ML14251A068

NRR E-mail Capture - Pilgrim Watchs September 3, 2014 Supplement to ITS August 30, 2013 2.206 Petition; Kld Pilgrim Population Update Report 2014 Rev 0 Draft October 16, 2014

ML14251A068
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Site:	Pilgrim
Issue date:	09/03/2014
From:	Lampert M - No Known Affiliation
To:	Office of Nuclear Reactor Regulation
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1 NRR-PMDAPEm Resource From:

Mary Lampert [mary.lampert@comcast.net]

Sent:

Wednesday, September 03, 2014 4:36 PM To:

NRCExecSec Resource Cc:

Morgan, Nadiyah

Subject:

PILGRIM WATCH'S SEPTEMBER 3, 2014 SUPPLEMENT TO ITS AUGUST 30, 2013 2.206 PETITION; KLD PILGRIM POPULATION UPDATE REPORT 2014 REV 0 DRAFT OCTOBER 16, 2014 Attachments:

PILGRIM WATCH SUPPLEMENT TO ITS AUGUST 30, 2013 2.206 PETITION 09.03.14.pdf; KLD_Pilgrim_Population_Update_Report_2014_Rev0_Draft.pdf Hello:

Attached please find two documents.

• Pilgrim Watchs September 3, 2014 Supplement To Its August 30, 2013 2.206 Petition To Modify, Suspend, Or Take Any Other Action To The Operating License Of Pilgrim Station Until The NRC Can Assure Emergency Preparedness Plans Are In Place To Provide Reasonable Assurance Public Health & Safety Are Protected In The Event Of A Radiological Emergency -Pilgrim Nuclear Power Stations Annual Population Update - 2014

• KLD Pilgrim Population Update Report 2014 Rev 0, Draft, October 16, 2014 If you have any difficulty in downloading the documents, please call Mary Lampert at 781-934-0389.

A courtesy of receipt by return email will be appreciated.

Thank you for your attention and enjoy your evening.

Mary

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PILGRIM WATCH'S SEPTEMBER 3, 2014 SUPPLEMENT TO ITS AUGUST 30, 2013 2.206 PETITION; KLD PILGRIM POPULATION UPDATE REPORT 2014 REV 0 DRAFT OCTOBER 16, 2014 Sent Date:

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lampert@comcast.net Files Size Date & Time MESSAGE 805 9/3/2014 4:36:22 PM PILGRIM WATCH SUPPLEMENT TO ITS AUGUST 30, 2013 2.206 PETITION 09.03.14.pdf 377416 KLD_Pilgrim_Population_Update_Report_2014_Rev0_Draft.pdf 992865 Options Priority:

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September 3, 2014 Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 By Email: NrcExecSec@nrc.gov PILGRIM WATCHS SEPTEMBER 3, 2014 SUPPLEMENT TO ITS AUGUST 30, 2013 2.206 PETITION TO MODIFY, SUSPEND, OR TAKE ANY OTHER ACTION TO THE OPERATING LICENSE OF PILGRIM STATION UNTIL THE NRC CAN ASSURE EMERGENCY PREPAREDNESS PLANS ARE IN PLACE TO PROVIDE REASONABLE ASSURANCE PUBLIC HEALTH & SAFETY ARE PROTECTED IN THE EVENT OF A RADIOLOGICAL EMERGENCY PILGRIM NUCLEAR POWER STATIONS ANNUAL POPULATION UPDATE - 2014 I.

INTRODUCTION Pursuant to §2.206 of Title 10 in the Code of Federal Regulations, Pilgrim Watch (Hereinafter PW) on behalf of its members and members of the Town of Duxbury Nuclear Advisory Committee, Pilgrim Coalition, Project for Entergy Accountability, Cape Cod Bay Watch, EcoLaw, Beyond Nuclear, Greenpeace, and others submits this supplement to its request that the Nuclear Regulatory Commission (NRC) institutes a proceeding to modify, suspend or take any other action1 as may be proper to the operating license of Pilgrim Station in order that the NRC can assure Pilgrims Radiological Emergency Plan and Standard Operating Procedures/Guidelines are based on accurate and credible Evacuation Time Estimates (ETEs).

The new and significant information petitioners add to the KLD petition is based on the October 16, 2014 Pilgrim Nuclear Power Station 2014 Population Update Analysis Draft 1 NRC Enforcement actions include: notices of violation, civil penalties, orders, notice of nonconformance, confirmatory action letters, letters of reprimand, and demand for action.

2 Report, Rev., KLD-TR-659. The data is essentially the same as in the July 31, 2014 MEMO from KLD, Kevin Weinisch, Regarding Pilgrim Nuclear Power Station Annual Update-2014 analyzed in Pilgrim Watchs August 11, 2014 KLD Supplement. The 2014 Population Update shows updated population figures that indicate an insignificant change in population. As predicted in Pilgrim Watchs August 11 Supplement, the updated 2014 report followed the same flawed format, methodology and assumptions, used in the KLD Pilgrim Evacuation Estimate December 12, 2012 Final Report KLD-TR-510 and its 2013 Pilgrim Nuclear Power Station Annual Population Update, 2013 that significantly underestimated evacuation time estimates.

Whats wrong with KLDs update analyses? The 2014 update, like its predecessor, failed to learn two fundamental lessons from KLDs Cape Cod Telephone Survey.

First, as previously explained, the 2014 update used KLDs ridiculously low assumption that only 20% of the shadow evacuation would evacuate. The Cape Cod Telephone Survey shows that the actual number who would choose to evacuate is between 50% and 70%, at the 95% confidence level2. Second, the Cape Telephone Survey also showed that the shadow evacuation extends to 25 miles not 15 miles, as assumed by KLD3.

Section IV of Appendix E to 10 CFR part 50 and Section 5.4, Reviews and Updates of NUREG/CR-7002 says that:

2 Pilgrim Watch August 30, 2013 filing in this proceeding fully discussed the KLD Cape Telephone Survey and the KLD telephone survey in the EPZ and its 15 mile shadow It showed that if telephone survey respondents were told that the questions regarded a radiological incident, and not simply an unspecified incident like the Sandias and the EPZ survey, far more respondents said they would evacuate. This is expected because the public fears radiation the most, especially so since Fukushima.

3 Distance: Cape Cod extends only to 25 miles from Pilgrim Station; therefore the Cape Telephone Survey was limited to 25 miles. If the Cape extended further than 25 miles from Pilgrim, it is likely that the Telephone Survey would show the shadow evacuation extends beyond 25 miles and an added percent beyond 25 miles would chose to evacuate.

3 If at any time during the decennial period, the EPZ permanent resident population increases such that it causes the longest ETE value for the 2-mile zone or 5-mile zone, including all affected Emergency Response Planning Areas, or for the entire 10-mile EPZ to increase by 25 percent or 30 minutes, whichever is less, from the nuclear power reactor licensee's currently NRC approved or updated ETE, the licensee shall update the ETE analysis to reflect the impact of that population increase. The licensee shall submit the updated ETE analysis to the NRC under § 50.4 no later than 365 days after the licensee's determination that the criteria for updating the ETE have been met and at least 180 days before using it to form protective action recommendations and providing it to State and local governmental authorities for use in developing offsite protective action strategies.

If the shadow evacuation estimate were correctly to assume either (i) that 50% to 70% of the shadow population would try to evacuate, or (ii) that the actual shadow evacuation zone would extend to 25 miles then the increase in the number of evacuees will increase KLDs base line ETE analysis by more than 30 minutes and an updated ETE for Pilgrim Station will be required.

II.

DOCUMENTS PETITIONERS RELY UPON

 Pilgrim Nuclear Power Station 2014 Population Update Analysis Draft Report, Rev,

KLD-TR-659, October 16, 2014

 MEMO from KLD, Kevin Weinisch, Regarding Pilgrim Nuclear Power Station Annual Update-2014, July 31, 2014

 KLD Pilgrim Nuclear Power Station Annual Population Update - 2013, September 25, 2013

 KLD Pilgrim Evacuation Estimate December 12, 2012, Final Report KLD-TR-510014

 U.S. Census Bureau QuickFacts

 Pilgrim Watchs 2.206 Petition To Modify, Suspend, Or Take Any Other Action To The Operating License Of Pilgrim Station Until The NRC Can Assure Emergency Preparedness Plans Are In Place To Provide Reasonable Assurance Public Health And Safety Are Protected In The Event Of A Radiological Emergency, August 30, 2013

4

 Amendment And Supplement To Pilgrim Watchs 2.206 Petition To Modify, Suspend, Or Take Any Other Action To The Operating License Of Pilgrim Station Until The NRC Can Assure Emergency Preparedness Plans Are In Place To Provide Reasonable Assurance Public Health & Safety Are Protected In The Event Of A Radiological Emergency, November 22, 2013 III.

FACTUAL BASIS The following analysis is based on KLD Pilgrim Nuclear Power Station Annual Population Update - 2014, October 16, 2014.

1.

The ETE is the time required to evacuate the zone in question. The ETE depends on the number of evacuees, assumes that the entire zone is evacuated, and also assumes a 20% shadow evacuation of those in the 10-15 mile zone.

2.

Table 6. ETE Variation with Population Change shows that an updated ETE will be required if the number of evacuees increases by 25,258 from KLDs base assumption of 109,891 to 135,077. According to KLDs analysis, the-to-be evacuated population of the EPZ has increased by 2,409 from 2010s Census population. (2014 Update, Table 3, pg., 8) KLD determined that an increase in slightly more than 25,000 evacuees (23%) from the EPZ and its shadow region would increase the full EPZ 90th Percentile ETE by 30 minutes. Obviously, a larger increase in the number of evacuees would result in even longer ETEs.

5 2014 Update, pg., 12

3.

In the 2014 Population Update Analysis, the only increases in the number of evacuees that KLD considered were those resulting from increases in the populations of the EPZ and the 10-15 mile shadow region. The total number of evacuees, and the ETE, are critically dependent on the percentage of those in the shadow region that will choose to evacuate.

4.

Table 4 Shadow Population by Sector (2014 Update, pg., 8) shows KLDs estimate of the population of the shadow region, within 15 miles of Pilgrim. Its ETE estimate assumed that only 20% (16,124) of the 2014 Extrapolated Population (80,619) would choose to evacuate. It also unrealistically assumed that no one more than 15 miles from Pilgrim would evacuate.

6 Pilgrim 2014 Update, pg., 8

5.

The recent KLD Cape Cod Telephone Survey (discussed at length in Pilgrim Watchs August 30, 2013 2.206 Petition pending before the NRC, pages 5-13; and Pilgrim Watchs Supplements) showed that the 20% assumption is ridiculously low, and that the actual number of people in the shadow region who would choose to evacuate, at the 95% confidence level, is between 50% and 70%. Seventy (70) percent of those within 25 miles said they would evacuate if they were told that there was an incident at the Pilgrim Nuclear Power Station; and fifty (50) percent of those within 25 miles of Pilgrim would evacuate, even if they were told that they were not in Pilgrims Emergency Planning Zone. KLDs Cape Telephone Survey unequivocally showed that ETEs shadow evacuation assumption is fatally wrong. In both events, far more than 20% of those in the shadow region will voluntarily evacuate.

6.

The recent Cape Cod Telephone Survey showed that actual number of evacuees from the 10-15 mile shadow zone would be far more than the 16,077 estimated by KLD.

7

 70% of the 2014 Extrapolated Population (80,619) yields 56,433 evacuees that said they would evacuate if there was an incident at Pilgrim. That number is 40,399 more evacuees than KLD assumed.

 50% of the 2014 Extrapolated Population (80,619) yields 40,085 evacuees that said they would evacuate even if told they were not in the EPZ; this is 24,051 more shadow region evacuees than KLD assumed.

Taking only the more conservative 50% (24,051 more shadow region evacuees than KLD assumed), the increased number of evacuees from both the EPZ and the shadow region (2,409 +

24,051) is more than the 25,258 additional evacuees that KLD admitted would require an updated ETE. Splitting the difference between the 50% and 70% in the Cape Telephone Survey responses, if 60% (48,371) of those in the 10-15 mile zone chose to evacuate, the additional number of evacuees (32,332 evacuees) from the shadow region alone would be well over KLDs 25,258 number requiring an update, If 70% choose to evacuate, the number of evacuees would clearly require an update.

% of estimated 2014 Shadow Population, (80,619)

Added Evacuees Updated ETE Required If population exceeds 25,258 20% = 16,034 0

No 50% = 40,085 24,051 Close 60% = 48,371 32,332 Yes 70% = 56,433 40,399 Yes Sources: Table 4 Estimated 2013 shadow population = 80,387; Table 6: updated ETE required if evacuees increases by 25,258

8

7.

Shadow Region out to 25 miles: KLDs Cape Cod Telephone Survey4 also showed that the ETEs assumption that there would be shadow evacuation only from the 10-15 mile region is incorrect. The Cape survey showed that 50% to 70% of the respondents throughout the Cape, out to 25 miles, would choose to evacuate. The number of evacuees simply from outside the official 15 mile shadow region would also be well over the 25,258 more required for an ETE.

Any realistic ETE must take into account a shadow region that extends out to at least 25 miles.

If either (a) less than 6% of the ignored population of the 15-25 mile shadow region or (b) as little as 4% of the total 10-25 mile shadow region, chose to evacuate, the total number of evacuees would increase by more than the 22,258 that KLD admits requires a new ETE analysis.

a. The 15-25 mile shadow region KLDs analysis ignored more than 625,000 people who live in the 15-25 mile shadow evacuation region.

Barnstable Countys 2010 permanent population5 was 215,888; and the 2013 permanent population is 214,990. (U.S. Census QuickFacts) The KLD Population Estimate included two towns (Bourne and Sandwich) in Barnstable County (Table 1) with a total population of 40,468, in its 10-15 mile Shadow Region. Subtracting the population of those already counted two towns, the ignored population of what should be the Barnstable County Shadow Region is 174,522, not counting an additional 300,000 summer visitors and workers who reside outside Barnstable County.

4 The Cape Survey was restricted to respondents from 10-25 miles, not beyond 25 miles. Also the survey was restricted to permanent residents. Pilgrim Watch showed that summer visitors, numbering over 300,000, were more likely to evacuate than permanent residents. (Pilgrim Watchs August 30, 2013 Petition, pg., 14, section b) 5 The census provides permanent population numbers; the summer population approximately doubles the Cape population. If NRC were to insist on a conservative estimate, it would base the population on the largest population, summer.

9 Plymouth Countys 2010 population was 494,919 and the estimated 2013 population is 501,915. (U.S. Census QuickFacts) The KLD Population Estimate included 10 towns in its 10-15 mile Shadow Region with a total population of 109,819 (Table 6). Subtracting the population of those ten already counted towns, the population of the towns within the 25-mile Plymouth County Shadow Region that was ignored is 392,096. There are two Norfolk County towns within the 25 mile radius, Cohasset (pop., 7,483) and Weymouth (pop., 54,565), that were ignored. This total ignored shadow evacuation population is 454,144, again omitting a sizable summer visitor population and worker population that resides outside EPZ.

If only 20% of this added Barnstable County permanent population decided to evacuate, there would be 34,904 more evacuees. If 50%, 60%, or 70% decided to evacuate the number of additional evacuees would be respectively 87,261, 104,713 and 122,165. In each case the number of evacuees would far exceed the 25,248 that the KLD Update admits would require an updated ETE.

If the over 300,000 summer visitor population and workers residing outside the country were added the number of evacuees would exceed 3,87,261, if 50% chose to evacuate; 404,713, if 60% chose to evacuate; and over 422,165 if 70% chose to evacuate. Research shows that visitors are more likely to evacuate than permanent residents.6 If only 20% of this nearly half-million Plymouth County and two Norfolk County town permanent populations, (all within 25 miles) decided to evacuate, there would be 90,828 more 6 New Jersey Hurricane Evacuation Study Transportation Analysis, Technical Memoranda, Prepared for US Army Corps of Engineers Philadelphia District, by PBS&J Tallahassee FLA, June 2007 (http://www.ready.nj.gov/plan/pdf/maps/hurrevacution_study.pdf) (Discussed in PWs 2.206 Petition, August 30, 201, pg., 14)

10 evacuees. If 50%, 60%, or 70% decided to evacuate the number of additional evacuees would be respectively 227,072, 272,486, and 317,901.

In each case, the number of evacuees would far exceed the 25,248 that KLD 2014 admits would require an updated ETE.

b. The 10-25 mile shadow region Barnstable and Plymouth Shadow Evacuation Regions to 25 Miles: The total permanent population of the 25-mile Barnstable County 2013 Shadow Region on one side of Pilgrim is 214,990; the total permanent population of the 25-mile Plymouth County and two Norfolk County towns 2013 Shadow Region is 501,915. The total shadow population of permanent residents would be 716,905 -almost nine times the 80,619 estimated by KLD (Table 4).

If only 4% of this shadow population of simply permanent residents out to 25 miles chose to evacuate, there would be 28,676 more evacuees than KLD estimated, exceeding the 25,258 number that KLD admits requires an ETE update; if 20% (KLDs assumed percentage) were to evacuate, there would be more than 143,000 more evacuees, more than five times what KLD admits requires an update.

The overall picture emphasizes the total inadequacy of KLDs estimates. In an effort to produce ETEs that the NRC might find acceptable, KLD chose to deal with a population of less than 175,000, the EPZ population plus the 10-15 mile shadow region population, and to ignore 80% of the latter What are the 625,000 people that KLD says will not even try to evacuate supposed to do?

What are summer visitors and workers who reside outside the area supposed to do?

11

8.

Incorrect Methodology & Assumptions: The KLD Population Update further underestimates the population demand, the total number of people evacuating, by using the incorrect methodology and making the same inaccurate assumptions that were made in KLD Pilgrim Evacuation Estimate December 12, 2012 Final Report KLD-TR-510014 (discussed in Pilgrim Watchs August 30, 2013 petition); and in KLD Pilgrim Nuclear Power Station Annual Population Update - 2013, September 25, 2013 (discussed in Pilgrim Watchs August 11, 2014 KLD Supplement).

a. Methodology: Population Update 2014 and 2013 Only Looked At Undifferentiated Permanent Population Data The Update should have looked at increases in population sub-groups. The KLD Pilgrim Evacuation Estimate December 12, 2012 Final Report KLD-TR-510 looked at summer population, transient population, worker population, and the transportation dependent-school children and residents of nursing/ group homes. By doing so, KLD acknowledged that these sub groups are important to consider in estimating evacuation times7.

b. KLDs Population Update 2014, Like its 2013 predecessor and the ETE, Incorrectly Assumes That The Longest 90 Percentile is Scenario 8: Winter, Mid-Day, Mid-Week, Snow Regulations require that an updated ETE must be conducted if population growth is large enough to cause the 90 percentile ETE to increase by 25% or 30 minutes. In order for the Population Update to be valid it must correctly assess the longest scenario. It did not do so.

Pilgrim Watch and Petitioners showed in the on-going 2.206 Enforcement Petition that the ETE underestimated traffic flow. It failed to account for chronically heavy traffic over summer 7 Note that Pilgrim Watchs August 2013 filing showed that KLDs ETE did not properly estimate the numbers and times required to evacuate different sub-groups.

12 weekends that significantly increases travel times; and it underestimated traffic flow during inclement weather. The impact of snow is greatest during peak commuting hours that KLD never studied. Peak Traffic Scenarios must be recalculated to satisfy the requirement.

c. KLDs Population Update 2014, and its 2013 predecessor, models the 2-mile zone or 5-mile zone, including all affected Emergency Response Planning area and the entire EPZ.

This conforms to Section IV of Appendix E to 10 CFR part 50 and Section 5.4, Reviews and Updates of NUREG/CR-7002 but it does not conform to reality. The Cape Telephone Survey showed that 50% of the respondents said that they would evacuate anyway even if told that they were not in the EPZ. Therefore it shows that the segmented evacuation will never be followed inside the EPZ, far more than 20% will choose to voluntarily evacuate outside the 2-mile or 5-mile area. Additionally at the Alert Stage of the accident beaches, parks, forests are closed and boaters are told to get off the water. The word of trouble at Pilgrim will rapidly spread due to todays rapid communication capability and an unplanned evacuation will begin.

Unplanned evacuations mean an increase in vehicle accidents that will clog the routes when the actual evacuation is called, increasing evacuation times.

IV.

CONCLUSION Faulty assumptions and methodology in the KLD Pilgrim Evacuation Estimate December 12, 2012 Final Report KLD-TR-510014 were carried forward in KLD Pilgrim Nuclear Power Station Annual Population Update - 2014 and 2013. The result is KLD documents that are not credible.

There will be much higher levels of congestion, and much longer evacuation times, as our filings

13 in this proceeding showed. Absent an honest and credible ETE, the population does not have reasonable assurance of adequate proptection in the event of an accident. It is time to do better.

Pilgrim should not be operating until a new Population Update and ETE is done. Indeed an updated ETE analysis must be prepared if the EPZ resident population increases such that it causes the 90th percentile ETE for either the 2-mile zone, the 5-mile zone or the entire 10-mile EPZ to increase by 25% or 30 minutes, whichever is less. (Section IV of Appendix E to 10 CFR part 50 and Section 5.4, Reviews and Updates of NUREG/CR-7002). Pilgrim Watch has shown that based on KLDs own Cape Telephone Survey that the EPZ resident population and shadow evacuation exceeds the population number requiring a new study. Properly adding the summer population would further escalate the population figures.

As we concluded in our original August 2013 KLD petition, Judge Rosenthal of the ASLB accurately said that, with one possible exception, the NRC had not granted a section 2.206 petitioner the substantive relief it sought for at least 37 years. Judge Rosenthal concluded that, where truly substantive relief is being sought (i.e., some affirmative administrative action taken with respect to the licensee or license), there should be no room for a belief on the requesters part that the pursuit of such a course is either being encouraged by Commission officialdom or has a fair chance of success."8 Again, we truly hope that Judge Rosenthal will be proven wrong and this petition will be granted.

8 Memorandum And Order (Denying Petitions For Hearing), LBP-12-14, July 10, 2012, Additional Comments of Judge Rosenthal ( See NRCs EHD Docket EA-12-05-/12-51)

14 Respectfully submitted on behalf of the Petitioners, Mary Lampert Pilgrim Watch, Director 148 Washington Street Duxbury, MA 02332 Tel 781-934-0389 Email: mary.lampert@comcast.net September 3, 2014

October16,2014

DraftReport,Rev0

KLDTR-659







PilgrimNuclearPowerStation



2014PopulationUpdateAnalysis





WorkperformedforEntergy,by:





KLDEngineering,P.C.

1601VeteransMemorialHighway,Suite340

Islandia,NY11749

mailto:kweinisch@kldcompanies.com



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ExecutiveSummary

Federalregulations(SectionIVofAppendixEto10CFRpart50)requirenuclearpowerplantlicenseesto

estimatethepermanentresidentpopulationwiththeEmergencyPlanningZone(EPZ)oftheplantat

leastannuallyduringtheyearsbetweendecennialcensuses.Ifthepopulationincreasessuchthatthe

Evacuation Time Estimate (ETE) for the 2mile region, 5mile region or entire EPZ increases by 25

percentor30minutes,whicheverisless,afullETEupdateisrequired.BasedonU.S.CensusBureau

data,thepopulationwithinthe2mileregion,5mileregionandentireEPZforthePilgrimNuclearPower

Station(PNPS)hasincreasedby3.1%,3.2%and2.6%,respectively,sincethe2010Census.Basedonthe

populationsensitivitystudydocumentedinthe2012ETEreport,greaterthan23%populationgrowthis

neededtoincreaseETEby30minutesormore.Assuch,thepopulationwithintheEPZhasnotgrown

enoughatthistimetotriggerafullETEupdate.

Introduction

SectionIVofAppendixEto10CFRpart50andSection5.4,ReviewsandUpdatesofNUREG/CR7002

stipulate:

LicenseesshallestimateEPZpermanentresidentpopulationchangesatleastannuallyduring

theyearsbetweendecennialcensusesusingU.S.CensusBureaudata.Theseestimatesshall

occurnomorethan365daysapart.State/localgovernmentpopulationdatamayalsobeused,if

available. Licensees shall maintain these estimates available for NRC inspection during the

periodbetweencensusesandshallsubmittheseestimatestotheNRCwithanyupdatedETEs.

Ifatany timeduringthedecennial period,the EPZpermanentresidentpopulationincreases

such that it causes the longest ETE value for the 2mile zone or 5mile zone, including all

affectedEmergencyResponsePlanningAreas,orfortheentire10mileEPZtoincreaseby25

percentor30minutes,whicheverisless,fromthenuclearpowerreactorlicensee'scurrently

NRCapprovedorupdatedETE,thelicenseeshallupdatetheETEanalysistoreflecttheimpactof

thatpopulationincrease.ThelicenseeshallsubmittheupdatedETEanalysistotheNRCunder§

50.4nolaterthan365daysafterthelicensee'sdeterminationthatthecriteriaforupdatingthe

ETE have been met and at least 180 days before using it to form protective action

recommendations and providing it to State and local governmental authorities for use in

developingoffsiteprotectiveactionstrategies.



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Entergy has contracted KLD Engineering, P.C. to estimate annual population changes between the

decennialcensusesforthePNPSinaccordancewiththeaforementionedfederalregulations.Entergy

and the offsite response organizations (OROs) - the Massachusetts Emergency Management Agency

(MEMA),andtheTownsofCarver,Duxbury,Kingston,MarshfieldandPlymouth-havereviewedand

approvedthemethodologyandCensusgrowthratesprovidedbelow.

USCensusGrowthRates

The population analysis for the 2012 PNPS ETE was performed using 2010 Census population data

providedontheU.S.CensusBureauwebsite1.TheCensusBureauQuickFacts2websiteprovidesannual

updatesofpopulationdataforeachstate,county,minorcivildivision(town)3andmunicipalityinthe

UnitedStates.ThemostrecentupdatefortowngrowthratesavailableontheQuickFactswebsiteisfor

thetimeperiodfromApril1,2010toJuly1,2013.Thegrowthratesforeachtownwithinthestudyarea

(EPZplustheShadowRegion)providedbyQuickFactsaresummarizedinTable1.TheCensusdoesnot

provideannualpopulationestimatesfortheCensusDesignatedPlaces(CDPs-e.g.,NorthPlymouth,

etc.)withinthestudyarea.TheCensusboundariesforalltownswithinthestudyareaareshownin

Figure1.





1www.census.gov

2http://quickfacts.census.gov/qfd/index.html

3http://www.census.gov/popest/data/cities/totals/2013/SUBEST20134.html



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Table1.TownPopulationChangefromApril1,2010toJuly1,2013

Town

2010

Population

2013

Population

Percent

Change

BarnstableCounty,MA

ShadowRegion

Bourne

19,754

19,733

0.11%

Sandwich

20,675

20,589

0.42%

PlymouthCounty,MA

EPZ

Carver

11,509

11,494

0.13%

Duxbury

15,059

15,288

1.52%

Kingston

12,629

12,819

1.50%

Marshfield

25,132

25,509

1.50%

Plymouth

56,468

57,826

2.40%

ShadowRegion

Halifax

7,518

7,606

1.17%

Hanson

10,209

10,324

1.13%

Middleborough

23,116

23,601

2.10%

Pembroke

17,837

18,097

1.46%

Plympton

2,820

2,859

1.38%

Rochester

5,232

5,381

2.85%

Wareham

21,822

22,384

2.58%





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Figure1.CensusBoundarieswithinthePNPSStudyArea



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Methodology

The compound growth formula (Equation 1) was used for all population projections, where g is the

annualgrowthrateandXisthenumberofyearsprojectedforwardfromYear2010.Thecompound

growthformulacanbesolvedforgasshowninEquation2.ThedataprovidedinTable1wasusedin

Equation2tocomputetheannualgrowthrateforeachtowninthestudyareausingX=3.25(3years

and3monthsfromApril1,2010toJuly1,2013).Thecomputedannualgrowthratesforeachtownare

summarizedinTable2.

Equation1.CompoundGrowthRate



 

















 

!"

Equation2.AnnualGrowthRate

#$!







! 













(



Table2.AnnualGrowthRatebyTown

Town

AnnualGrowth

Rate

BarnstableCounty,MA

ShadowRegion

Bourne

0.03%

Sandwich

0.13%

PlymouthCounty,MA

EPZ

Carver

0.04%

Duxbury

0.47%

Kingston

0.46%

Marshfield

0.46%

Plymouth

0.73%

ShadowRegion

Halifax

0.36%

Hanson

0.35%

Middleborough

0.64%

Pembroke

0.45%

Plympton

0.42%

Rochester

0.87%

Wareham

0.79%







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Themostdetaileddatashouldalwaysbeusedwhenforecastingpopulation.Intermsofdetaileddata,

municipaldataisthefinestlevelofdetail,thentowndata,countydata,andstatedata.Asshownin

Figure 1, there are no incorporated municipalities within the study area. Town growth rates are

availablefortheentirestudyareaandwereusedastheyarethefinestlevelofdetailavailable.Thus,

countyandstatedatawerenotused.

UsingGeographicalInformationSystems(GIS)mappingsoftware,theappropriateannualgrowthrate

wasappliedtoeachCensusblockinthestudyareadependingonwhichtowntheblockislocatedwithin.

ThepopulationwasprojectedtoSeptember1,2014forthisupdateusingEquation1withX=4.42(4

yearsand5monthsfromtheApril1,2010CensusdatetoSeptember1,2014).

Results

Thesubareaswhichcomprisetheapproximate10mileEPZforthePNPSareshowninFigure2.Table3

presentsthe2010permanentresidentpopulation4andestimatedpermanentresidentpopulationfor

2014foreachsubarea,fortheEPZasawhole,andalsoforthe2and5mileregions.Table4presents

theestimatedpermanentresidentpopulationfor2014forthePNPSShadowRegion,whichextends15

milesradiallyfromthePNPS.Figure3andFigure4presenttheestimated2014EPZandShadowRegion

permanent resident population, respectively, by sector and distance from the PNPS site. These

populationroseswereconstructedusingGISsoftware.

Notethatthe2MileRegionand5MileRegiondonotconformexactlytothe2mileand5mileradiidue

totheirregularshapeoftheSubareas;seeFigure2.Thus,the2mileand5milepopulationsshownin

Figure3donotexactlymatchthe2MileRegionand5MileRegiontotalsinTable3.

Equation3 wasusedto compute thepercent changeinpopulationfrom2010to2014.The percent

changeinpopulationforthevariousregionsofinterestissummarizedinTable5.



4Asperfederalregulations,onlythepermanentresidentpopulationneedstobeconsideredintheannual

updates;transientandspecialfacilitypopulationsarenotconsidered.



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Figure2.SubareasComprisingthePNPSEPZ



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Table3.EPZPopulation

Subarea

2010Census

Population

2014Extrapolated

Population

1

3,710

3,826

12





2MileRegionTotal:

3,710

3,826

2

8,985

9,278

3

10,946

11,297

4

17

17

5MileRegionTotal:

23,658

24,418

5

15,546

16,039

6

8,305

8,576

7

8,959

9,253

8

12,629

12,881

9

15,059

15,358

10

2,329

2,376

11

7,479

7,472

EPZTotal:

93,964

96,373



Table4.ShadowPopulationbySector

Sector

2010Census

Population

2014Extrapolated

Population

N

0

0

NNE

0

0

NE

0

0

ENE

0

0

E

0

0

ESE

0

0

SE

0

0

SSE

6,756

6,745

S

9,469

9,473

SSW

12,363

12,766

SW

3,968

4,074

WSW

4,928

4,981

W

4,741

4,835

WNW

12,639

12,856

NW

10,158

10,362

NNW

14,255

14,527

Total

79,277

80,619





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Figure3.PermanentEPZResidentPopulationbySector



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Figure4.ShadowPopulationbySector



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Equation3.PercentPopulationChange

)



• !  +

, 







 )



Table5.SummaryofPercentPopulationChanges

Region

Percent

PopulationChange

(20102014)

2MileRegion

3.1%

5MileRegion

3.2%

EPZ

2.6%

ShadowRegion

1.7%

EPZ+ShadowRegion

2.2%



AsdocumentedintheNRCsresponsetotheEmergencyPlanningFrequentlyAskedQuestion(EPFAQ)

2013001, the licensee should consider the impact of a population increase on the longest 90th

percentileETEforthescenariosidentifiedinTable13ofNUREG/CR7002,withtwopossibleexceptions:

1.

Theroadwayimpactscenarioneednotbeconsideredbecausetheonlypurposeofthisscenario

istosupportthedevelopmentoftrafficcontrolplanning.

2.

Theneedtoincludethespecialeventscenariodependsonthefrequencyofthespecialevent

analyzed.Licenseesshouldconsiderusingthisscenarioifthespecialeventchosenisrepetitive

duringtheyear,suchasmultiplehomefootballorbaseballgames,andnotaonetimeevent

suchasaseasonalparade.

AsdocumentedinTable71,TimetoCleartheIndicatedAreaof90PercentoftheAffectedPopulation

in the PNPS ETE Report (KLD TR510, dated December 2012), the scenario with the longest 90th

percentileETEisScenario8-awinter,midweek,middayscenariowithsnow-anonspecialevent.

Table6isadaptedfromTableM3inAppendixMofthePNPSETEReportanddocumentsthepopulation

sensitivity study conducted for an evacuation under Scenario 8 conditions.  As discussed in the

introduction,federalregulationsstipulatethatanupdatedETEmustbeconductedifpopulationgrowth



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islargeenoughtocausethe90thpercentileETEtoincreaseby25percentor30minutes,whicheveris

less.ThosepopulationchangeswhichresultinanETEchangemeetingorexceedingthefederalcriteria

forafullETEupdatearehighlightedredinTable6

ComparingthepercentpopulationchangespresentedinTable5withthoseinTable6indicatesthat

populationhasnotgrownenoughtotriggeranETEupdate.Asdiscussedintheintroduction,annual

populationestimatesshallbemaintainedbylicenseesandmadeavailableforNRCinspectionbetween

censuses.ThisreportshouldbekeptonfileforNRCinspectorstoindicatethattheannualpopulation

analysisfor2014hasbeencompletedandthatanupdatedETEanalysisisnotwarrantedatthistime.

ThisreportneednotbesubmittedtotheNRCasanupdatedETEanalysishasnotbeentriggeredby

populationgrowth.



Table6.ETEVariationwithPopulationChange

Resident

Population+

20%Shadow

Population

Base

PopulationChange

10%

20%

23%

109,819

120,801

131,783

135,077

ETEfor90thPercentile

Region



Base

PopulationChange

10%

20%

23%

2MILE

2:55

2:55

3:00

3:00

5MILE

2:35

2:45

2:50

2:55

FULLEPZ

3:30

3:40

3:55

4:00

ETEfor100thPercentile

Region



Base

PopulationChange

10%

20%

26%

2MILE

6:00

6:00

6:00

6:00

5MILE

6:05

6:05

6:05

6:05

FULLEPZ

6:10

6:10

6:10

6:10