ML12340A608

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

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

Text

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 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. December 21, 2011 9 -----------------------------------x 10 PRE-FILED WRITTEN TESTIMONY OF 11 DR. FRANÇOIS J. LEMAY 12 REGARDING CONSOLIDATED NYS-12-C (NYS-12/12-A/12-B/12-C) 13 On behalf of the State of New York, the Office of the 14 Attorney General hereby submits the following testimony by 15 François J. Lemay regarding Consolidated Contention NYS-12-C.

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

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

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

22 United States Nuclear Regulatory Commission Official Hearing Exhibit In the Matter of

Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3)

ASLBP #:07-858-03-LR-BD01 Docket #:05000247 l 05000286 Exhibit #:

Identified:

Admitted: Withdrawn:

Rejected: Stricken: Other: NYS000241-00-BD0110/15/2012 10/15/2012 NYS000241 Submitted: December 21, 2011 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 2 Q: Please summarize your educational and professional 23 qualifications.

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

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

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

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

43 I also have extensive experience with COSYMA, a code from the 44 European Union that is similar to MACCS, and have performed 45 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 3 similar calculations for ESKOM in South Africa, Hydro-Quebec and 46 New Brunswick Power in Canada, and the Canadian Navy. I also 47 used COSYMA to calculate the cost of accidents near Darlington 48 and Gentilly for the Canadian Department of Natural Resources.

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

52 A: Yes. 53 Q: Dr. Lemay, I show you what has been marked as Exhibit 54 NYSR70001. Do you recognize this document?

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

58 Q: What is the source of those materials?

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

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

64 A: Yes. These are true and accurate copies of the 65 documents that were referred to, used and/or relied upon in 66 preparing the ISR report and this testimony. In some cases, 67 where the document was extremely long and only a small portion 68 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 4 is relevant to my testimony, an excerpt of the document is 69 provided. If it is only an excerpt, that is noted on the first 70 page of the Exhibit.

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

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

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

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

82 140-145 (November 30, 2007); Answer of Entergy Opposing New York 83 State Notice of Intention to Participate and Petition to 84 Intervene, section on NYS-12, at pp. 86-91 (January 22, 2008);

85 NRC Staff's Response to Petitions for Leave to Intervene, 86 section on NYS-12, at pp. 50-52 (January 22, 2008); NYS Reply in 87 Support of Petition to Intervene, Contention 12, at pp. 75-81 88 (February 22, 2008); the portion of the transcript of the March 89 2008 hearing before the Board concerning the MACCS2 code; the 90 July 31, 2008 Board Order (see infra note 1); NYS Contentions 91 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 5 Concerning NRC Staff's Draft Supplemental Environmental Impact 92 Statement, Contention 12-A, at pp. 2-9 (February 27, 2008);

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

104 Applicant's Answer to NYS New and A mended Contentions Concerning 105 Entergy's December 2009 Revised SAMA Analysis, Contention 12-B, 106 at pp. 1-19 (April 5, 2010); NRC Staff's Answer to NYS New and 107 Amended Contentions Concerning the December 2009 SAMA 108 Reanalysis, Contention 12-B, at pp. 1-12 (April 5, 2010); the 109 June 30, 2010 Board Order (see infra , note 1); NYS New 110 Contention 12-C concerning NRC Staff's December 2010 FEIS and 111 the Underestimation of Decontamination and Clean Up Costs 112 Associated With a Severe Reactor Accident in the New York 113 Metropolitan Area (February 3, 2011) (including the February 114 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 6 2011 declaration of David Chanin); NYS Motion for Leave to File 115 New and Amended Contention 12-C (February 3, 2011); Applicant's 116 Answer to NYS Amended Contention 12C (March 7, 2011); NRC 117 Staff's Answer to NYS Contention 12-C (March 7, 2011); NYS 118 Combined Reply to NRC Staff and Entergy's Answers to Contention 119 12-C (March 18, 2011); and the July 6, 2011 Board Order.

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

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

1 The Board consolidated these 127 contentions and I will collectively refer to them as 128 Consolidated NYS-12-C.

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

131 1 See Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3) LBP-08-13, 61-65 (July 31, 2008);

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

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

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

Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 7 A: As I explained earlier, I have reviewed pleadings and 132 orders related to NYS-12, NYS-12-A, NYS-12-B, and NYS-12-C.

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

146 Consolidated NYS C asserts that Entergy's ER, NRC 147 Staff's Draft Supplemental Environmental Impact Statement , which 148 I'll refer to as DSEIS, Entergy's De cember 2009 SAMA Reanalysis 149 a nd NRC Staff's F SEIS failed to address site specific 150 assumptions and inputs related to clean-up and decontamination 151 costs in the New York City metropolitan region in the event of a 152 severe accident at IP. In Consolidated NYS-12-C, NYS asserts 153 that NRC Staff and Entergy substantially underestimate the costs 154 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 8 of decontamination measures which must be considered in the 155 License Renewal Application process.

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

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

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

-169 A/12-B contained in Appendix G to the FSEIS.

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

172 A: This testimony will explain ISR's review an d 173 assessment of Entergy's use of the MACCS2 code to estimate the 174 economic costs associated with a severe accident at IP for its 175 SAMA analysis, and NRC Staff's evaluation of Entergy's SAMA 176 analysis as part of the FSEIS. ISR's review and evaluation 177 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 9 encompasses the assumptions inherent in the MACCS2 code. In 178 particular, this includes the input parameters to the CHRONC 179 module of the code which were developed and used by Entergy for 180 its SAMA analysis, and the NRC's discussion of these issues in 181 the FSEIS. ISR

's analysis is focused on the effect of the 182 critical input parameters on the total economic cost of a severe 183 nuclear accident.

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

185 Do you recognize this document?

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

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

192 A: Yes. 193 Q: Please summarize ISR's conclusions.

194 A: ISR has concluded that Entergy underestimated the 195 total economic cost of a severe nuclear accident at IP. This 196 underestimation is primarily a result of Entergy's use of MACCS2 197 Sample Problem A input values for the CHRONC module and was 198 largely due to Entergy's use of costs and times for 199 decontamination that were unrealistic given current known 200 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 10 decontamination data and the complexities of an urban to hyper-201 urban area such as that surrounding IP.

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

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

219 Q: How is a SAMA analysis performed?

220 A: To determine whether a SAMA is cost-beneficial, it is 221 necessary to determine the statistical expectation value of the 222 benefit of implementing a SAMA, which is compared to the cost of 223 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 11 implementing the SAMA. The expectation value of the benefit is 224 obtained by calculating the economic consequences of a range of 225 accidents and weighting these consequences by the probability of 226 their occurrence. Accordingly, a SAMA analysis is probabilistic, 227 averaging the economic consequences over a range of accidents, 228 weather scenarios and physical locations. The analysis models 229 the dispersion of a cloud of radioactive dust and its deposition 230 on the ground. It uses a year's worth of site-specific 231 meteorological data to predict the probabilistic consequences of 232 an accident over the 50-mile radius area around the site. It 233 also uses site-specific population density and economic activity 234 parameters to evaluate the costs of an accident. The ultimate 235 goal is a cost-benefit analysis comparing the expected value of 236 the avoided consequences against the cost of implementing 237 specific preventative or mitigative measures.

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

243 A: Yes. It is called MELCOR Accident Consequence Code 244 Systems 2, or MACCS2. To the best of my knowledge, the MACCS2 245 code is the only computer model used in the United States for 246 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 12 performing the consequence portion of a full SAMA analysis. In 247 other jurisdictions (such as Canada) the COSYMA Code has also 248 been used for the same purpose. For IP, Entergy used the MACCS2 249 code to estimate the cost of decontamination and costs of 250 evacuation and relocation after a severe accident.

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

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

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

268 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 13 A: MACCS incorporates many improvements in modeling 269 flexibility in comparison to CRAC2. While the underlying models 270 of CRAC2 and MACCS are largely similar, the main difference 271 between the two is that a number of parameters are "hard

-wired" 272 and, thus, cannot be changed in the CRAC code. In MACCS and 273 MACCS2, those same parameters are user-defined and, thus, can be 274 derived from site-specific data. Essentially, the MACCS and 275 MACCS2 updates to the CRAC code facilitate the analysis of 276 consequence uncertainties in the model parameters.

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

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

284 Q: How does the MACCS2 model operate?

285 A: MACCS2 is executed in three steps. The first module, 286 ATMOS, calculates air and ground concentrations, plume size, and 287 timing information for all plume segments as a function of 288 downwind distance. The next module, EARLY, calculates the 289 consequences due to exposure to radiation in the first seven 290 days, which is the emergency phase of the accident. The last 291 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 14 module, CHRONC, calculates the consequence of the long-term 292 effects of radiation and computes the decontamination and 293 economic impacts incurred due to the accident.

294 2. The CHRONC Module of the MACCS2 Code 295 Q: Did ISR's analysis focus on particular aspects of the 296 MACCS2 code?

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

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

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

314 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 15 MACCS2 determines the economic cost of a severe accident 315 primarily on the basis of the CHRONC input parameters. The 316 CHRONC module contains two models: the economic cost model and 317 mitigative actions model.

318 Q: Please describe CHRONC's economic cost model.

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

325 Q: Are costs based on user-defined inputs to the MACCS2 326 code? 327 A: Yes. The following costs are treated as user defined 328 inputs in the economic models implemented in the MACCS2 code:

329 (1) Food and lodging costs for short-term relocation of 330 people who are evacuated or relocated during the emergency phase 331 of the accident; 332 (2) Decontamination costs for property that can be returned 333 to use if decontaminated; 334 (3) Economic losses incurred while property, both farm and 335 nonfarm, is temporarily interdicted for a period of time 336 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 16 following decontamination to allow for radioactive decay to 337 reduce ground contamination to acceptable levels; 338 (4) Economic losses resulting from milk and crop disposal; 339 and 340 (5) Economic losses due to permanent interdiction of 341 property.

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

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

347 Q: What is the purpose of CHRONC's mitigative actions 348 model? 349 A: CHRONC's mitigative actions module determines what 350 mitigative strategies to employ for a severe accident.

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

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

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

358 (1) No mitigative actions 359 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 17 (2) Decontaminate areas using the lowest selected 360 decontamination factor; 361 (3) Decontaminate areas using the highest selected 362 decontamination factor; 363 (4) Decontaminate areas using the highest selected 364 decontamination factor and implement temporary interdiction for 365 up to 30 years; or 366 (5) Condemn the area.

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

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

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

380 A: The decision on which mitigative action to implement 381 hinges on a threshold value, the habitability criterion, which 382 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 18 I'll refer to as HC. The HC is dependent on the long-term 383 projected dose that a person would get if he or she continued to 384 live in the contaminated area for the specified time. The HC 385 recommended by the US Environmental Protection Agency is 0.04 386 Sieverts in 5 years.

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

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

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

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

402 (4) If decontamination using the highest selected DF and 403 temporary relocation for any time less than 30 years to allow 404 for radioactive decay results in a dose less than the HC, 405 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 19 decontaminate to the highest selected DF and move back after 406 TIMDEC2 plus the interdiction time, otherwise:

407 (5) Condemn the property.

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

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

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

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

425 Thus, to determine reasonable input values, one must look at 426 site-specific data or, where site-specific data is not 427 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 20 available, modify available data to reflect site-specific 428 conditions.

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

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

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

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

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

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

450 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 21 Q: Did ISR evaluate Entergy's use of the MACCS2 code?

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

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

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

457 Q: And what did ISR determine?

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

464 Q: What is Sample Problem A?

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

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

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

473 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 22 A: The NUREG-1150 authors chose five commercial nuclear 474 plants of different design to estimate the risks of a severe 475 accident. One of these, the Surry reactor, is a Westinghouse 476 designed three-loop reactor in a large, dry containment building 477 located near Williamsburg, Virginia. Using the Surry reactor in 478 Sample Problem A allowed the authors of MACCS2 to test the food 479 chain model because it is largely surrounded by farmland.

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

482 A: No. Neither he MACCS nor MACCS2 documentation 483 suggests that the input values of the code sample problems be 484 considered recommended or default values. In fact, David 485 Chanin, the developer of the MACCS2 code, discussed the use of 486 Sample Problem A as default values in his 2005 paper, "The 487 Development of MACCS2: Lessons Learned

". In this paper, he 488 stated "We also went so far as to scrupulously avoid using the 489 common 'default value' in referring to the code's provided 490 'Sample Problem' input data files. 'Sample data' and 'example 491 usage' were the terms used to remind the analyst that they, and 492 they alone, were responsible for reviewing MACCS and MACCS2 493 input data and resultant code outputs to ensure appropriateness 494 for their application."

495 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 23 Q: Did Entergy use the inputs from Sample Problem A to 496 derive the input values it used for its SAMA analysis?

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

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

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

511 VI. ISR'S MACCS2 CODE SENSITIVITY ANALYSIS 512 Q: Dr. Lemay, let's move on to the specifics of ISR's 513 analysis of the economic costs associated with a severe accident 514 at IP. W hat was the first step in ISR's analysis

? 515 A: ISR conducted a sensitivity analysis on the MACCS2 516 code to determine which input parameters directly and most 517 significantly affect the costs of mitigative actions following a 518 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 24 severe accident. This allowed ISR to focus on input parameters 519 that could make a difference in the cost of mitigative actions.

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

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

532 Q: How did ISR evaluate the sensitivity of the MACCS2 533 model? 534 A: To evaluate the sensitivity of each of the CHRONC 535 input parameters, ISR varied each input parameter, one at a 536 time, and performed a MACCS2 simulation run for IP2 using 537 Entergy's five input files which include the ATMOS, EARLY, 538 CHRONC weather, and site file.

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

541 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 25 A: ISR chose to quantify the effect of changing each 542 parameter by calculating the change in the resulting total 543 offsite economic cost risk, which I will refer to as OECR.

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

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

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

557 The OECR is obtained by adding the total offsite economic 558 cost for each of the eight release categories after weighting 559 them by their respective frequencies. The release categories 560 correspond to an end state of the reactor (such as core melt) 561 and each have an associated frequency. The OECR calculated by 562 Entergy using Sample Problem A input values was $2.12E+05/yr for 563 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 26 IP2. ISR used Entergy's OECR as a basis for comparison to ISR's 564 calculated OECRs.

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

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

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

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

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

580 A: ISR determined that eleven parameters were sensitive.

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

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

586 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 27 A: Yes, ISR determined that decontamination costs are the 587 dominant factor in the evaluation of the remediation costs 588 following a severe nuclear accident. The most sensitive input 589 parameters related to decontamination costs include:

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

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

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

600 A. Decontamination Factor (DF) 601 Q: Dr. Lemay, I'd like to discuss each of these sensitive 602 parameters with you. Let's start with the decontamination 603 factor. What is a decontamination factor?

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

609 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 28 Table 1: Reduction in contamination for each DF 610 DF Reduction in contamination 2 50% 3 67% 5 80% 7 85.7% 10 90% 15 93.3% 20 95% 611 For example, to achieve a DF of 3, 67% of the contamination 612 would need to be removed. To achieve a DF of 15, 93.3% of the 613 contamination would need to be removed. Decontamination factors 614 may be classified as light, moderate, or heavy. These 615 classifications correlate with differing activities and degrees 616 of cleanup.

617 Q: Could you explain what light decontamination means?

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

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

626 Q: What does moderate decontamination mean?

627 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 29 A: Moderate decontamination includes activities such as 628 removing and replacing roofing and all landscape material.

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

632 removal of contamination.

633 Q: What does heavy decontamination mean?

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

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

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

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

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

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

649 650 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 30 B. Approaches for Nonfarm Decontamination Cost (CDNFRM) 651 Q: Please describe Nonfarm Decontamination Cost, which I 652 will refer to as CDNFRM.

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

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

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

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

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

672 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 31 Q: Did ISR evaluate other methods for calculating a 673 realistic CDNFRM that would be more applicable to IP?

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

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

". 681 (2) Second, for each of these two areas, ISR calculated the 682 costs of light and/or heavy decontamination using the per square 683 kilometer decontamination costs obtained from the following four 684 sources: 685 Approach A is based on data from Site Restoration as 686 modified by Survey of Costs , which describe the results from US 687 plutonium dispersal tests; 688 Approach B relies upon data from Barbara Reichmuth

's 689 presentation of results from radiological dispersal device 690 economic consequence analysis in the US; 691 Approach C uses CONDO, a decontamination cost 692 estimation tool from the UK National Radiological Protection 693 Board, and its database; 694 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 32 Approach D relies upon data from RISO presenting 695 results from decontamination analyses completed by RISO National 696 Laboratory in Denmark.

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

708 709 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 33 Value of CDNFRM(2005)CONDO, cost per km 2RISO, cost per km 2ISR assuming DF (Pu) = DF (Cs) andDF (Pu) = 1/2 DF (Cs)Entergy, from MACCS2 Sample Problem A (CPI adjusted)CONDO, using area fractions for medium population densitiesEntergy Site file, using spatial grid areas ReichmuthCONDO, using area fractions for high population densitiesSite Restoration as modified by Survey of Costs and ISR cost per km 2Cost per km 2 for cesium, for a generic area Cost per km 2 for cesium, for NYC metro area and elsewhere Cost per km 2 for plutonium, for NYC metro area and elsewhere Cost per km 2 for cesium, for NYC metro area and elsewhereEntergy Site file, using population dataTotal cost for cesium, for entire 50-mi radius areaPer capita cost for cesium, for entire 50-mi radius areaPer capita cost for cesium, for entire 50-mi radius areaPer capita cost for cesium, for NYC and Vancouver, Canada areasApproach AApproach CApproach DApproach B 710Figure 3: ISR's methodology for determining light and heavy decontamination costs (CDNFRM) 711 712 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 34 713 1. Approach A:

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

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

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

729 Survey of Costs subsequently used the Site Restoration 730 analysis as a basis for calculating the cost of cleanup of the 731 hyper-dense population area of interest here, NYC. To do this, 732 Survey of Costs used the actual area coverage percentage in NYC 733 for Site Restoration

's five categories of land use and then 734 multiplied the results by the population density ratio of NYC to 735 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 35 Albuquerque, to account for the greater structure density in 736 NYC. In Survey of Costs , Luna pre-supposes that building 737 density is directly proportional to population density.

738 ISR's calculation was a modification of both Site 739 Restoration and Survey of Costs. Instead of assuming that 740 building density is directly proportional to population density, 741 ISR used the actual building densities for NYC and Albuquerque 742 obtained from US Census data to modify Site Restoration and 743 Survey of Costs and arrive at a range of appropriate 744 decontamination costs. The average building density for the 745 five NYC boroughs is 13,980 buildings/mi 2 , compared to 1,557 746 buildings/mi 2 for Albuquerque.

747 ISR's results a re shown in Table 2 below, which was taken 748 from the ISR report, Exhibit NYS000242.

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

Land Use Area Fraction in NYC Light (2<DF<5) ($M/km 2) Moderate (5<DF<10) ($M/km 2) Heavy (DF>10) ($M/km 2) Building Density Multiplier Light (2<DF<5) ($M/km 2) Moderate (5<DF<10) ($M/km 2) Heavy (DF>10) ($M/km 2) Residential 0.287 $20.31 $45.99 $84.51 8.98 $182.38 $412.99 $758.90 Commercial 0.164 $32.09 $48.55 $139.84 8.98 $288.17 $435.98 $1,255.76 Industrial 0.068 $45.51 $47.55 $84.12 1.00 $45.51 $47.55 $84.12 Streets 0.250 $3.97 $4.62 $61.88 1.00 $3.97 $4.62 $61.88 Vacant land 0.238 $19.29 $20.38 $22.64 1.00 $19.29 $20.38 $22.64 Overall cost

$121.17 $167.09 $392.99 $539.32 $921.52 $2,183.30 751 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 36 Q: You mentioned that Site Restoration used historical 752 data for plutonium and other radionuclides. Do the ability and 753 methods used to decontaminate vary depending on the 754 radionuclides involved in a radioactive release?

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

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

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

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

773 The smaller particles have a lower deposition velocity and they 774 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 37 tend to disperse further downwind. Their concentration on the 775 surface is typically lower and the size of the zone to 776 decontaminate is larger.

777 Q: Why does cesium make decontamination challenging?

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

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

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

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

797 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 38 A: Yes. First, ISR evaluated the results obtained from 798 one of the more recent Holt decontamination experiments 799 described in Exhibit NYS000259. In that experiment, Sandia 800 attempted to remove both cesium and plutonium from concrete 801 using a decontamination technique called strippable coatings.

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

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

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

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

817 Q: In its approach A, Site Restoration/Survey of Costs , 818 calculations, how did ISR account for the likelihood that 819 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 39 cesium, and possibly small quantities of plutonium, will be 820 released if there is severe accident at IP?

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

830 831 Table 3: Suggested values of CDNFRM assuming cost (cesium) = cost (plutonium) (costs in 2005 832 USD) 833 Light Decontamination (DF=3) Heavy Decontamination (DF=15)

NYC metro Area Outside NYC Metro Area NYC metro Area Outside NYC Metro Area Cost per km 2 ($) from Site Restoration

/Survey of Costs 5.39E+08 1.21E+08 2.18E+09 3.93E+08 Total area within 50-mi radius (km 2) 356 19986 356 19986 Total cost for the area ($) 1.92E+11 2.42E+12 7.77E+11 7.85E+12 Total cost over 50-mi radius ($) 2.61E+12 8.63E+12 Population over 50-mi radius 19,228,712 19,228,712 CDNFRM Per capita cost ($, 2005) 135,927 448,889 834 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 40 Table 4: Suggested values of CDNFRM assuming cost (cesium) = 2 x cost (plutonium) (costs in 835 2005 USD) 836 Light Decontamination (DF=3) Heavy Decontamination (DF=15)

NYC metro Area Outside NYC Metro Area NYC metro Area Outside NYC Metro Area Cost per km 2 ($) from Site Restoration

/Survey of Costs 1.08E+09 2.42E+08 4.37E+09 7.86E+08 Total area within 50-mi radius (km 2) 356 19986 356 19986 Total cost for the area ($) 3.84E+11 4.84E+12 1.55E+12 1.57E+13 Total cost over 50-mi radius ($) 5.23E+12 1.73E+13 Population over 50-mi radius 19,228,712 19,228,712 CDNFRM Per capita cost ($, 2005) 271,854 897,778 837 838 As you can see from the calculations in Tables 3 and 4, 839 ISR's modifications to Site Restoration/Survey of Costs results 840 in a range of appropriate values for CDNFRM. ISR has determined 841 that the 2005 adjusted cost of light decontamination would be 842 between $135,927 and $271,854 per person, while the cost of 843 heavy decontamination would be between $448,889 and $897,778 per 844 person. 845 Q: How does ISR's range of values calculated using 846 approach A compare to Entergy's values?

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

849 850 851 852 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 41 2. Approach B: Reichmuth 853 Q: Dr. Lemay, let's discuss the second approach ISR used 854 to determine CDNFRM. Please describe that approach.

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

859 Q: What relevant studies did Barbara Reichmuth conduct?

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

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

869 Of particular relevance here is Reichmuth's work with RDDs 870 involving cesium, Exhibit NYS000256. While ISR recognizes that 871 the mechanisms for dispersal differ between a reactor accident 872 and an RDD event, the key factor in determining cost for both is 873 removal of cesium from porous substances such as concrete found 874 in urban areas. In Exhibit NYS000256, Reichmuth derived costs 875 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 42 for an RDD event based on a dose rate limit for rehabitation, 876 which is similar to the HC used by Entergy in its MACCS2 code 877 inputs. 878 Q: How did ISR use the Reichmuth studies to determine an 879 appropriate CNDFRM value for IP?

880 A: The decontamination techniques proposed by Reichmuth 881 correspond to heavy decontamination. Therefore, using 882 Reichmuth's results , the cost for nonfarm heavy decontamination 883 equivalent to Entergy's DF of 15 would be between $200,000 and 884 $252,000 per person. Since Reichmuth assessed the costs of 885 cesium decontamination in NYC and Vancouver, these values are 886 directly relevant to the cost of remediation for an accident at 887 IP. 888 Q: How do Reichmuth's decontamination costs compare to 889 Entergy's CDNFRM inputs?

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

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

896 A: In approach C, ISR derived decontamination costs using 897 CONDO. 898 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 43 Q: What is CONDO?

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

906 Q: How does CONDO calculate decontamination costs?

907 A: CONDO includes a database which contains 908 decontamination costs per km 2 of land. The database includes 909 costs for decontamination techniques as well as various types of 910 land areas like paved areas, buildings, trees, and many others.

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

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

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

918 A: Because the NYC metropolitan area is comprised of both 919 urban and hyper-urban population densities, ISR performed 920 calculations in CONDO to obtain a range of decontamination 921 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 44 values for light decontamination, Entergy's DF of 3, and heavy 922 decontamination , Entergy's DF of 15. 923 For the first CONDO calculation, ISR assumed that the NYC 924 metropolitan area has an urban population density of greater 925 than 1,000 persons per km 2 , and everywhere else has a population 926 density less than 1,000 persons per km

2. ISR performed this 927 calculation for light and heavy decontamination.

928 For the second calculation, ISR assumed that the NYC 929 metropolitan area has a hyper-urban population density of about 930 10,000 persons per km 2 , and everywhere else has a population 931 density between 1,000 and 10,000 persons per km

2. ISR performed 932 this calculation for light and heavy decontamination.

933 Annex C to the ISR report, Exhibit NYS000242, contains the 934 details of ISR's CONDO calculations.

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

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

943 944 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 45 Table 1: Costs using CONDO values assuming the NYC metro area is classified as urban and the 945 area outside the NYC metro area is classified as semi-urban (costs in 2005 USD) 946 Light Decontamination (DF=3) Heavy Decontamination (DF=15) NYC metro Area Outside NYC Metro Area NYC metro Area Outside NYC Metro Area Cost per km 2, ($) (Annex C) 2.78E+07 1.82E+07 1.31E+08 8.40E+07 Total area (km

2) 356 19986 356 19986 Total cost for the area ($) 9.90E+09 3.64E+11 4.66E+10 1.68E+12 Total cost over 50-mi radius ($) 3.74E+11 1.73E+12 Population over 50-mi radius 19,228,712 19,228,712 CDNFRM Per capita cost ($, 2005) 19,431 89,734 947 Table 2: Costs using CONDO values assuming the NYC metro area is classified as hyper-urban 948 and the area outside the NYC metro area is classified as urban (costs in 2005 USD) 949 Light Decontamination (DF=3) Heavy Decontamination (DF=15) NYC metro Area Outside NYC Metro Area NYC metro Area Outside NYC Metro Area Cost per km 2, ($) (Annex C) 5.61E+07 2.78E+07 2.64E+08 1.31E+08 Total area (km

2) 356 19986 356 19986 Total cost for the area ($) 2.00E+10 5.56E+11 9.40E+10 2.62E+12 Total cost over 50-mi radius ($) 5.76E+11 2.71E+12 Population over 50-mi radius 19,228,712 19,228,712 CDNFRM Per capita cost ($, 2005) 29,933 140,430 950 951 Q: How do the results ISR obtained using CONDO compare to 952 Entergy's CDNFRM inputs?

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

958 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 46 959 4. Approach D: RISO 960 Q: Please describe the last approach ISR used to 961 determine CDNFRM.

962 A: For approach D, which I'll refer to as RISO, ISR 963 repeated the methodology used for the CONDO approach, but 964 substituted the costs per km 2 reported by the Riso National 965 Laboratory, Exhibit NYS000251, for the costs reported in the 966 CONDO dataset.

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

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

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

980 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 47 The RISO cost rates are provided in Annex C to the ISR 981 report, Exhibit NYS000242.

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

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

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

987 Table 3: Costs using RISO values assuming the NYC metro area is classified as urban and the 988 area outside the NYC metro area is classified as semi-urban (costs in 2005 USD) 989 Light Decontamination (DF=3) NYC metro Area Outside NYC Metro Area Cost per km 2 ($) (Annex C) 5.46E+07 3.34E+07 Total area within 50-mi radius (km

2) 356 19985 Total cost for the area ($) 1.94E+10 6.68E+11 Total cost over 50-mi radius ($) 6.87E+11 Population over 50-mi radius 19,228,712 CDNFRM Per capita cost ($, 2005) 35,726 990 Table 4: Costs using RISO values assuming the NYC metro area is classified as hyper-urban and 991 the area outside the NYC metro area is classified as urban (costs in 2005 USD) 992 Light Decontamination (DF=3) NYC metro Area Outside NYC Metro Area Cost per km 2 ($)(Annex C) 1.17E+08 5.46E+07 Total area within 50-mi radius (km

2) 356 19985 Total cost for the area ($) 4.17E+10 1.09E+12 Total cost over 50-mi radius ($) 1.13E+12 Population over 50-mi radius 19,228,712 CDNFRM Per capita cost ($,2005) 58,916 993 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 48 Q: How do the results ISR obtained using RISO compare to 994 Entergy's CDNFRM inputs?

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

1000 5. Summary of ISR's Calculated Decontamination Costs 1001 Q: Have you completed describing the four approaches ISR 1002 used to calculate appropriate ranges of decontamination costs 1003 for IP? 1004 A: Yes. 1005 Q: Could you summarize the results of ISR's 1006 decontamination cost calculations?

1007 A: Yes. The following Table 11 and Figure 4, which are 1008 taken from the ISR report, Exhibit NYS000242, summarize the 1009 ranges of decontamination costs calculated by ISR. As you can 1010 see, the range of decontamination costs ISR calculated by using 1011 the four approaches I just described are much higher than the 1012 decontamination costs calculated by Entergy using Sample Problem 1013 A. In fact, none of the range of values calculated by ISR goes 1014 as low as the values used by Entergy. It is therefore likely 1015 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 49 that the decontamination costs used by Entergy in the MACCS2 1016 input file underestimate the cost of decontamination.

1017 Table 11: Summary of ISR's decontamination costs 1018 Approach Reference or Source of Data CDNFRM ($/person, 2005) Light Decontamination Heavy Decontamination

- Entergy (Sample Problem A) 5,184 13,824 A Site Restoration/Luna 136,000 - 272,000 449,000 - 898,000 B Reichmuth Not available 200,000

- 252,000 C CONDO 19,000 - 30,000 90,000

- 140,000 D RISO 36,000 - 59,000 Not available - Aggregate 19,000 - 272,000 90,000 - 898,000 1019 $-$100,000 $200,000 $300,000 $400,000 $500,000 $600,000 $700,000 $800,000 $900,000 $1,000,000 Entergy (Sample Problem A)Chanin/LunaReichmuth*CONDORISO*Aggregate of the four sources examined in this reportPer capita non-farm decontamination costReference or source of dataLight decontaminationHeavy decontamination*Therewas no data available for light decontamination based on Reichmuth's studies or for heavy decontamination based on RISO's studiesColumns indicatethe midpoint of the range represented by the high-low values 1020 Figure 4: Graphical summary of decontamination costs with ranges 1021 1022 Q: Does the MACCS2 source code, as written, limit the 1023 decontamination cost input, CDNFRM, that can be calculated and 1024 considered?

1025 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 50 A: Yes, the MACCS2 code limits CDNFRM to a maximum of 1026 $100,000/person.

1027 Q: How did ISR calculate OECR given the fact that ISR's 1028 range of appropriate CDNFRM values exceeds $100,000 per person?

1029 A: ISR had to modify the MACCS2 source code to allow for 1030 the greater decontamination costs calculated by the approaches I 1031 just presented and which are discussed in its report. ISR found 1032 where the authors of the code had limited the value of CDNFRM to 1033 be less than $100,000 per person and removed this single line of 1034 code. 1035 Q: In the MACCS2 code, is there a point at which it is 1036 not longer cost-effective to decontaminate and property will be 1037 condemned instead of decontaminated?

1038 A: Yes. Once decontamination costs reach $200,000 per 1039 person, it will be more cost-effective to condemn property than 1040 to decontaminate according to the MACCS2 code calculations.

1041 Q: Could you explain how this happens?

1042 A: As shown in Figure 5 below, which was taken from the 1043 ISR report, Exhibit NYS000242, the OECR reaches a maximum when 1044 decontamination costs reach around $200,000/person. This is the 1045 threshold near which the cost of decontaminating equals that of 1046 condemning property. In the MACCS2 code, the cost of 1047 condemnation is governed by the value of nonfarm wealth, which I 1048 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 51 will discuss later on in my testimony. The value of nonfarm 1049 wealth is a user-defined value, set with input parameter VALWNF.

1050 Figure 5: OECR vs heavy decontamination cost 1051 0.00E+001.00E+052.00E+053.00E+054.00E+055.00E+056.00E+057.00E+05050100150200250300350400OECR ($/yr)CDNFRM, DF=15 ($ thousand/person) 1052 If the cost of heavy decontamination is greater than 1053 $200,000/person, the resulting OECR calculated by ISR is 1054 $581,000/year, which is 2.74 times the OECR calculated by 1055 Entergy ($212,000/year for IP2).

1056 3. Decontamination Time (TIMDEC) 1057 Q: Dr. Lemay, now that we have completed describing the 1058 work performed by ISR to evaluate the nonfarm decontamination 1059 cost input parameter to the MACCS2 code, can you please describe 1060 the next sensitive parameter ISR evaluated?

1061 A: Yes, the next sensitive parameter we evaluated was the 1062 Decontamination Time, which is called TIMDEC in the code.

1063 Q: What is TIMDEC?

1064 A: TIMDEC is a MACCS2 input parameter used by the code to 1065 account for the time it would take to decontaminate following a 1066 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 52 severe accident. The MACCS2 code requires users to input two 1067 decontamination times: one for the lower DF, and one for the 1068 higher DF. As discussed previously, DFs of 3 and 15 were used 1069 by Entergy and therefore, by ISR, in this analysis.

1070 Q: What inputs did Entergy use for the TIMDEC parameter?

1071 A: Once again, Entergy took its inputs directly from 1072 Sample Problem A. These inputs are 60 days for a DF of 3 and 1073 120 days for DF of 15.

1074 Q: How did ISR assess whether Entergy's use of the Sample 1075 Problem A TIMDEC inputs of 60 and 120 days produced realistic 1076 costs for decontamination?

1077 A: ISR determined this by comparing Entergy's inputs to 1078 two actual severe accidents: Chernobyl and Fukushima.

1079 For Chernobyl, large-scale decontamination of the area 1080 affected by the accident terminated four years after the 1081 accident. This included the decontamination of tens of 1082 thousands of buildings in the most contaminated cities and 1083 villages of the former USSR. Since large-scale decontamination 1084 efforts stopped prematurely is not possible for anyone to 1085 estimate what the total duration of a clean-up for the Chernobyl 1086 accident could have been.

1087 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 53 Although decontamination following the Fukushima nuclear 1088 accident has barely begun, some estimates suggests that the 1089 decontamination could last for decades.

1090 Q: How did ISR use the Chernobyl and Fukushima 1091 information in its calculations?

1092 A: ISR used the MACCS2 code to calculate the effect that 1093 increased decontamination times, TIMDEC, would have on cost.

1094 Figure 6 from the ISR report, Exhibit NYS000242, is a graphical 1095 depiction of the effect of decontamination time on cost in 1096 MACCS2. Figure 6 shows that OECR increases as TIMDEC increases.

1097 Total economic cost increases over time because relocation costs 1098 increase as decontamination time increases. As the OECR 1099 increases due to decontamination time, it becomes more cost-1100 effective to condemn infrastructure and buildings and therefore 1101 the OECR plateaus.

1102 0.00E+002.00E+054.00E+056.00E+058.00E+051.00E+061.20E+061.40E+06051015202530OECR ($/yr)Decontamination (DF=15) time (years)Decontamination (DF=3) time is half as long 1103 Figure 6: OECR (2005 USD) for decontamination times up to 30 years 1104 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 54 1105 Q: Does the MACCS2 source code, as written, restrict the 1106 decontamination time, TIMDEC, input values?

1107 A: Yes, the MACCS2 code limits decontamination times to a 1108 maximum of one year. Thus, ISR had to modify the source code to 1109 allow for the likelihood that decontamination would take longer 1110 than the values from Sample Problem A and longer than one year.

1111 Q: What did ISR conclude from its assessment of Entergy's 1112 TIMDEC inputs?

1113 A: ISR concluded that Entergy's decontamination times of 1114 60 and 120 days, which were taken from Sample Problem A are 1115 unreasonable and have not been justified with supportive 1116 evidence. Considering large-scale decontamination took four 1117 years after Chernobyl, it is reasonable to expect that the 1118 decontamination time would be at least four years of continuous 1119 time for a severe accident at IP, which is surrounded by a much 1120 more densely populated and developed area that that which 1121 surrounds Chernobyl.

1122 It is difficult to give a precise estimate of the time it 1123 would take to decontaminate a large urban area after a severe 1124 nuclear accident, given the fact that the Chernobyl clean-up was 1125 stopped after 4 years and given estimates that the Fukushima 1126 clean-up could last several decades. In order to assess the 1127 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 55 impact of longer decontamination times, ISR calculated the OECR 1128 from a range of 2 to 15 years for a DF of 3 and a range of 4 to 1129 30 years for a DF of 15.

1130 ISR determined that for this range of decontamination 1131 times, if all other inputs by Entergy remain unchanged, the 1132 resulting OECR calculated by ISR is 3 to 5.7 times higher than 1133 the OECR calculated by Entergy (2.12E+05 $/year for IP2).

1134 C. Value of Nonfarm Wealth (VALWNF) 1135 Q: Please discuss the next sensitive parameter ISR 1136 evaluated.

1137 A: The next sensitive parameter evaluated by ISR was 1138 value of nonfarm wealth, which I'll call VALWNF. As I testified 1139 previously, in MACCS2, the total economic cost, and therefore 1140 the OECR, reaches a maximum for decontamination costs around 1141 $200,000/person. This value is important since it limits the 1142 cost of decontamination. If the cost of decontamination exceeds 1143 the nonfarm wealth, the buildings are condemned and the nonfarm 1144 wealth is added to the cost of the accident.

1145 Q: How does the MACCS2 code manual define VALWNF?

1146 A: According to the MACCS2 manual, the value of the 1147 nonfarm wealth in the region includes all public and private 1148 property not associated with farming that would be unusable if 1149 the region was rendered either temporarily or permanently 1150 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 56 uninhabitable. The MAACS2 manual specifies that VALWNF should 1151 include the cost of land, buildings, infrastructure, and the 1152 cost of any nonrecoverable equipment or machinery.

1153 In MACCS2, the user must enter the value of nonfarm wealth 1154 in two input files: (1) the site data input file requires a 1155 value of nonfarm wealth, VNFRM, for each economic region or in 1156 the case of NY, each county; (2) the CHRONC input file requires 1157 a value of nonfarm wealth, VALWNF, for the entire region of 1158 interest (i.e. the 50-mile radius zone) that is an aggregate of 1159 the VNFRM values. ISR determined that the OECR output value is 1160 not sensitive to changes in the VNFRM values entered in the site 1161 data input, but is sensitive to the VALWNF value entered in the 1162 CHRONC input file.

1163 Q: What value did Entergy use for VALWNF?

1164 A: $208,838 per person.

1165 Q: Was Entergy's value for VALWNF derived from Sample 1166 Problem A?

1167 A: No. In fact, VALWNF, along with the value of farm 1168 wealth, VALWF, and the long-term exposure period, EXPTIM, was 1169 the only MACCS2 input value Entergy did not derive from Sample 1170 Problem A.

1171 Q: How did Entergy generate the VALWNF values?

1172 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 57 A: Entergy used a computer program called, SECPOP2000 as 1173 a starting point for its calculation of VALWNF.

1174 Q: What is SECPOP2000?

1175 A: SECPOP2000 is a sector population, land fraction and 1176 economic estimation program capable of generating MACCS2 input 1177 data. The SECPOP2000 calculation sums the Reproducible Tangible 1178 Wealth, value of the urban land, and farm household assets.

1179 Then SECPOP2000 subtracts the value of the farm assets, and 1180 divides by the entire population of the United States, resulting 1181 in a dollar/person value.

1182 Q: Why did Entergy use SECPOP2000 as a starting point for 1183 its calculation of VALWNF?

1184 A: According to Entergy, the VALWNF value cannot be 1185 readily calculated without recent data from the US Bureau of 1186 Economic Analysis, specifically data on "reproducible tangible 1187 wealth". In the absence of this data, Entergy used SECPOP2000 to 1188 generate the original VNFRM values, as tabulated in Entergy's 1189 report. 1190 Q: How did Entergy modify its SECPOP200-generated values?

1191 A: Entergy concluded that the SECPOP2000-provided values 1192 were not entirely adequate because SECPOP2000's da tabase uses 1193 1997 economic data. In an effort to better represent the 1194 economic worth of the area, Entergy obtained the Gross County 1195 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 58 Product, GCP, or Gross Metro Product, GMP, values per spatial 1196 sector surrounding IP for the year 2004. Entergy divided the 1197 GCP by the population to obtain a value of GCP/person.

1198 Entergy then added this GCP/person value to the original 1199 VNFRM value to obtain a final VNFRM value. Entergy felt that 1200 adjusting the SECPOP2000 output using GCP better represents the 1201 economic worth of the area surrounding IP. Finally, Entergy 1202 weighted these values by population surrounding IP to obtain a 1203 final VALWNF value for use as the MACCS2 CHRONC input.

1204 Q: In ISR's opinion, are Entergy's calculations of VALWNF 1205 complete?

1206 A: No, ISR concluded that Ente rgy's calculations of 1207 VALWNF are outdated since the values obtained from SECPOP2000 1208 were not scaled up from 1997 values to 2004 values. It should be 1209 noted that for every other input parameter evaluation, the costs 1210 calculated by Entergy and by ISR are adjusted to 2005 dollars.

1211 In this instance, ISR adjusted the costs to 2004 to allow direct 1212 comparison with the Entergy estimates. The difference between 1213 2004 and 2005 costs is not significant.

1214 Q: How did ISR revise Entergy's VALWNF calculation

? 1215 ISR scaled the SECPOP VNFRM values from 1997 to 2004 1216 dollars by using the increase in GDP: $8,332 billion for 1997 1217 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 59 and $11,853 billion for 2004 [30], resulting in an increase by a 1218 factor of 1.43.

1219 All of the SECPOP2000 VNFRM values were increased by a 1220 factor of 1.43 to better represent economic worth in 2004 1221 dollars. The rest of the calculation follow ed with Entergy's 1222 methodology. The GCP was then added to the SECPOP2000 to obtain 1223 VNFRM for each county.

1224 Q: What were the values that ISR obtained for VALWNF and 1225 how do they comp are to Entergy's values?

1226 A: The population-weighted sum of all counties in the 50-1227 mile radius around IP yields a VALWNF of $284,189 per person, 1228 which is higher than the value used by Entergy, which was 1229 $208,838. Using a VALWNF of $284,189 per person increases the 1230 final cost, OECR, by about 18%.

1231 D. Per capita cost of long-term relocation (POPCST) 1232 Q: What was the next parameter assessed by ISR?

1233 A: The next parameter assessed by ISR is the per capita 1234 cost of long-term relocation.

1235 Q: What value did Entergy use?

1236 A: Entergy's use of the value of $8,640 was based on a 1237 CPI-adjustment to 2005 of a moving cost of $5,000 in 1986 found 1238 in NUREG/CR-4551. The cost of $5,000 is the average between a 1239 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 60 moving cost of $4,500 and the cost of 140 days of lost wages 1240 estimated as $5,600.

1241 Q: How did ISR assess the estimation of the cost of long-1242 term relocation used by Entergy?

1243 A: First, ISR agreed that the moving expenses would 1244 contribute very little to the cost of long-term relocation since 1245 the majority of the personal belongings would be contaminated.

1246 Second, ISR felt that given current unemployment benefits 1247 policies in the State of New York, it seemed that 140 days of 1248 lost wages was too low.

1249 New York State unemployment benefits normally last 26 weeks 1250 (182 days) and have recently been extended to 93 weeks (651 1251 days). 1252 Q: What value of lost wages did you use?

1253 A: ISR calculated the cost of long-term relocation by 1254 multiplying the 2005 average income per capita ($76/day) by a 1255 range of duration for the lost wages. The resulting cost 1256 $10,640/person (for 140 days of lost wages) to $49,857/person 1257 (for 93 weeks of lost wages).

1258 E. Other Sensitive Parameters 1259 Q: After evaluating POPCST, did ISR analyze any other 1260 MACCS2 parameters in detail?

1261 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 61 A: Yes. ISR evaluated the effect of the following 1262 additional sensitive parameters on the OECR: Property 1263 Depreciation Rate or DPRATE, Societal Discount Rate for Property 1264 or DSRATE, and Nonfarm Wealth Improvements Fraction or FRNFIM.

1265 Q: Did Entergy use Sample Problem A values for these 1266 parameters?

1267 A: Yes. 1268 Q: Did ISR also conclude that it was inappropriate to use 1269 Sample Problem A values for these input parameters?

1270 A: Yes, as I previously explained, the MACCS2 code is 1271 designed to calculate economic costs based on site-specific 1272 data. Entergy did not attempt to derive site-specific inputs 1273 for these parameters. Instead they relied upon Sample Problem A 1274 adjusted for inflation. As I discussed previously, these values 1275 were developed for the Surry site, and were not intended as 1276 default values.

1277 Q: What did ISR conclude from its evaluation of these 1278 parameters?

1279 A: Having evaluated alternative inputs for these 1280 sensitive parameters, ISR deter mined that Entergy's use of 1281 Sample Problem A sometimes led Entergy to overestimate the OECR 1282 and sometimes led Entergy to underestimate the OECR. The 1283 overall effect of ISR's calculations using more appropriate 1284 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 62 values for the remaining sensitive parameters was negligible on 1285 the final OECR. A more detailed discussion of these 1286 calculations can be found in Section 4 of the ISR report, 1287 Exhibit NYS000242.

1288 VIII. ISR'S C OMPARISON OF ENTERGY'S MACCS2 INPUT VALUES WITH 1289 THOSE FROM OTHER NUCLEAR POWER PLANTS IN THE US 1290 Q: Dr. Lemay, did ISR review the MACCS2 input values used 1291 for the SAMA analysis at any other nuclear power plants in the 1292 US? 1293 A: Yes, we did. The ISR report provides a comparison of 1294 the MACCS2 input values used by Entergy with those of other 1295 nuclear power plant license applicants. Table 12 of the ISR 1296 report, Exhibit NYS000242, shows the values for parameters 1297 discussed in detail in the ISR report which are the most 1298 sensitive for cost determination. In the Table, ISR displays 1299 cost-parameter values in 2005 dollars, which was the reference 1300 year used for the IP analysis.

1301 Q: What was the purpose of performing this comparison?

1302 A: ISR was interested in comparing Ente rgy's MACCS2 1303 inputs with those of other nuclear power plants to determine 1304 whether others relied upon Sample Problem A or developed site-1305 specific data.

1306 Q: What does this comparison show?

1307 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 63 Q: It appears that for all the other nuclear power plants 1308 for which ISR obtained data, values for the decontamination 1309 costs, CDNFRM, and relocation costs, POPCST, were determined by 1310 adjusting MACCS2 Sample Problem A values using CPI. The value 1311 of non-farm wealth, VALWNF, for the various plants appears to be 1312 site-specific, likely resulting from location census data. The 1313 decontamination times, TIMDEC; depreciation rate, DPRATE; rate 1314 of return, DSRATE; and fraction of non-farm wealth due to 1315 improvements, FRNFIM; are all equivalent to the values used in 1316 Sample Problem A.

1317 Q: What did I SR conclude from its comparison of Entergy's 1318 input values to those of other nuclear power plants?

1319 A: It appears that no matter the specific location or 1320 attributes of the facility, the input values remain constant.

1321 This is because, with the exception of the value for VALWNF, 1322 they were derived from Sample Problem A. ISR has concluded that 1323 it is inappropriate to simply rely on Sample problem A for any 1324 and all power plants because the Sample Problem A inputs do not 1325 account for site-specific circumstances. For IP, a reliance on 1326 the generic Sample Problem A values has led to a significant 1327 underestimation of the costs of a severe accident.

1328 1329 1330 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 64 IX. ISR'S RESPONSE TO NRC STAFF EVALUATION (FSEIS APPENDIX G) 1331 Q: Did ISR review NRC Staff's Evaluation of Severe 1332 Accident Mitigation Alternatives which is found in Appendix G to 1333 the FSEIS?

1334 A: Yes. NYS asked ISR to review and respond to the NRC 1335 Staff's discussion related to Contention 12 in Section G.2.3 of 1336 the FSEIS. Section G.2.3. of the FSEIS also discusses work that 1337 NRC Staff asked Sandia to complete. In connection with its 1338 review of Appendix G, ISR also reviewed a Sandia report provided 1339 to the NRC Staff, Exhibit NYS000218, on issues discussed in 1340 Appendix G.

1341 Q: Dr. Lemay, I'd like to walk you through the NRC 1342 Staff's comments related to Contention 12 and ask you about 1343 ISR's response to those comments. Let's start on page G-23, 1344 lines 37-43. What is NRC Staff addressing here?

1345 A: NRC staff is responding to the portion of NYS 1346 Contention 12 where NYS asserts that the size of particles 1347 dispersed from a severe accident would be smaller than the 1348 particle size considered in MACCS2 and that it would be more 1349 expensive to decontaminate and clean up a suburban/urban area in 1350 which small-sized radionuclide particles have been dispersed.

1351 In their response, NRC Staff argued that they had reviewed the 1352 inputs and assumptions regarding particle size distribution and 1353 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 65 decontamination costs used in the SAMA analysis, and determined 1354 that the particle size utilized in the analysis was reasonable 1355 and acceptable.

1356 Q: What specific points does NRC Staff raise to support 1357 its position that the particle size utilized in Entergy's SAMA 1358 analysis was reasonable and acceptable?

1359 A: The NRC Staff discusses the difference between the 1360 primary constituent in weapons grade plutonium and the primary 1361 contaminant from a severe accident at a nuclear plant. NRC 1362 Staff notes that plutonium is an alpha emitter that's more 1363 difficult and expensive to characterize and verify in the field 1364 than gamma emitters like cesium. Also, NRC Staff states that 1365 plutonium is primarily an inhalation hazard with a much longer 1366 half-life than cesium, which is primarily an external health 1367 hazard. According to NRC Staff, the need for evacuating the 1368 public is much greater with plutonium because if inhaled, the 1369 health consequences can be severe.

1370 Q: What is ISR's response to this NRC Staff comment?

1371 A: By discussing the expense associated with 1372 characterizing plutonium, NRC Staff implies that radionuclide 1373 detection and characterization is a large part of the 1374 decontamination costs. While detection and characterization of 1375 plutonium may be more costly than for cesium, it comprises a 1376 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 66 small part of decontamination costs, less than 1% of the 1377 decontamination costs, according to Exhibit NYS000249. The main 1378 cost of decontamination is not radionuclide 1379 detection/characterization, but decontamination, removal, 1380 transport and storage of waste and/or building demolition.

1381 NRC Staff's discussion of the need for evacuation is 1382 inappropriate because public evacuation and the associated costs 1383 are not part of the MACCS2 code's assessment of economic costs.

1384 The SAMA analysis includes the costs of longer-term dose 1385 reduction measures such as permanent relocation and 1386 decontamination. It is the cost of these measures that should be 1387 assessed for plutonium and cesium.

1388 Q: Thank you. Let's move on to Appendix G, page G-24, 1389 lines 7-11. What is NRC Staff's addressing here?

1390 A: NRC Staff is describing Sandia's review of the 1391 decontamination methods discussed in Site Restoration. Sandia 1392 concluded that the activities in Site Restoration required to 1393 support clean-up of moderate plutonium contamination align more 1394 closely with clean-up activities for heavy cesium contamination.

1395 Thus, Sandia determined that decontamination cost values for 1396 moderate plutonium contamination are comparable to those for 1397 heavy cesium contamination.

1398 Q: What is ISR

's response to this conclusion?

1399 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 67 A: NRC Staff and Sandia rely heavily on the cost of 1400 decontamination of a road to estimate the costs of 1401 decontamination of buildings, houses, soil and vegetation in 1402 urban areas. A review of the literature does not support this 1403 extrapolation. Our review of the literature shows that cesium is 1404 more difficult to remove from porous surfaces like concrete than 1405 plutonium.

1406 The concern for plutonium resuspension is due to the fact 1407 that it initially does not bind to surfaces because plutonium 1408 oxide is not readily soluble. This property also makes it 1409 initially easy to remove. Over time plutonium settles into the 1410 surface and resuspension becomes less significant.

1411 Data on plutonium resuspension shows that the initial 1412 inhalation health hazard goes down by a factor 10,000 over a few 1413 decades. After 30 years, the resuspension coefficient becomes 1414 negligible and the long term health hazard from plutonium is 1415 much less than for other radionuclides. Long-term control of 1416 contamination would likely be based on similar consideration for 1417 plutonium and cesium.

1418 A severe reactor accident will result in contamination 1419 containing fission products (cesium and other radionuclides) and 1420 actinides (plutonium). The choice of decontamination techniques 1421 will be based on an analysis of the exposure pathways for all 1422 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 68 these radionuclides. In some locations, the hazard from 1423 plutonium could be the driving factor while in other places the 1424 hazard from cesium could dominate. Any effective decontamination 1425 technique will result in some removal of cesium, plutonium and 1426 any other radionuclides. Therefore, using the example of road 1427 decontamination presented by Sandia, if complete removal of the 1428 road is justified for plutonium, it will also result in the full 1429 decontamination of cesium.

1430 Q: Lastly , let's discuss p age G-24, lines 20

- 26. What 1431 is NRC Staff discussing here?

1432 A: NRC Staff uses the Site Restoration value of $178.4 1433 million/km 2 for clean-up of moderate plutonium contamination in 1434 urban areas and divides that value by the population density of 1435 NYC to arrive at a cost of $14,900 per person. NRC Staff then 1436 compares this value to Entergy's MACCS2 input of

$13,824 per 1437 person for decontamination of heavy cesium contamination. NRC 1438 Staff concludes that the decontamination cost from Site 1439 Restoration "is not significantly different than the value used 1440 by Entergy in the SAMA analysis

." 1441 Q: What is ISR's response to this NRC Staff comment

? 1442 A: NRC Staff's analysis ignore s the fact that NYC has a 1443 much higher building density than Albuquerque, the city upon 1444 which the Site Restoration cost figures are based. One cannot 1445 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 69 simply divide the Site Restoration decontamination cost per km 2 1446 by population density to arrive at an accurate cost figure. By 1447 doing just that, NRC Staff has assumed that a cleanup of the 1448 same size contaminated area in Albuquerque would be the same as 1449 a contaminated area in New York City. This is simply not true.

1450 For a city such as NYC, building density must be taken into 1451 account. Survey of Costs proposed that the ratio of population 1452 densities of New York City to Albuquerque, the city upon which 1453 the Site Restoration data is based, be used to take building 1454 density in account. Since Entergy has questioned this 1455 assumption, ISR has found a better way to account for building 1456 density. As I explained when describing ISR's approach A for 1457 calculating decontamination costs, ISR used census values of 1458 building densities in Albuquerque and NYC to adjust the Site 1459 Restoration data. Using ISR's approach A, this leads to a cost 1460 of heavy decontamination between $449,000 and $898,000 per 1461 person. 1462 X.

SUMMARY

OF ISR'S CONCLUSIONS REGARDING ENTERGY'S ANALYSIS 1463 AND NRC STAFF'S DISCUSSION OF THE COSTS RELATED TO A SEVERE 1464 ACCIDENT AT IP 1465 Q: Dr. Lemay, after reviewing and responding to Entergy's 1466 calculation of the economic costs associated with a severe 1467 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 70 accident and the NRC Staff's comments, what conclusions did ISR 1468 ultimately reach?

1469 A: ISR concludes that Entergy's input parameters to the 1470 MACCS2 code, which were accepted by NRC Staff, underestimated 1471 the total economic cost of a severe nuclear accident primarily 1472 because of the direct use of MACCS2 Sample Problem A input 1473 values for the CHRONC module. The underestimation was mostly 1474 due to costs and times for decontamination that were unrealistic 1475 given current known decontamination data and the complexities of 1476 an urban to hyper-urban area such as that surrounding IP.

1477 Q: Has ISR derived a more appropriate range of values for 1478 the MACCS2 input parameters?

1479 A: Yes. ISR has derived more appropriate values and 1480 calculated the effect on the MACCS2 output. A summary of the 1481 ISR-proposed range of inputs and calculated OECR for all of the 1482 sensitive parameters is provided in Table 13, reproduced below.

1483 For all cases, only a single input parameter is varied, keeping 1484 all others as determined by Entergy.

1485 1486 1487 1488 1489 Pre-filed Written Testimony of François J. Lemay Consolidated Contention NYS-12-C 71 Table 13: Summary of ISR proposed inputs an d calculated OECRs (costs in 2005 USD) 1490 Parameter Description Entergy's value ISR's proposed input value ISR's calculated OECR ($/yr) and ratio a Minimum Maximum Minimum Maximum CDNFRM (DF=3) Per capita cost of nonfarm light decontamination $5,184 $19,000 $272,000 4.21E+05 (1.99) 1.25E+06 (5.88) CDNFRM (DF=15) Per capita cost of nonfarm heavy decontamination $13,824 $90,000 $898,000 TIMDEC (DF=3) Time required for light decontamination 60 d 2 y 15 y 6.44E+05 (3.04) 1.20E+06 (5.66) TIMDEC (DF=15) Time required for heavy decontamination 120 d 4 y 30 y VALWNF Per capita value of nonfarm wealth (2004 USD) $208,838 $284,189 2.51E+05 (1.18) DPRATE Depreciation rate 20% 20% 2.12E+05 (1.00) DSRATE Societal discount rate for property 12% 5% 7% 1.87E+05 (0.88) 1.95E+05 (0.92) POPCST Per capita cost of long-term relocation $8,640 $10,640 $49,857 2.23E+05 (1.05) 4.41E+05 (2.08) FRNFIM Nonfarm wealth improvements fraction 80% 90% 2.19E+05 (1.03) Using all of ISR's proposed input values 9.07E+05 (4.28) 1.47E+06 (6.96) Notes: a The ratio shown in brackets is the ratio of the ISR-calculated OECR to the Entergy-calculated OECR ($2.12E+05/yr).

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

1493 A: The OECR is determined to be between 4 and 7 times the 1494 currently calculated Entergy value of $212,000/year.

1495 Q. Does this conclude your testimony?

1496 A. Yes. 1497 1498 1499