNFRM, ISR recalculated the values for 14 CDNFRM, subtracting surface water and farmland from the area. 15 As shown in Table 13 of the revised tables from the ISR report 16 that ISR created for this testimony, attached hereto as 17 NYS000430, the impact of this change is a decrease of 13% at the 18 low end of the range for the OECR. There is no change at the 19 high end of the range. Thus, even when surface water and 20 farmland are removed from the area, Entergy and NRC Staff have 21 still underestimated OECR by, at minimum, a factor of 3. 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 37 Q. In NRC Staff A64 and A65, Staff claims that ISR 1 incorrectly accounted for parkland in the calculation of CDNFRM. 2 Is this true? 3 A. 4 the Entergy MACCS2 site input file, parkland area was not 5 accounted for as farmland and therefore must be included in the 6 only other category, as nonfarm land area. 7 In our calculations, we implicitly categorize parkland as 8 the area outside the NYC metro area, which is either semi-urban 9 or urban. This is justifiable because in order to retain the 10 value of the parks, the cost of decontamination (principally 11 tree felling and removal) and replacement of trees, soil and 12 grass is likely comparable to a semi-urban or urban area on a 13 per square kilometer basis. 14 This approximation is valid since park land accounts for 15 about 10% of the urban or semi-urban area outside NYC metro area 16 and is therefore, not a large component of the cost. 17 (1) 18 Site Restoration and the Use of the Reichmith Study 19 Q. 20 that ISR should not have included the cost of compensation in 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 38 calculating CDNFRM in Approach A (Site Restoration/Luna) and 1 Approach B (Reichmuth)? 2 A. We removed the compensation costs and re-calculated 3 CDNFRM for Approaches A and B, as shown in the tables attached 4 hereto as NYS000430. The resultant effect on the OECR is a 5 decrease of the upper bound by 5%. 6 Q. 7 that ISR ignores differences between New York and Albuquerque 8 and, thus, improperly extrapolates data from Site Restoration? 9 A. 10 would be expected to be generally proportional to [interior] 11 the 12 interior square footage for housing is greater in Albuquerque 13 compared to New York City (NYC), and that there should be a 14 reduction in the decontamination costs using Site 15 Restoration/Luna for NYC. Entergy further states the same would 16 be expected for commercial property. 17 Reference ENT000469 shows that average homes in the five 18 boroughs of NYC are smaller than in Albuquerque. There is no 19 evidence, however, that the multi-story residential and 20 commercial buildings that are common in the NYC area would have 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 39 less interior square footage than in Albuquerque, which has 1 fewer multi-story buildings. 2 Furthermore, Entergy (A121, A129) claims that the housing 3 density in the area outside the NYC metro region is about 50% 4 that of the City of Albuquerque, so there should be a reduction 5 in the decontamination costs for this region. 6 The authors of the Site Restoration Report state that they 7 8 9 housing density is used to assess the cost, the whole area 10 around Albuquerque City must be considered. From the New 11 Mexico: 2000 Population and Housing Unit Counts (Census Bureau), 12 attached hereto as NYS000427, the housing density of the 13 Albuquerque census county division is approximately 700 14 units/square mile, which is comparable to the 790 units/square 15 mile reported by Entergy for the area outside the NYC Metro 16 region. 17 Q. 18 that the data from Site Restoration is inappropriate for the 19 calculation of CDNFRM since it is based on a plutonium 20 dispersion scenario, for which decontamination is more expensive 21 than for a nuclear reactor accident? 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 40 A. Our use of Site Restoration was intended to be a point 1 of reference in a benchmarking exercise that illustrates various 2 approaches to determining the cost of decontamination ($/km2) and 3 the resulting CDNFRM ($/person). For estimation purposes, the 4 two parameters extracted from Site Restoration: the 5 decontamination cost per area and the corresponding DF, are 6 irrespective of the geographic extent and severity of the 7 accident. 8 The data from Site Restoration is one way to calculate 9 CDNFRM, and the ISR report explains how the Site Restoration 10 costs can be adjusted to be more applicable to a nuclear 11 accident (NYS000242, Approach A at 16-18). For example, the ISR 12 report assumed that the costs of a nuclear reactor accident 13 would be one to two times higher than the costs of a plutonium 14 dispersion scenario. This is because Cs-137, as well as the 15 remaining gamut of radionuclides released (including Pu-239) 16 from the reactor, must be considered when decontaminated, in 17 addition to Pu-239. 18 Q. 19 and A134 that the data from Site Restoration focuses on a small 20 geographical area, and did not account for economies of scale 21 that could be realized for larger areas? 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 41 A. It is reasonable that economies of scale are possible 1 during the decontamination of large areas, such as farmland. 2 However, NUREG/CR-5148 (NYS00424A-NYS0424BB) shows that a large 3 part of the cost of decontamination in urban areas is related to 4 5 There appears to be no practical way to scale these tasks 6 economically. 7 In addition, the logistics of planning a large scale 8 decontamination program, including budget approval, approval for 9 waste repositories, and set up times would be long, contentious 10 and difficult. For comparison, it has taken one year to 11 finalize plans and budgets for preliminary remediation efforts 12 in the Fukushima Prefecture as shown in the Road to Recovery, 13 attached hereto as NYS000428. 14 Q. 15 that consideration of on-site waste disposal and waste volume 16 reduction, as discussed in Site Restoration, would lead to 17 significantly lower estimates of decontamination costs? 18 A. There are significant issues concerning on-site waste 19 disposal for a severe nuclear accident. The approval and 20 planning for on-site waste repositories is a long and 21 contentious process (NYS000264). In a hyper-urban region such as 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 42 NYC, on-site disposal is likely impossible due to the lack of 1 suitable space. For the rest of the 50-mile SAMA region, there 2 would be long drawn out negotiations to identify suitable 3 locations for on-site disposal. Wherever such repositories are 4 located, they would result in a decline in property values, 5 which is currently not considered in the MACCS2 calculation. 6 Therefore, we believe it may be more cost-effective to employ 7 off-site waste disposal. 8 The waste volume reduction of 50-60% considered in Site 9 Restoration is for farmland or rangeland decontamination. Our 10 use of Site Restoration data is solely for the determination of 11 CDNFRM, which is only for nonfarm land. Therefore, this waste 12 volume reduction does not apply to our calculations. 13 (2) 14 Q. 15 that when using the CONDO approach, the decontamination 16 techniques that ISR chose are not consistent with the DFs for 17 light and heavy decontamination? 18 A. We disagree. ISR selected decontamination techniques 19 from the lists contained in CONDO (NYS000250 at Table A7 of 20 Appendix A) that most closely represented light and heavy 21 decontamination. Some techniques, such as felling and removal 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 43 (DF=10) of trees are essentially the only option for both levels 1 of decontamination. Vacuuming, cleaning and washing (DF=5) for 2 building interiors are also the only option for both levels of 3 decontamination. After removing these techniques and other 4 outliers such as removal (DF=1.4) for plants and shrubs and 5 removal and replacement (DF=50) for paved areas, light 6 decontamination techniques have a DF of 3 to 5, and heavy 7 decontamination techniques have a DF of 10. 8 Q. 9 -10 the NYC metro region and classifying the remaining area as urban 11 is unjustifiable when using the CONDO methodology? 12 A. The CONDO methodology classifies environments 13 according to their population density: rural (<25 per km2); semi-14 urban (25 to 1000 per km2); and urban (>1000 per km2) (NYS000250 15 at 54). With the revisions made to the nonfarm land area I 16 discussed on page 36 of this testimony, there are two population 17 grid elements (designated as the NYC Metro area) that have a 18 population density that exceeds 10,000 per km2, based on the 19 Entergy MACCS2 site input file. The remaining grid elements 20 have a population density between 25 and 10,000 per km2. 21 -22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 44 1 extraordinarily high population density. 2 To define a range, we calculated the minimum value based on 3 the assumption that the NYC Metro region is urban, and the 4 remaining area is semi-urban. This is supported by the 5 aforementioned classifications provided in CONDO. 6 Q. 7 that MACCS2 assumes that contamination is spread over a flat 8 plane and that it implicitly addresses 3-D structures through 9 the use of per capita costs like CDNFRM and, thus, ISR should 10 not have included multipliers in the CONDO approach to address 11 3-D aspects of decontamination? 12 A. First, it appears that NRC Staff is describing 13 contamination by gravitational settling. Gravitational settling 14 15 important close to the release point. 16 In the MACCS2 model, airborne contamination is transferred 17 to a surface through a transfer coefficient called the dry 18 deposition velocity. This transfer coefficient is a function of 19 the particle size, the chemical form of the particles, the 20 chemical affinity of the surfaces and the roughness of the 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 45 topography. This transfer coefficient applies to vertical and 1 horizontal surfaces, and even to leaves in the trees. 2 Second, the cost of urban decontamination ($/km2) is 3 proportional to building density and internal space density. All 4 four ISR approaches (A to D) began with a calculation of the 5 decontamination cost per unit area of nonfarm land ($/km2) with 6 consideration of 3-D buildings and structures. In order to 7 account for floor and building density, multipliers must be 8 used. The use of multipliers is consistent with CONDO and other 9 costing tools such as DECON, which is presented in NUREG/CR-3413 10 and which I discussed on pages 26-28 of this testimony. 11 With the appropriate multipliers, the cost per unit area of 12 nonfarm land ($/km2) is multiplied by the area of nonfarm land 13 and then divided by the population to obtain a value for CDNFRM. 14 In the absence of a documented methodology for the costs used by 15 Entergy to determine CDNFRM as discussed in Section V of this 16 testimony, this is the reasonable and most appropriate method to 17 calculate CDNFRM. 18 Q. 19 20 21 and unreasonable? 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 46 A. NRC Staff is correct that contamination would not be 1 uniform on building roofs, exterior walls, and interior space; 2 but it is not cost effective to differentiate between the 3 portions of surfaces which would require decontamination and 4 those that would not in any given building. It is more likely 5 that bulk decontamination, such as hosing or vacuuming, would 6 take place first followed by verification for hot spots. Our 7 assumption is reasonable given the likely operational efforts 8 and strategies which would be employed in the event of a severe 9 accident. 10 Q. In A140, Entergy suggests that your use of 11 spreadsheets based on the CONDO database, instead of the code, 12 may have errors, inaccuracies or biases. Is this plausible? 13 A. We have included these spreadsheets along with any 14 assumptions in Annex C of our report (NYS000242 at 46-56). As 15 such, they are available for review and criticism. Any other 16 claims regarding our calculations using the CONDO data were 17 addressed in preceding responses of this testimony. 18 (3) Testimony on the Use of RISO 19 Q. 20 RISO approach in A149 and A150? 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 47 A. For the RISO approach, Entergy claims in A149 and A150 1 that two decontamination techniques/surface pairs were excluded 2 as compared to the CONDO approach, and of the decontamination 3 techniques considered, some are compatible with heavy 4 decontamination instead of light decontamination. Furthermore, 5 Entergy claims in A150 that the cost data is not evident from 6 the RISO reference. 7 We excluded plants and shrubs, and treesboth of which were 8 not available in RISO and did not significantly contribute to 9 the total cost in the CONDO approach because they were less than 10 1% of the total cost. The only techniques with a heavy-11 decontamination-like DF were vacuuming, cleaning, and washing, 12 which are the only RISO techniques for interior decontamination. 13 All other RISO techniques referred to in our report have a DF 14 less than 3, which is representative of light decontamination. 15 The cost data was based on the RISO document but is explicitly 16 described in the RODOS Report: Estimation of the unit costs of 17 decontamination techniques, attached hereto as Exhibit 18 NYS000429. 19 20 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 48 C. 1 Time (TIMDEC) 2 Q. Has ISR reviewed its estimates for TIMDEC in light of 3 testimony provided by Entergy (A102 and 103) and NRC Staff 4 (A57)? 5 A. Yes, ISR has considered this testimony by NRC Staff 6 and Entergy. As I discussed earlier in this testimony, the only 7 s testimony provides for the 8 Sample Problem A TIMDEC values is NUREG-1150 and NUREG/CR-3673 9 (NRC000058). As I also discussed earlier in this testimony on 10 pages 22-23 of this testimony, the Sample Problem A TIMDEC 11 values are not reasonable, and NUREG-1150 describes an 12 idealistic decontamination scenario based on these unrealistic 13 values, without justifying their use or showing how they were 14 calculated. Additionally, I explained how the discussion of 15 decontamination time in NUREG/CR-3673 is based on unreasonable 16 assumptions. 17 In preparing this rebuttal testimony, ISR also reviewed 18 reports regarding decontamination following Fukushima that have 19 been published since December 2011. In light of these recent 20 reports on decontamination efforts in the Fukushima Prefecture 21 (NYS000428), there is support for changing the lower bound of 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 49 TIMDEC to 1 and 2 years for light and heavy decontamination, 1 respectively. 2 According to these reports, full-scale decontamination for 3 the outer edges of the plume deposition began one year after the 4 accident. Since it is on the outer edges of the plume 5 deposition, it is representative of light decontamination. 6 Amongst other things, the delays have been caused by the lengthy 7 time it has taken to develop a decontamination plan, which is 8 dependent on detailed radiation surveys and procurement of 9 suitable and efficient decontamination equipment and materials, 10 and by the time it has taken to gain approval of the 11 supplementary budget by the government. Another reason for the 12 delay is the need to secure approval from the local communities 13 for storage sites for decontamination waste. (NYS000265). 14 These delays would be expected following a severe accident at IP 15 and have nothing to do with the direct damage caused by the 16 Tsunami. 17 It is therefore possible that residents from some areas 18 will be allowed back to their home after a delay of more than a 19 year. Therefore, at the low end, a minimum TIMDEC of 1 year is 20 justifiable by the recent reports. 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 50 If light and heavy decontamination is conducted in series 1 (i.e., light decontamination first and then heavy) as is the 2 case for the Fukushima Prefecture, a minimum TIMDEC of 2 years 3 for heavy decontamination is also reasonable. In MACCS2, the 4 cost associated with TIMDEC is solely the decline in property 5 value during inhabitation. The impact of the change in TIMDEC on 6 the OECR is a 30% decrease at the low end of the cost. 7 Q. Both the NRC (A57) and Entergy (A102, A160) have 8 reiterated that the intention of the MACCS2 decontamination 9 model is to restore property to habitability based on the 10 defined dose criterion, not to entirely decontaminate the area. 11 Based on this, they infer that the ISR estimates of TIMDEC are 12 too large. Do you agree? 13 A. TIMDEC represents the average time from evacuation of 14 a population to return to their original home in a given grid 15 element. It is possible that within that grid element, some 16 people will return to their property more quickly than TIMDEC, 17 and that decontamination efforts may continue long after TIMDEC. 18 Given the large uncertainty in determining this time, we defined 19 a range of values based on real-world experience with actual 20 severe accidentsFukushima and Chernobyl. 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 51 As discussed in the previous answer, we now consider that 1 the minimum time between evacuation and return home for areas 2 requiring light decontamination is 1 year and 2 years for heavy 3 decontamination. This appears reasonable, from the current 4 experience in the Fukushima Prefecture. Maximum times of 15 and 5 30 years respectively represent upper bounds based again on the 6 decontamination plans in the Fukushima Prefecture (NYS000269). 7 An appropriate average value would be somewhere between these 8 minimum and maximum values. 9 Q. 10 the costs associated with large TIMDEC values are due to per 11 12 13 14 A. Entergy misunderstands how the MACCS2 inputs of TIMDEC 15 and POPCST work. Interdiction costs are the sum of relocation 16 costs, such as per diem expenses for relocated individuals, and 17 the decrease in property value during decontamination. TIMDEC 18 is only a factor in the decrease in property value during 19 decontamination. Relocation costs are solely a function of the 20 POPCST value and the population. As discussed in the ISR report 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 52 (NYS000242 at 28-29) for the POPCST parameter, relocation costs 1 are assumed for a duration between 20 and 93 weeks. 2 Q. Entergy and NRC Staff make several arguments about 3 various decontamination techniques, including leaving 4 contamination in place and new methods. (Entergy Testimony at 5 A91; NRC Staff Testimony at A38) What is your response to this 6 testimony? 7 A. In A91, Entergy claims that leaving contamination in 8 place, but burying it may be a financially attractive 9 alternative that reduces the dose. This issue has no bearing, 10 positive or negative, on our calculations and final conclusions. 11 We agree that this technique could work well in farmland where 12 deep-plowing can bury the contamination, but it is less 13 applicable to the urban areas of NYC where concrete and paved 14 surfaces are predominant. 15 In addition, no matter what the decontamination technique, 16 it is difficult to achieve a high dose reduction factor (DRF=15) 17 where cesium is present, even if some surfaces can be 18 decontaminated perfectly (DF>100). As an example, it may be 19 easy to decontaminate the glass surfaces with a DF>100. However 20 it may not be possible to decontaminate the brick to a DF>5. The 21 actual DRF achieved near the building will be much less than 22 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 53 DF>100 and closer to the DF=5. The lowest DF determines the 1 achievable DRF, so even though the glass is thoroughly 2 decontaminated, the dose reduction factor will not be as high 3 due to the remaining cesium contamination in the brick. 4 D. 5 and NRC Staff Comments About MACCS2 Parameters 6 Q. 7 regarding the VALWNF parameter, specifically that the increased 8 factor associated with lost tourism and business bounds the 9 increased factor associated with scaling up the 1997 SECPOP2000 10 values to 2004 values? 11 A. The values taken from SECPOP2000 represented the 1997 12 value of possessions such as houses, automobiles, etc. Entergy 13 used the 2004 Gross County Product (GCP) to additionally account 14 for lost tourism and business in the calculation of VALWNF. In 15 general, the GCP is the total value of goods and services 16 produced. NYS00270A-NYS00270B. 17 From the above, SECPOP2000 values and GCP values account 18 for two separate things and they cannot bound one another. Both 19 values are needed in the calculation of VALWNF, and both should 20 be in 2004 dollars. 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 54 Q. Regarding the POPCST parameter, Entergy suggests in 1 A157 that the long-term relocation cost should be based on 2 historical unemployment durations instead of the current term 3 for unemployment benefits. What is your response? 4 A. The unemployment as a result of a severe nuclear 5 accident, potentially affecting up to 20 million people, would 6 not be comparable to traditional, historical unemployment. 7 Given that the unemployment in 2005 had an average duration of 8 18 weeks (Entergy Testimony at A157), a range of 20 to 93 weeks 9 would be reasonable for unemployment triggered by a severe 10 nuclear accident. 11 Q. -12 A101 regarding the reasonableness of the calculations performed 13 with the MACCS2 code as modified by ISR? 14 A. Entergy incorrectly testifies that the modified MACCS2 15 code did not run properly. The original set of runs performed 16 with the MACCS2 code modified by ISR failed to run to completion 17 because a single carriage return character was missing at the 18 end of the input files. When that carriage return character was 19 added, the input files ran to completion without error and gave 20 the results presented in the ISR Report. 21 Pre-filed Written Rebuttal Testimony of François J. Lemay Consolidated Contention NYS-12C 55 Furthermore, ISR is well aware of the verification 1 requirements when performing nuclear safety calculations. In 2 accordance with ISR's rigorous internal QA Standards, we ran all 3 the sample problems provided by Sandia and all input files 4 prepared by Entergy using the MACCS2 executable provided by 5 Sandia and the version modified by ISR in order to ensure that 6 the model was running properly. Our results were identical to 7 those published by Sandia and by Entergy. The modified code 8 provides correct results. 9 IX. CONCLUSION 10 Q. Does the testimony from NRC Staff and Entergy affect 11 12 in the SAMA analysis for IP? 13 A. No. The analysis conducted by ISR shows that 14 15 underestimated the total economic cost of a severe nuclear 16 accident at IP. 17 I have reviewed all the exhibits referenced herein. True 18 and accurate copies are attached. 19 20