Report to Congressional Requesters

United States General Accounting Office

GAO

July 2001 NUCLEAR

REGULATION

Progress Made in

Emergency

Preparedness at

Indian Point 2, but

Additional

Improvements Needed

GAO-01-605
Page i GAO-01-605 Indian Point 2

Letter 1

Results in Brief 2

Background 4

Consolidated Edison Has Taken Actions to Resolve Emergency

Preparedness Weaknesses, but More Needs to Be Done 7

The Four Counties Strengthened Their Emergency Preparedness

Programs as a Result of the Lessons Learned From the February

2000 Event 11

Counties Suggest Better Communication Among NRC, FEMA, and

Nonstate Entities With a Major Role in Radiological Emergency

Preparedness 13

Conclusions 17

Recommendations for Executive Action 18

Agency Comments and Our Evaluation 19

Appendix I Indian Point 2 Steam Generator 22

Appendix II The Nuclear Regulatory Commission’s Emergency

Action Levels and Conditions That Could Cause

an Emergency 23

Appendix III Description of NRC’s New Safety Oversight Process

for Emergency Preparedness 24

Appendix IV Some Emergency Preparedness Issues Identified by

NRC’s Office of the Inspector General 27

Appendix V Emergency Preparedness Corrective Actions

Initiated by Consolidated Edison Since the

February 2000 Event 28

Contents
Page ii GAO-01-605 Indian Point 2

Appendix VI County Officials’ Suggestions to Improve

Radiological Emergency Preparedness and

NRC’s/FEMA’s Responses 29

Appendix VII Initiatives to Streamline FEMA’s Radiological

Emergency Preparedness Program and Their Status 32

Appendix VIII Comments From the Nuclear Regulatory Commission 35

Appendix IX Comments From the Federal Emergency Management

Agency 47

Appendix X Scope and Methodology 56

Tables

Table 1: Selected Emergency Preparedness Weaknesses That

Occurred During the February 2000 Event and the

Corrective Actions Taken by Consolidated Edison 9

Table 2: The Nuclear Regulatory Commission’s Emergency Action

Levels and Some Examples of Nuclear Power Plant

Conditions That Could Cause an Emergency 23

Table 3: Performance Indicator Data Through March 2001 25

Table 4: Suggestions Made by County Officials to Improve

Radiological Emergency Preparedness and NRC’s and

FEMA’s Responses 29

Table 5: FEMA’s Initiatives and Their Status 32

Figures

Figure 1: 10- and 50-Mile Emergency Planning Zones for Indian

Point 2 6
Page iii GAO-01-605 Indian Point 2

Figure 2: Comparison of the Relevant Section of the Radiological

Emergency Data Form During and After the Event 12

Figure 3: Indian Point 2 Steam Generator in Relation to Other Plant

Equipment and the Locations Where a Leak Could Release

Radioactive Material to the Environment 22

Abbreviations

FEMA Federal Emergency Management Agency

NRC Nuclear Regulatory Commission
Page 1 GAO-01-605 Indian Point 2

July 30, 2001

Congressional Requesters

In February 2000, Consolidated Edison Company shut down the Indian

Point 2 commercial nuclear power plant in New York State because a tube

had ruptured in a steam generator, raising the possibility that radioactively

contaminated water could leak into the environment.1

 In this particular

instance, the total amount of radioactivity released posed no threat: It was

about one thousandth of the dose an individual receives from a chest

X-ray. However, in the event of a more serious emergency at Indian Point

2, protecting the public from a radioactive release presents more

substantial challenges because the plant is located in a heavily populated

area. More than 280,000 people reside within 10 miles of the plant in four

counties; millions more live in New York City—about 25 miles distant—

and within 50 miles in Connecticut, New Jersey, New York, and

Pennsylvania. Other commercial nuclear power plants are generally

located in less-populated areas.

To protect the public if a commercial nuclear power plant accidentally

releases radiation to the environment, the responsible regulatory agency,

the Nuclear Regulatory Commission (NRC), requires the utility to prepare

and NRC to approve a radiological emergency preparedness plan. The

on-site plan describes what is to be done in an emergency, how it is to be

done, and who is to do it. Among other things, the plan identifies the

process for notifying and communicating with the utility’s own personnel

as well as with state, federal, and local agencies and the media during an

emergency. The plan also identifies the circumstances and actions, such as

providing shelter or evacuating the local population, the utility would

recommend that off-site officials take to protect the public. NRC conducts

inspections to ensure that the utility can effectively implement the on-site

plan.

 1

Steam generators are one of two major systems used to convert heat into electrical power

for industrial and residential use. Heat from the plant’s fuel is transferred through pipes to

the steam generator. The steam produced by the generator is transferred to the turbines,

where it is converted into electricity. App. I shows one of the four steam generators in

relation to other systems within a plant and the locations where a leak could release

radioactive material to the environment.

United States General Accounting Office

Washington, DC 20548
Page 2 GAO-01-605 Indian Point 2

In addition, the Federal Emergency Management Agency (FEMA) is

responsible for ensuring that state and local communities develop

emergency preparedness plans to address the off-site impacts of a nuclear

emergency. FEMA also oversees the conduct of periodic exercises to

determine whether the off-site response would adequately protect public

health and safety. In New York State, the counties are responsible for

protecting public health and safety during a natural, radiological, or other

disaster, except when the governor declares a state of emergency. The

four counties that have major responsibilities for responding to an

emergency at Indian Point 2 are Westchester, Rockland, Putnam, and

Orange. Because of the number of parties involved both on- and off-site,

good communication is essential to prepare for and respond to a

radiological emergency.

Concerned about the safety of the communities near Indian Point 2, you

asked us to examine the emergency preparedness issues associated with

the plant. Specifically, this report describes the (1) emergency

preparedness weaknesses at the plant and the actions that Consolidated

Edison has taken to resolve them, (2) lessons learned by the four Indian

Point counties from the February 2000 event, and (3) suggestions offered

by the counties to improve the radiological emergency preparedness

process beyond the actions already taken.

Over the years, NRC had identified a number of emergency preparedness

weaknesses at Indian Point 2 that had gone largely uncorrected. For

example, in 1998 and again in 1999, NRC identified several communication

weaknesses, including delays in activating the pagers used to alert the

utility’s staff about an emergency. Consolidated Edison had some actions

under way to correct emergency preparedness weaknesses before the

February 2000 event and initiated others to address the problems that

occurred during it. However, according to an April 2001 NRC inspection

report, the actions had not been fully effective. With respect to the

aforementioned communications weaknesses in particular, in evaluating

Consolidated Edison’s response to the February 2000 emergency, NRC

found that critical personnel were not notified in a timely fashion, which

delayed the staffing and operation of the on-site emergency response

facility. NRC found that this occurred because the process to activate the

pagers was complex and not well understood and that Consolidated

Edison had acted without diagnosing the underlying causes of the

problems. As a result, NRC found emergency preparedness problems

similar to those it had identified before and during the February 2000

event. Despite the weaknesses identified, in commenting on a draft of this

Results in Brief
Page 3 GAO-01-605 Indian Point 2

report, NRC noted that Consolidated Edison's emergency preparedness

program could protect the public.

The four counties in New York State that are responsible for responding to

a radiological emergency at Indian Point 2 have strengthened their

emergency preparedness programs as a result of the lessons learned from

the February 2000 event. These lessons included the need for better

coordination between the counties in responding to a radiological

emergency and in providing the media with information. Another

important lesson learned was the need to improve communication during

an emergency between Consolidated Edison and the counties about the

extent of the problems and their potential impact on the public. This

lesson resulted in one important change to improve communications

among the state, counties, and Consolidated Edison. In partnership, they

revised the form that Consolidated Edison used to provide information on

whether radiation was released from the plant. Although the February

2000 event posed no danger to the public, Consolidated Edison had not

clearly communicated with the state and counties about whether a

radioactive release had occurred and its magnitude. Consolidated Edison

reported that a radioactive release had occurred but that this release

posed no danger to the public; county officials reported that no release

had occurred. This contradictory information led to credibility problems

with the media and the public. The form now clearly shows whether a

release has occurred.

Beyond the actions already taken by Consolidated Edison and the counties

to improve their emergency response programs, county officials suggested

changes that would improve communications among NRC, FEMA, and

nonstate entities. In particular, county officials said that since they are

responsible for radiological emergency preparedness for Indian Point 2,

NRC and FEMA should communicate directly with them during

nonemergency situations. In New York and 16 other states—where more

than half of the nation’s 103 operating nuclear power plants are located—

counties or other local governments are responsible for radiological

preparedness, but NRC and FEMA communicate primarily with the states

and rely on the states to communicate with local jurisdictions. In response

to the counties’ suggestion, NRC said that meeting with local officials

would be resource intensive, and FEMA said that some states limit it from

communicating with local officials. However, NRC has not assessed the

costs and benefits of routinely meeting with local officials, and FEMA's

method of communicating with the states has not been effective in

providing the four counties with information on various initiatives that will

affect their radiological emergency preparedness programs. Given that
Page 4 GAO-01-605 Indian Point 2

effective communication is critical to prepare for and respond to a

radiological emergency, we are recommending that NRC and FEMA

reassess their policies for communicating primarily with the state in those

instances where other entities have a major role for responding to a

radiological emergency. In commenting on a draft of this report, NRC said

that it did not have the resources to routinely communicate with 160

counties, and FEMA said that it expects to increase its interactions with

local officials in the coming years.

Emergency plans for commercial nuclear power plants are intended to

protect public health and safety whenever plant accidents cause radiation

to be released to the environment. Since the March 1979 accident at the

Three Mile Island nuclear power plant in Pennsylvania, significantly more

attention has been focused on emergency preparedness. For example, the

NRC Authorization Act for Fiscal Year 1980 established a requirement for

off-site emergency planning around nuclear power plants and allowed

NRC to issue a nuclear plant operating license only if it determines that

there exists either a

• related state or local emergency preparedness plan that provides for

responding to accidents at the specific plant and complies with NRC’s

emergency planning guidelines or

• state, local, or utility plan that provides reasonable assurance that

public health and safety is not endangered by the plants’ operation in

the absence of a related state or local emergency preparedness plan.

In November 1980, NRC and FEMA published regulations that provided

the criteria for radiological emergency plans. The regulations include 16

emergency standards—15 related to both on- and off-site safety and 1

related solely to on-site safety—and require that emergency plans be

prepared to cover the population within a 10-mile radius of a commercial

nuclear power plant. In addition, state plans are required to address

measures necessary to deal with the potential for the ingestion of

radioactively contaminated foods and water out to a radius of 50 miles.

The 10-mile and 50-mile radii are called “emergency planning zones.” NRC

and FEMA have supplemented the criteria several times since November

1980, most recently in July 1996 when the agencies endorsed the prompt

evacuation of the public within a 2-mile radius and about 5 miles

downwind of the plant, rather than sheltering the public, in the event of a

severe accident.

Background
Page 5 GAO-01-605 Indian Point 2

NRC has established four emergency classification levels in order of

increasing concern—unusual events, alerts, site-area emergencies, and

general emergencies. A "general emergency" involves the actual or

imminent substantial degradation of the plant with the potential for a

significant release of radiation to the environment. The emergency at

Indian Point 2 was an “alert,” which is a low-level event that poses no

threat to public health and safety. Appendix II describes the emergency

action levels and provides examples of plant conditions that could lead to

an emergency. Since 1981, NRC’s data show that utilities reported at least

2,500 unusual events, 140 alerts, 6 site-area emergencies, and no general

emergencies.

FEMA and the affected state and local governments within the 10-mile

emergency planning zone conduct exercises at least every 2 years at each

nuclear power plant site. In addition, each state with a nuclear power

plant must conduct an exercise at least every 6 years within the 50-mile

zone. The Indian Point site has two operating plants with different

licensees—Consolidated Edison and Entergy. As a result, the practice has

been to alternate the off-site biennial exercises between the two plants.

Therefore, FEMA conducts an off-site exercise for Indian Point 2 every

4 years. Later this year, Entergy expects to assume ownership of Indian

Point 2. Under federal regulations, each licensee must participate in a

biennial off-site exercise every 2 years. Since Entergy would own both

plants on the site once NRC approves the transfer, NRC said that the

practice of alternating the off-site exercises will not be necessary.

The state of New York has three nuclear power plant sites, and FEMA

conducts a 50-mile exercise at one of the three sites every 6 years.

Therefore, FEMA would conduct a 50-mile exercise for the Indian Point

site only once every 18 years. The purpose of the exercises is to test the

integrated capabilities of appropriate state and local government agencies,

utility emergency personnel, and others to verify their capability to

mobilize and respond if an accident occurred. Before the exercises,

generally, FEMA and state officials not involved in them agree to the

accident scenarios and the aspects of emergency preparedness that will be

tested.

In addition, NRC requires utilities to conduct exercises of the plant’s onsite plan during the interval between the biennial exercises. According to

NRC staff, the utilities usually conduct their exercises as part of FEMA’s

biennial exercises. Figure 1 shows the 10- and 50-mile emergency planning

zones for Indian Point 2.
Page 6 GAO-01-605 Indian Point 2

Figure 1: 10- and 50-Mile Emergency Planning Zones for Indian Point 2

Note: The U.S. Military Academy at West Point, with a resident population of about 9,000, is located

within the 10-mile emergency planning zone in Orange County. Since the Academy is a Department

of Defense facility, it is exempt from state and local emergency planning requirements. However, the

Academy is connected to the emergency communication system that links Indian Point 2 with state

and local officials.

Source: Developed by GAO from maps obtained from Consolidated Edison.
Page 7 GAO-01-605 Indian Point 2

Over the years, NRC has identified a number of emergency preparedness

weaknesses at Indian Point 2 that have gone largely uncorrected and made

Consolidated Edison’s response during the February 2000 event less than

satisfactory. For example, in 1998 and again in 1999, NRC identified

several communication weaknesses, including delays in activating the

pagers used to alert the utility’s staff about an emergency. In evaluating

Consolidated Edison’s response to the emergency, NRC found that the

notification of critical personnel was delayed, which delayed the staffing

and operation of the on-site emergency response facility. This occurred

because the process to activate the pagers was complex and not well

understood. Consolidated Edison already had actions under way to

correct emergency preparedness weaknesses before the February 2000

event and initiated others to address the problems that occurred during it.

However, these efforts have been ineffective and incomplete. As a result,

in an April 2001 inspection report, NRC identified emergency

preparedness weaknesses similar to those that occurred before and during

the February 2000 event.

Beginning in 1996, NRC identified numerous weaknesses with the

emergency preparedness program at Indian Point 2. NRC found, for

example, that Consolidated Edison was not training its emergency

response staff in accordance with procedures and some individuals had

not taken the annual examination and/or participated in a drill or exercise

in a 2-year period as required. In response, Consolidated Edison

disciplined the individuals responsible, developed an improved computerbased roster containing the current status of the training requirements for

emergency response personnel, and instituted a process to distribute

training modules to those employees prior to the expiration of their

qualifications.

Although NRC cited Consolidated Edison for the training weaknesses,

NRC relied on the utility to take corrective actions for other emergency

preparedness problems and weaknesses. However, Consolidated Edison

did not correct the weaknesses identified. For example, in 1998 and again

in 1999, NRC identified problems with activating the pagers used to alert

the utility’s staff about an emergency as well as other communication

weaknesses. In 1999, NRC concluded that Consolidated Edison lacked the

ability to detect and correct problems and determine their causes,

resulting in weak oversight of the emergency preparedness program. In

response, NRC staff said that they met with utility managers to specifically

discuss and express NRC’s concerns with the emergency preparedness

program. In commenting on a draft of this report, NRC noted that a

Consolidated Edison

Has Taken Actions to

Resolve Emergency

Preparedness

Weaknesses, but More

Needs to Be Done

Ineffective Corrective

Actions Resulted in Repeat

Inspection Findings Before

the February 2000 Event
Page 8 GAO-01-605 Indian Point 2

September 1999 special inspection confirmed that Consolidated Edison's

emergency preparedness program would provide reasonable assurance of

protecting the public and that the utility could or would take adequate

protective measures during an emergency.

Utilities' commitment to take timely corrective action and effective NRC

oversight of the actions taken became even more important when, in April

2000, NRC implemented its new safety oversight process. (App. III

provides a brief description of the new process for emergency

preparedness.) This is because under the new safety oversight process,

NRC will rely even more on utilities to track and correct certain problems

through their corrective action programs. During subsequent inspections,

NRC will select a sample of corrective actions taken to verify that they

resolve the findings and limit the potential that they will recur. Therefore,

without a strong commitment by the utility to follow through to fix

problems or when NRC does not hold utilities accountable for fixing them,

problems can worsen. This is what happened at Indian Point 2. As

described in the next section, some of the problems that occurred during

the February 2000 event were uncorrected from the past, which confirmed

that Consolidated Edison did not effectively correct its many emergency

preparedness weaknesses.

NRC conducted an intensified inspection effort to determine the causes of

and response to the February 2000 event. During the inspections, NRC

identified several emergency preparedness problems. Although

Consolidated Edison has taken actions to correct these problems, a recent

NRC inspection found that similar problems persist.

Despite concluding that Consolidated Edison took the necessary steps to

protect public health and safety during the February 2000 event, NRC

identified several weaknesses with the emergency preparedness program

at Indian Point 2. For example, Consolidated Edison did not activate its

emergency operation facilities within the required 60 minutes primarily

because of the complex process used to page the emergency response

staff. As a result, the on-site response was delayed and the utility had no

process to ensure that all emergency response staff were notified. In

addition, NRC’s Office of the Inspector General identified other emergency

preparedness issues that are discussed in appendix IV along with NRC’s

Consolidated Edison’s

Actions to Resolve

Identified Weaknesses Are

Incomplete
Page 9 GAO-01-605 Indian Point 2

response to them.2 The Office of the Inspector General concluded, and

NRC agrees, that recurring uncorrected weaknesses at Indian Point 2

played a role in the utility’s response during the February 2000 event.

Table 1 briefly describes some of the weaknesses that occurred during the

event and the actions that the utility has taken to resolve them.

Table 1: Selected Emergency Preparedness Weaknesses That Occurred During the February 2000 Event and the Corrective

Actions Taken by Consolidated Edison

Emergency preparedness weakness Corrective action taken

Consolidated Edison did not activate its emergency operation

facilities within the required 60 minutes primarily because of the

complex process used to page the emergency response staff.

Consolidated Edison revised its pager activation process and

upgraded its pagers. It trained emergency response personnel

and tested their ability to respond during 10 training drills and an

unannounced call. It activates the pagers weekly to verify that

they are functional.

Consolidated Edison did not keep track of emergency response

personnel as they entered the plant site and could not account for

them within the required 30 minutes—it took about 20 minutes to

activate the pagers.

Consolidated Edison revised its accountability process, trained

personnel in the new process, and tested their ability to respond

during four unannounced drills.

Consolidated Edison failed to properly communicate information

about whether a radiation release had occurred and its

magnitude.

Consolidated Edison, the state, and counties revised the form

used to report whether a release of radiation had occurred and

its magnitude. In addition, the counties have agreed that they,

rather than Consolidated Edison, will notify elected officials. To

do so, Consolidated Edison paid for the counties to install a

“reverse 911” system, which supplements an existing manual

system. The “reverse 911” system dials the necessary telephone

numbers and records whether the individual has received the

message. The system is programmed to make three separate

attempts to notify each relevant local official.

Consolidated Edison’s technical representatives were late to

arrive at the counties’ emergency operations centers.

Consolidated Edison has assigned to the counties technical

representatives who will respond immediately to an emergency.

It is also working with the counties to install a videoconferencing

system in the four emergency operations centers to enhance

communications between the plant and off-site officials.

The emergency response data system (the real-time data link

between the plant and NRC) was inoperable for the first several

hours because of a preexisting equipment problem.

Consolidated Edison implemented surveillance testing and

routine monitoring to help ensure that the system is operational.

 2

See NRC’s Response to the February 15, 2000, Steam Generator Tube Rupture at Indian

Point Unit 2 Power Plant (Case No. 00-03S, Aug. 29, 2000).
Page 10 GAO-01-605 Indian Point 2

Emergency preparedness weakness Corrective action taken

Problems arose in implementing the media response plan. For

example, technical and support personnel lacked familiarity with

their jobs, and an outdated telephone list prevented Consolidated

Edison from contacting a local official.

Consolidated Edison established new procedures for the joint

news center, trained relevant personnel, and purchased new

computers to improve information availability. It has established a

process to update telephone lists. In addition, the counties have

agreed that they, rather than Consolidated Edison, will notify

elected officials. To do so, Consolidated Edison paid for the

counties to install a “reverse 911” system, which supplements an

existing manual system. The “reverse 911” system dials the

necessary telephone numbers and records whether the individual

has received the message. The system is programmed to make

three separate attempts to notify each relevant local official.

The technical support needed to resolve procedural and other

plant technical issues was not timely and was of limited help.

Consolidated Edison has revised its procedures, added staff, and

provided additional training for its staff. It conducted 11 training

drills, including 5 that were unannounced, during calendar year

2000 to test the staff’s knowledge about procedural and plant

configuration issues.

Consolidated Edison subsequently undertook an evaluation of its entire

emergency preparedness program to determine the causes of the

deficiencies and develop corrective actions. In its evaluation, Consolidated

Edison concluded that senior management did not pay sufficient attention

to the emergency preparedness program or problems at Indian Point 2

because such problems were not viewed as a high priority warranting

close attention and improvement. As a result, emergency preparedness

had relatively low visibility, minimal direction, and inadequate resources.

The company also found that (1) the emergency response organization had

been stagnant, understaffed, poorly equipped, and consistently ineffective;

(2) the emergency manager performed collateral and competing duties;

and (3) for a period of time, a contractor held the manager's position.

Consolidated Edison also found that the professional development and

continuing training of the emergency planning staff had been minimal.

Consolidated Edison undertook various initiatives to address the

deficiencies noted. The initiatives, including those identified in table 1, are

described in its business plan for calendar years 2000 and 2001. Appendix

V shows some of these initiatives.

Despite the various actions that Consolidated Edison took to correct its

emergency preparedness problems, in April 2001, NRC reported that it had

found problems similar to those previously identified at Indian Point 2.

NRC again found communication and information dissemination

weaknesses. It also found that the utility’s training program had not

prevented the recurrence of these issues during on-site drills and that its

actions to resolve other weaknesses had not been fully effective. NRC said

that Consolidated Edison had identified the major issues in its business
Page 11 GAO-01-605 Indian Point 2

plan, which, if properly implemented, should improve emergency

preparedness at the plant. In commenting on a draft of this report, NRC

noted that its April 2001 inspection report concluded that Consolidated

Edison's emergency preparedness program would provide reasonable

assurance of protecting the public.

Although Consolidated Edison has been making improvements in its

emergency preparedness program, officials recognize that these actions

alone will not enhance the public’s confidence in its ability to effectively

respond to a radiological emergency. The company must, for example,

follow through on its commitments to help achieve public confidence and

to have a strong emergency preparedness program. More importantly,

Entergy, which expects to assume ownership of the plant later this year,

will need to continue the corrective actions begun by Consolidated

Edison.

The four counties that are responsible for responding to a radiological

emergency at Indian Point 2 have strengthened their programs as a result

of the lessons learned from the February 2000 event. The lessons learned

included the need to improve (1) communications during an emergency,

(2) how the media is provided with information, and (3) coordination

among the counties in the way they respond to a radiological emergency.

The need to improve communications between Consolidated Edison and

the counties about the extent of the emergency and the potential impact

on the public was an important lesson learned from the event. This lesson

resulted in one important change to improve communications among the

state, counties, and Consolidated Edison—that is, revising the

Radiological Emergency Data Form. The utility completes the form

15 minutes after declaring an emergency and updates it at 30-minute

intervals thereafter. Although the February 2000 event posed no danger to

the public, Consolidated Edison reported that a radioactive release had

occurred but that it posed no danger to the public. County officials, on the

other hand, reported that no release had occurred. This contradictory

information led to credibility problems with the media and the public.

In April 2000, Consolidated Edison, in partnership with the state and

counties, revised the form to ensure that all affected parties are “speaking

with one voice” when providing the media and the public with

information. Before the emergency, the counties did not have a defined

process to determine the information they needed and how they would

The Four Counties

Strengthened Their

Emergency

Preparedness

Programs as a Result

of the Lessons

Learned From the

February 2000 Event
Page 12 GAO-01-605 Indian Point 2

present that information to the public. Figure 2 shows the relevant section

of the form used during the February 2000 event and the revisions made to

it.

Figure 2: Comparison of the Relevant Section of the Radiological Emergency Data

Form During and After the Event

Source: New York State Emergency Management Office.

As can be seen from figure 2, the form now clearly shows whether a

release has occurred.

• Some other actions that the counties have taken to improve their

radiological emergency programs include the following:

• All four counties have agreed to activate their emergency operation

centers at the alert level (a low-level event). Before the event, the

counties differed on when they would activate their centers. Rockland

County activated its center at the alert level; the other three counties

activated their centers at the site-area emergency level (the next level

above an alert). As a result, once Rockland activated its center during

the February 2000 event, the media questioned why the other three

counties had not done so. According to FEMA officials, Rockland

County activated its center earlier than the other counties because it is

the only county whose center is located within 10 miles of the plant.

• The counties will activate the Joint News Center (located at

Westchester County airport) at the alert level. Before the February

2000 event, the counties individually decided when to activate the Joint

News Center.
Page 13 GAO-01-605 Indian Point 2

• The “Executive Hot Line” that linked the state, four counties, and

governor has been linked to the emergency operations facility at

Indian Point 2 to establish and maintain real-time communications

during an emergency.

Even before strengthening their programs, county officials believed—and

continue to believe—they can protect public health and safety during a

radiological emergency. They take this position because they have used as

much as 80 percent of the plan for Indian Point to respond to such natural

disasters as hurricanes, snow and ice storms, and Y2K.

Beyond the actions already taken by Consolidated Edison and the counties

to improve their emergency response programs, county officials suggested

changes that would improve communications among NRC, FEMA, and

nonstate entities. In particular, county officials said that since they are

responsible for radiological emergency preparedness for Indian Point 2,

NRC and FEMA should communicate directly with them during

nonemergency situations. In New York and 16 other states—where more

than half of the nation’s 103 operating nuclear power plants are located—

counties or other local governments are responsible for radiological

preparedness, but NRC and FEMA communicate primarily with the states

and rely on the states to communicate with local jurisdictions. In response

to the counties’ suggestion, NRC said that routinely meeting with local

officials would be resource intensive, and FEMA said that some states

limit it from routinely communicating with local officials. However, NRC

has not assessed the costs and benefits of meeting with local officials, and

the four New York counties have not been privy to information concerning

various FEMA initiatives that will affect their emergency preparedness

programs.

Counties Suggest

Better

Communication

Among NRC, FEMA,

and Nonstate Entities

With a Major Role in

Radiological

Emergency

Preparedness
Page 14 GAO-01-605 Indian Point 2

One of NRC’s four performance goals, established to comply with the

Government Performance and Results Act of 1993, is to increase public

confidence in it as a regulator.3 Yet, NRC routinely communicates with the

states rather than other entities that are responsible for radiological

emergency preparedness and response. FEMA’s information shows that in

17 states where more than half of the 103 operating commercial nuclear

power plants are located, other entities, such as counties or local

governments, are responsible for radiological emergency preparedness

and response. Not communicating with these other entities could threaten

NRC's ability to achieve its public confidence goal.

At least every 5 years, NRC staff expect to meet with officials from all 31

states that have operating nuclear power plants. NRC also provides state

officials with training on such issues as the agency’s role and the resources

it can provide in the event of a radiological emergency as well as the

resources that other federal agencies can provide. According to NRC staff,

they meet with some states more frequently, and the requests to meet

exceed the agency’s capability. As a result, NRC is examining ways to

combine training and meetings on different subjects to maximize its

outreach efforts and improve the manner in which it communicates with

the states.

Although NRC’s policy is to meet at the state level, its staff believe that

local officials have various options for meeting with NRC. For example,

local officials are not precluded from participating in the meetings held at

least every 5 years with the states and can interact with NRC staff during

public meetings, including those held annually for all plants. They also

noted that NRC would likely meet with local officials if asked to do so. But

emergency preparedness officials from the four counties around Indian

Point 2 said they do not believe that public meetings are the appropriate

forums for government-to-government interactions. Therefore, the

counties suggested that NRC should meet with them at least annually.

NRC has also been considering other changes in its relationship with local

officials that could improve routine communications about emergency

preparedness. For example, earlier this year, NRC staff considered the

following questions: What should the resident inspectors (inspectors

 3

The four performance goals are to maintain safety, increase public confidence, make

NRC’s activities and decisions more effective and efficient, and reduce unnecessary

regulatory burden on stakeholders.

Increasing Public

Confidence May Be

Difficult When NRC Does

Not Routinely

Communicate With Those

Responsible for

Responding to

Radiological Emergencies
Page 15 GAO-01-605 Indian Point 2

assigned to each nuclear plant) do differently in the future concerning

interacting with local officials, and should the inspectors participate in

public meetings to discuss a plant? NRC staff considered various options

to resolve these issues. NRC has considered, for example, inviting local

officials to meet privately with resident inspectors at the conclusion of the

biennial exercise briefings or having resident inspectors attend the annual

meetings that NRC holds with the public to discuss the results of the new

safety oversight process for each plant. In an April 2001 memorandum, the

staff said they would modify NRC’s internal guidance to encourage using

resident inspectors to increase communications with local officials.

Resident inspectors generally live near the plants, are the most likely

candidates to communicate with local officials, and should be the most

knowledgeable about plant operations that could affect off-site officials.

However, NRC also has staff in four regional offices around the country

and at its headquarters in Rockville, Maryland, that could meet with local

officials. NRC has not assessed the costs and benefits of using staff other

than resident inspectors to meet with local officials.

In addition, in assessing the first year of the new safety oversight process’s

implementation, NRC expects to determine whether the annual plant

meetings help the agency meet its public confidence goal. Since the public

would be most concerned about how it could be affected by the plant in

the event of an emergency, NRC’s attaining this goal could be enhanced by

interacting with those responsible for responding to radiological

emergencies at nuclear power plants. According to NRC staff, routinely

communicating with local officials has resource implications and meeting

its public confidence performance goal entails a trade-off with the

agency’s other three goals—maintain safety, reduce unnecessary

regulatory burden, and enhance the effectiveness and efficiency of its

operations. However, NRC has not assessed the costs and benefits of

meeting with local officials or the impact that such meetings would have

on achieving its performance goals.

FEMA generally implements its programs through the states and relies on

the states to communicate relevant information to local jurisdictions.

County officials responsible for emergency preparedness at Indian Point 2

identified examples where this method of communicating with local

jurisdictions has not been effective.

For example, both New York State and county officials told us that the

February 2000 event identified the need for flexibility in FEMA’s off-site

exercises. According to county officials, they responded to the event as

FEMA Has Not Effectively

Communicated With New

York Counties Responsible

for Responding to

Radiological Emergencies

at Indian Point 2
Page 16 GAO-01-605 Indian Point 2

they would have responded during FEMA’s exercises, which are

conducted to the general emergency level. Yet, they noted, the response

for an alert like the one that occurred at Indian Point 2 is significantly

different from the response that would be taken during a general

emergency when a significant amount of radiation would be released off

the plant site, and the counties would monitor the magnitude of the

release and calculate the dose that the public would receive. As a result,

state and county officials suggested that it would be more realistic to

periodically conduct biennial exercises at the alert level, which they noted,

and NRC's data confirm, occur more frequently than a general emergency,

which has never occurred in this country. At the alert level, the counties

would activate their emergency operations centers and take other

response actions as they did during the February 2000 event. In

commenting on a draft of this report, FEMA said that the emergency plans

for the four New York counties require them to conduct off-site

monitoring and dose calculations at the alert level.

According to FEMA officials, because the exercises at Indian Point 2 were

conducted at the general emergency level, the counties were able to

respond appropriately to the February 2000 event. They also noted that

FEMA’s regulations allow state and local jurisdictions the flexibility to

structure the exercise scenarios to spend more time at the alert level and

less time at the general emergency level. Nevertheless, county officials

who participate in the exercises were not aware of the flexibility allowed

by FEMA's regulations. One reason for their lack of knowledge is that

county officials with whom we met did not participate in developing the

exercise scenarios. In commenting on a draft of this report, FEMA said

that it would consider the counties' suggestions when finalizing its new

streamlined exercise process.

In another example, county officials suggested that FEMA should consider

using tabletop exercises to supplement the biennial exercises.4

 Since 1999,

FEMA has been considering a proposal that would allow state and local

jurisdictions to use alternative techniques, including tabletop exercises,

for one of the three exercises conducted over a 6-year period. (App. VII

briefly describes FEMA's initiatives and their status.) FEMA expects to

revise its regulations in calendar year 2003 to allow the alternative

 4

A tabletop exercise is a structured discussion, which is based on a scenario or set of

conditions for potential emergency response situations, among decisionmakers or

responders in a low-stress environment. Tabletops are intended to be a teaching, training,

and developmental aid.
Page 17 GAO-01-605 Indian Point 2

techniques. Yet, county officials with whom we met were not aware that

FEMA was considering a regulatory change or how it would affect their

emergency preparedness programs. Communicating such information to

the counties would be invaluable, since a NRC document on conducting

tabletop exercises for radiological emergency response notes that it can

take as long as 6 months to plan the exercise and up to 6 months to report

on the lessons learned and the corrective actions for the issues identified.

Finally, although county officials knew that FEMA expected to implement

a streamlined exercise process in October 2001, they were not aware of

the particulars of the process or how it would affect their actions during

the exercises. According to a New York State official, the state

participated in developing the streamlined process and briefed the

counties about it. In commenting on a draft of this report, FEMA said that

one Westchester County official received information related to the new

streamlined exercise process; it had posted information on its Web page;

and it provided state, tribal, and local governments with information at an

annual conference. Despite these actions, as late as April 2001, county

officials responsible for emergency preparedness at Indian Point 2 told us

that they had received no information on the particulars of the streamlined

exercise process. Good business practices would seem to indicate that

FEMA would ensure that local jurisdictions are privy to information that

will affect their responses during the exercises and ultimately to a

radiological emergency.

We do not know whether the communication issues experienced by the

four New York counties are typical of the experience of the other

locations where the responsibility for radiological emergency

preparedness rests with an entity other than the state. Nevertheless, the

impact that a radiological emergency—even one like an alert that does not

endanger the public—can have on communities around nuclear power

plants would seem to highlight the need for effective communication to

prepare for and respond to such emergencies.

A more proactive approach by Consolidated Edison to fix recurring

weaknesses that had been identified over several years could have

improved the implementation of its emergency preparedness plan during

the February 2000 event. NRC's vigilance is needed to ensure that

Consolidated Edison and the new owner, Entergy, complete the planned

improvements. This event also demonstrated the importance of effective,

clear communication networks, both on-site in regard to the need to

ensure that pagers work well to notify key personnel of an emergency, as

Conclusions
Page 18 GAO-01-605 Indian Point 2

well as off-site, in regard to communicating about the extent and

magnitude of the emergency. The ultimate measure of Consolidated

Edison’s, the state’s, and counties’ readiness in a radiological emergency is

the manner in which they respond to an actual event. Exercises, while

playing a valuable role in preparing for and assessing such readiness, more

than likely will not identify the human reactions and all communications

issues that could arise in a real radiological emergency. This was

demonstrated during the February 2000 event.

In addition, the way the February 2000 event played out underlines the

critical importance of following through with lessons learned for

Consolidated Edison, the state, and counties and determining whether

some of these lessons could be applied to other plants. In this regard,

NRC’s and FEMA’s interacting primarily with the states for routine

communications needs to be reassessed at least for the 17 states where

another entity is responsible for radiological emergency responses. The

four Indian Point counties' lack of knowledge regarding the flexibility in

FEMA’s regulations to spend more time at various emergency levels and

its proposed streamlined exercise process demonstrate that FEMA’s

reliance on the state to communicate with the local communities did not

work in this case. Now may be an opportune time for NRC and FEMA to

assess the extent to which they communicate with those responsible for

effecting radiological emergency response.

Since the responsibility for responding to radiological emergencies at a

large percentage of this nation’s nuclear power plants rests with an entity

other than the state, we recommend that the Commissioners direct NRC

staff to assess the agency’s position of generally communicating with state

officials during nonemergency situations.

To improve communications with local governments, we recommend that

the Director of FEMA determine the reasons why the four counties

responsible for emergency response at Indian Point 2 are not

knowledgeable about FEMA's initiatives and, if necessary, reassess its

current practice of communicating through the state during nonemergency

situations.

Recommendations for

Executive Action
Page 19 GAO-01-605 Indian Point 2

We provided NRC and FEMA with a draft of this report for their review

and comment. NRC’s comments are in appendix VIII; FEMA’s comments

are in appendix IX. NRC neither agreed nor disagreed with our

recommendation. However, NRC reiterated its position that

communicating with about 160 counties during nonemergency times

would be resource intensive. NRC also raised three issues. First, NRC

said that we should make it clear our recommendation relates to

nonemeregency communications. We have done so. Second, NRC noted

that it maintained a very strong regulatory posture at Indian Point 2 in the

emergency preparedness area and that its actions were commensurate

with the safety significance of the emergency preparedness problems at

the plant. Since we had not inferred otherwise, we did not revise the

report. Third, NRC noted that despite the problems at the plant,

Consolidated Edison's emergency preparedness program would protect

the public in the event of a radiological emergency. We added this

information to the report, where appropriate. Although FEMA expressed

the view that it would be inappropriate to deal exclusively with the

counties (something we did not recommend), it plans to increase its

interaction with local officials nationwide in the coming years.

NRC and FEMA provided technical clarifications, which we incorporated

as appropriate.

We conducted our work from November 2000 through July 2001 in

accordance with generally accepted government auditing standards.

Appendix X provides details on our scope and methodology.

Unless you publicly announce its contents earlier, we plan no further

distribution of this report until 10 days after the date of this letter. At that

time, we will send copies to the Chairman, Nuclear Regulatory

Commission; the Commissioners, Nuclear Regulatory Commission; the

Director, Federal Emergency Management Agency; and the Director,

Office of Management and Budget. We will make copies available to others

on request.

Agency Comments

and Our Evaluation
Page 20 GAO-01-605 Indian Point 2

If you or your staff have any questions about this report, please call me on

(202) 512-3841. Key contributors to this report were Mary Ann Kruslicky,

Philip Olson, and Carrie Stevens.

(Ms.) Gary L. Jones

Director, Natural Resources and Environment
Page 21 GAO-01-605 Indian Point 2

List of Congressional Requesters

The Honorable Dan Burton

Chairman, Committee on Government Reform

House of Representatives

The Honorable Benjamin A. Gilman

House of Representatives

The Honorable Sue Kelly

House of Representatives

The Honorable Nita M. Lowey

House of Representatives
Appendix I: Indian Point 2 Steam Generator

Page 22 GAO-01-605 Indian Point 2

Figure 3: Indian Point 2 Steam Generator in Relation to Other Plant Equipment and the Locations Where a Leak Could

Release Radioactive Material to the Environment

Source: Nuclear Regulatory Commission.

Appendix I: Indian Point 2 Steam Generator
Appendix II: The Nuclear Regulatory

Commission’s Emergency Action Levels and

Conditions That Could Cause an Emergency

Page 23 GAO-01-605 Indian Point 2

Table 2: The Nuclear Regulatory Commission’s Emergency Action Levels and Some Examples of Nuclear Power Plant

Conditions That Could Cause an Emergency

Emergency action level and definition Examples

Unusual event

An extremely low-level emergency that

poses no threat to public safety but warrants

increased awareness on the part of utility

and off-site personnel.

Reactor coolant samples indicate measurable damage to the metal tubes that hold the

uranium fuel pellets.

The water level in the spent fuel pool is low.

Water leaks from the reactor coolant system in excess of The Nuclear Regulatory

Commission’s allowed limits.

The main turbine is severely damaged.

Loss of all on- and off-site communication equipment occurs.

Alert

A low-level emergency that poses no threat

to public safety but for which precautionary

mobilization of certain emergency response

functions is appropriate. Any radioactive

release is expected to be limited.

High radiation readings occur inside the primary containment—a large concrete and

steel structure that surrounds the reactor vessel and its coolant system.

Water leaks from the reactor coolant system at a rate greater than 50 gallons per

minute.

Radiation levels in one or more vital areas (equipment necessary for the safe operation

and shutdown of the plant) are high.

Damage to the main turbine results in damage to vital equipment.

Unauthorized personnel enter the protected area (area that includes vital plant

structures and is surrounded by a security fence).

A fire occurs that could potentially affect safety systems and an explosion occurs that

damages permanent plant equipment.

A toxic or flammable gas is released in or near a vital area.

Site-area emergency

Plant conditions degrade to a point where full

activation of response functions is warranted.

Any radioactive release is not expected to

exceed the Environmental Protection

Agency's exposure levels, except near the

site's boundary.

The normal methods of cooling the reactor—feed water system, main steam system, or

steam generators—do not function.

All alternating current electrical power to vital busses (on-site network to supply electric

power) is lost for more than 15 minutes.

Unauthorized personnel enter a vital area of the plant.

General emergency

Actual or imminent substantial degradation or

melting of the reactor with the potential for a

significant radioactive release to the

environment beyond the plant’s boundary

occurs.

Two of the three fission product barriers (fuel cladding, reactor coolant system, and

containment) fail.

All alternating current electrical power (on- and off-site) is lost and not expected to be

available for an extended period of time.

Unauthorized personnel take over the control room so that the utility looses the ability

to safely operate or shut down the plant.

Appendix II: The Nuclear Regulatory

Commission’s Emergency Action Levels and

Conditions That Could Cause an Emergency
Appendix III: Description of NRC’s New

Safety Oversight Process for Emergency

Preparedness

Page 24 GAO-01-605 Indian Point 2

In April 2000, the Nuclear Regulatory Commission (NRC) implemented its

new safety oversight process for nuclear power plants. Emergency

preparedness is one of seven “cornerstones” of the new safety oversight

process.1

 The cornerstones represent the activities that are essential for

the safe operation of the plants. The new safety oversight process also

includes performance indicators, inspections, and an assessment of the

safety significance of the inspection findings for all seven cornerstones.

NRC integrates the indicator results with inspection findings to arrive at a

conclusion about the overall safety performance of the plants and the

regulatory response that should be taken, if any.

Under its new safety oversight process, NRC has stratified emergency

preparedness requirements on the basis of their safety significance. The

focus of inspections is the 16 standards in 10 C.F.R. 50.47(b). NRC

concluded that the standards are not equally important to safety. As a

result, NRC identified the following four planning standards that are the

most significant from a safety standpoint:

• Timely and accurate classification of events because untimely and

inaccurate classification can delay the activation of the utility’s

emergency response organization and notification of off-site

governmental authorities.

• Timely and accurate notification of off-site governmental authorities.

• Timely and accurate development of recommended actions that offsite authorities should take to protect the public.

• Assessment of the off-site consequences of a radiological emergency

condition.

NRC focuses its oversight and inspection resources in emergency

preparedness on these four standards. NRC’s procedures set out the

agency’s expectations for inspectors and the methodology to be used to

prioritize and expend resources for the remaining 12 standards. In

addition, each year, NRC expects its staff to verify the accuracy of

performance indicator data, the utilities’ problem identification and

resolution programs, and the tests of the emergency response organization

and public alert and notification system (sirens).

 1

The seven cornerstones are initiating events, mitigating systems, barrier integrity,

emergency preparedness, public radiation safety, occupational radiation safety, and

physical protection.

Appendix III: Description of NRC’s New

Safety Oversight Process for Emergency

Preparedness
Appendix III: Description of NRC’s New

Safety Oversight Process for Emergency

Preparedness

Page 25 GAO-01-605 Indian Point 2

As part of the new safety oversight process, NRC identified three

performance indicators for emergency preparedness: drill/exercise

performance, emergency response organization drill participation, and

reliability of the alert and notification system. The drill/exercise indicator

measures performance in specific risk-significant activities; the emergency

response organization indicator provides information to assess the

licensees’ development and maintenance of key skills. From these two

indicators, NRC can assess the quality of training and emergency-planimplementing procedures as well as facility and equipment readiness,

including communications; personnel performance; and organizational

and management changes. In addition, a high rate of reliability of the alert

and notification system increases assurances that the utility can protect

public health and safety during an emergency. Table 3 shows performance

indicator data for Indian Point 2 from April 2000, when NRC instituted the

new safety oversight process, through March 2001, the month of the most

currently available data.

Table 3: Performance Indicator Data Through March 2001

Shown as a percentage

Performance indicator April 2000 December 2000 March 2001

Drill/exercise performance 91.2 94.5 95.2

Emergency response organization drill

participation

100.0 98.4 100.0

Reliability of the alert and notification

system

99.1 99.0 98.9

Source: NRC.

For each indicator, NRC has established thresholds for increased agency

oversight of commercial nuclear plants. For example, if the utility’s

drill/exercise performance is less than 90 percent, if the emergency

response organization drill participation is less than 80 percent, or if the

reliability of the alert and notification system is less than 94 percent, NRC

will focus greater attention on emergency preparedness activities at a

plant. As shown in table 3, since the inception of these performance

indicators in April 2000, Indian Point 2 has always exceeded NRC’s

thresholds.

In commenting on a draft of this report, NRC noted that it selected the

three performance indicators in conjunction with stakeholders because

they represented objective measures to monitor safety-significant

emergency preparedness activities. According to a representative of the

Union of Concerned Scientists, two of the performance indicators—
Appendix III: Description of NRC’s New

Safety Oversight Process for Emergency

Preparedness

Page 26 GAO-01-605 Indian Point 2

drill/exercise performance and emergency response organization drill

participation—are appropriate, but the alert and notification system

indicator is not. The reason is that the indicator reflects only the results of

monthly tests done on the alert and notification system and how many

pass or fail. However, if the equipment is inoperable between the time that

the tests are conducted, this is not reflected in the indicator. Yet,

inoperable equipment and equipment failure do happen. The Union’s

representative believes a better indicator would be “availability”; that is,

the total hours in a month that the equipment does not operate and for

how many hours it is inoperable. NRC staff expect to assess the first-year

implementation of the new safety oversight process and recommend

changes to the Commission. In commenting on a draft of this report, NRC

noted that although an availability indicator could enhance the current

performance indicators, it selected the reliability indicator to be consistent

with the Federal Emergency Management Agency's guidance for siren

testing and reporting.
Appendix IV: Some Emergency Preparedness

Issues Identified by NRC’s Office of the

Inspector General

Page 27 GAO-01-605 Indian Point 2

In August 2000, NRC’s Office of the Inspector General reported on

emergency preparedness and other issues at Indian Point 2. Selected

issues and the affected parties’ plans to address them are discussed below.

• Local officials want increased interaction with NRC on a routine basis.

As of April 3, 2001, NRC had determined that it would modify its

inspection guidance to encourage using resident inspectors for

increased communications to enhance local public confidence in NRC.

• Communication between county emergency operations centers and

NRC was nonexistent during the emergency. NRC does not expect to

take any action on this issue because the agency does not normally

communicate with local centers but, rather, relies on the state as a

single point of contact. The state is responsible for providing the

counties with information as well as evaluating the emergency and the

appropriate response to it.

• NRC did not notify the U.S. Secret Service about the emergency. NRC

transmitted information about the emergency to the White House

Situation Room, which was responsible for informing the Secret

Service. However, because of the proximity of former President and

Senator Clinton’s residence to the plant (11-1/2 miles), NRC and the

Secret Service finalized a new protocol, whereby NRC will notify the

Secret Service whenever a problem occurs at any NRC-licensed

facility, including commercial nuclear power plants.

• The release of information was not timely. According to NRC staff, in a

December 2000 letter, Consolidated Edison provided information that

refuted the Inspector General’s findings and concluded that

information was released in a timely manner.

• The state experienced difficulties in getting information about the

emergency from Consolidated Edison. The utility expects to stress the

importance of communications with off-site agencies in its training

program. NRC will monitor the actions taken.

• English is a second language for many who live within 10 miles of the

plant. According to NRC staff, FEMA is responsible for evaluating this

issue. FEMA officials said they will evaluate this issue after the final

2000 Census data are available. They noted, however, that they expect

the 2000 Census data to show that Spanish is a second language for

more than 5 percent of the population within 10 miles of Indian Point

and that the various oriental language groups are likely to approach

and may exceed 5 percent. According to FEMA officials, this could be

a significant issue for Indian Point, which has an estimated 280,000

people within 10 miles of the site. FEMA expects to complete a draft

report on this issue by the end of calendar year 2001.

Appendix IV: Some Emergency Preparedness

Issues Identified by NRC’s Office of the

Inspector General
Appendix V: Emergency Preparedness

Corrective Actions Initiated by Consolidated

Edison Since the February 2000 Event

Page 28 GAO-01-605 Indian Point 2

• Establish a minimum of three emergency response organization teams.

• Implement an improved emergency drill and exercise program.

• Implement an improved emergency facility and equipment check

surveillance program.

• Implement an improved self-assessment and performance indicator

process.

• Implement an improved training program for emergency management

staff.

• Revise the process for staffing the emergency notification telephone

system in the technical support center.

• Develop surveillance tests for the emergency response data system.

• Establish an emergency off-site technical advisor program.

• Upgrade the Meteorological Information Data Acquisition System.

• Upgrade the off-site Reuter-Stokes radiation monitoring system.

• Upgrade the siren verification system.

• Revise and implement an off-site monitor training program.

• Develop and implement a Web page for Indian Point 2.

• Issue new pagers to plant personnel.

• Conduct off-hours drills.

• Train joint news center personnel.

• Train company personnel who communicate with the media.

• Develop communication and visual aids to better provide the public

with information.

Appendix V: Emergency Preparedness

Corrective Actions Initiated by Consolidated

Edison Since the February 2000 Event
Appendix VI: County Officials’ Suggestions to

Improve Radiological Emergency

Preparedness and NRC’s/FEMA’s Responses

Page 29 GAO-01-605 Indian Point 2

Table 4: Suggestions Made by County Officials to Improve Radiological Emergency Preparedness and NRC’s and FEMA’s

Responses

Suggested action NRC staff’s response FEMA’s response

NRC and FEMA

NRC and FEMA need to condition off-site

jurisdictions that an alert does not equate

to a general emergency.

Any outreach effort is beneficial and would

help NRC meet its “increase public

confidence” performance goal. However,

NRC does not normally communicate with

local jurisdictions but, rather, relies on the

state as a single point of contact. NRC

believes that its state outreach efforts have

been successful. In addition, it would be

very resource-intensive if NRC were to

routinely meet with local officials.

FEMA’s guidance allows states and local

jurisdictions the flexibility to structure the

exercise scenarios to spend more time at

the alert level and less time at the general

emergency level.

FEMA only

FEMA should not always conduct

exercises at the general emergency level.

In other words, FEMA should vary the

emergency action level during its

exercises.

NRC's Region I staff said that conducting

exercises at the general emergency level

contributed to the positive responses taken

by local jurisdictions during the February

2000 event. However, the probability that a

general emergency will occur is very small

while the probability for an alert is greater.

FEMA’s guidance allows states and local

jurisdictions the flexibility to structure the

exercise scenarios to spend more time at

the alert level and less time at the general

emergency level.

FEMA should establish liaisons with the

counties that would be familiar with the

relevant emergency plan. The liaisons

would participate in the off-site exercises.

With only one exception, FEMA

implements its programs through the

states. The states are responsible for

assisting local jurisdictions and providing

them with information. New York State

officials have asked FEMA to coordinate its

communications/interactions with local

jurisdictions through the state.

FEMA has assigned five staff involved with

emergency preparedness at Indian Point.

FEMA has a site manager (at all nuclear

plant sites) and a team leader for each

New York county within 10 miles of the

plant. Although the site manager and team

leaders are not located at the plant, they

are familiar with the local emergency plans

and participate in the exercises.

FEMA could conduct tabletop exercises in

lieu of the off-site exercises on a rotating

basis.

One of the initiatives resulting from FEMA’s

strategic review would allow state and local

jurisdictions to use alternative techniques in

one of the three exercises conducted over

a 6-year period. NRC is developing a rulemaking plan to revise its emergency

preparedness regulations, and staff expect

to provide the Commission with their

recommendations by the end of calendar

year 2001. NRC will coordinate the content

and timing of its rulemaking with FEMA.

Tabletop exercises have limited usefulness

in the radiological emergency

preparedness program. Tabletop exercises

could be used to test the decisions made

by off-site officials but would not be

beneficial for testing the participants’ ability

to appropriately measure radiation releases

and calculate the dose received.

FEMA’s regulations allow states and local

jurisdictions the flexibility to structure the

exercise scenarios to spend more time at

Appendix VI: County Officials’ Suggestions to

Improve Radiological Emergency

Preparedness and NRC’s/FEMA’s Responses
Appendix VI: County Officials’ Suggestions to

Improve Radiological Emergency

Preparedness and NRC’s/FEMA’s Responses

Page 30 GAO-01-605 Indian Point 2

Suggested action NRC staff’s response FEMA’s response

the alert level and less time at the general

emergency level.

One of the initiatives resulting from FEMA’s

strategic review would allow states and

local jurisdictions to use alternative

techniques in one of the three exercises

conducted over a 6-year period. FEMA will

revise its emergency preparedness

regulations to implement this initiative.

FEMA expects to finalize its regulations in

calendar year 2003.

FEMA could use tabletop exercises to

assess the state’s and counties’ ability to

respond within the 50-mile ingestion

pathway.

NRC staff said that nothing in FEMA’s

regulations would preclude states and local

jurisdictions from conducting more

exercises.

Although FEMA uses tabletop exercises to

test other emergency responses, it has not

used them for assessing radiological

emergency responses within the 10-mile

emergency planning zone at Indian Point 2.

FEMA would have no objections to states

and local jurisdictions using tabletop

exercises to supplement the required

6-year exercises. In commenting on a draft

of this report, FEMA noted that it has used

tabletop exercises for the 50-mile ingestion

pathway exercises.

FEMA should be at the counties’

emergency operations centers during an

alert. This would allow a real-time

evaluation of performance and could

eliminate the need for a biennial exercise.

Some alerts are short lived. It would be

inappropriate for FEMA to establish an

expectation that staff would be at

emergency operations centers during an

alert and then not meet that expectation.

FEMA’s regulations set out policies and

procedures for state and local jurisdictions

to obtain credits for their response to an

actual emergency or natural disaster.

FEMA could not, however, give credit for

radiation monitoring and dose

assessments. So, an exercise of some

aspects of the radiological emergency plan

would need to be conducted.
Appendix VI: County Officials’ Suggestions to

Improve Radiological Emergency

Preparedness and NRC’s/FEMA’s Responses

Page 31 GAO-01-605 Indian Point 2

Suggested action NRC staff’s response FEMA’s response

FEMA should conduct unannounced

exercises.

NRC staff did not believe it was viable or

practical for FEMA to conduct

unannounced exercises. They noted that a

full-participation exercise can involve

hundreds of participants, including

volunteers, and that a large part of the

training benefits of the exercise would be

lost if FEMA did not announce them. They

also noted that although FEMA, state and

local jurisdictions, and the utility develop

the exercise scenario, FEMA does not give

the scenario to participants nor is the exact

time of the exercise announced. Rather,

FEMA announces the week in which the

exercise will occur. Therefore, the exercise

is “unannounced” since the state and local

jurisdictions do not know the exact date on

which it will occur.

FEMA conducts unannounced exercises

for some aspects of radiological emergency

preparedness. For example, in October

1999, FEMA conducted an unannounced

and off-hours drill of the four Indian Point

counties’ ability to activate their emergency

operations centers, mobilize their staff, and

establish communication links with the

plant.

As part of its efforts to streamline its

program, FEMA is considering a proposal

to eliminate unannounced exercises

because of opposition from off-site officials

throughout the country. In commenting on

a draft of this report, FEMA said that it will

continue to conduct unannounced drills for

a specific situation—a fast-breaking

emergency.

NRC only

NRC should meet with officials from the

four Indian Point 2 counties at least

annually (i.e., during nonemergency times).

NRC does not normally interact with local

officials but, rather, relies on the state as a

single point of contact during emergencies

and at other times. It would be very

resource-intensive to meet with all local

jurisdictions. However, NRC staff have

assessed this issue and developed options

to resolve it. Whatever option is selected

must be applied consistently to all plants

but must allow for regional and

headquarters management flexibility in

implementing the option because different

plants may need to be treated differently,

depending on the level of public interest

about the plant.

FEMA officials said that they would have

no objection to NRC’s meeting with county

officials.

In addition, if the Indian Point counties

have issues or concerns about receiving

information, FEMA’s regional office could

obtain the information for them or provide a

bridge to other federal agencies.

Other

Consolidated Edison or NRC needs to

provide more public education on the

actual and fictional hazards of nuclear

power.

Although NRC and the licensee are

responsible for educating the public, the

licensee is primarily responsible for doing

so. However, NRC’s Web site provides

some educational material and its Office of

Public Affairs periodically conducts a

workshop for the media. In addition, NRC's

technical staff visit schools to discuss

NRC’s role and functions and how plants

are designed.

Some states have active public education

programs.

NRC could conduct education programs

without violating the restriction that

prohibits it from promoting nuclear power.

A significant difference exists between

conducting education programs and being

an industry proponent.
Appendix VII: Initiatives to Streamline

FEMA’s Radiological Emergency

Preparedness Program and Their Status

Page 32 GAO-01-605 Indian Point 2

In June 1996, FEMA announced that it would review its radiological

emergency preparedness program to identify opportunities to improve,

streamline, and enhance its efficiency and effectiveness. The resulting

1999 report included 34 initiatives to improve the program. One group of

initiatives is intended to streamline the radiological emergency

preparedness program. Since that time, FEMA has completed 24

initiatives. FEMA expects to implement a streamlined exercise process in

October 2001.

Some FEMA officials have raised concerns about the streamlined process.

In particular, they are concerned with the (1) expanded use of granting

credits for the responses taken for nonradiological emergencies,

(2) increased use of out-of-sequence exercises (conducted separately from

the biennial exercise) for some radiological preparedness activities and

functions, and (3) possibility of eliminating unannounced exercises. We

did not examine the validity of these concerns because they were outside

the scope of this report. In commenting on a draft of this report, FEMA

noted that it would monitor the implementation of the initiatives and will,

if necessary, revise any that are not attaining the desired result. Table 5

shows the initiatives and their implementation status, according to FEMA

officials.

Table 5: FEMA’s Initiatives and Their Status

Initiative Implementation status

Streamline the program

Consolidate evaluation objectives into six areas to support a

results-oriented process

Interim evaluation areas published; four pilot exercises

completed. On June 11, 2001, FEMA published the results of the

pilot projects in the Federal Register, which included the new

evaluation areas, for comment. FEMA expects to implement the

new evaluation areas for the exercises conducted after

September 30, 2001.

Conduct medical services drills biennially Completed; policy took effect in October 1999.

Use out-of-sequence demonstrations of evaluation areas Completed; policy took effect in October 1999.

Provide feedback at the conclusion of an exercise Completed; policy took effect in October 1999.

Take immediate corrective actions during out-of-sequence

demonstrations

Completed; policy took effect in March 2000.

Provide credit for unannounced and off-hours exercises and drills

on the basis of the response to an actual emergency

Policy paper issued in September 2000 for comment.

Implement new exercise scenario options Draft policy issued in October 2000. Policy will be finalized after

FEMA revises its regulation.

Revise the annual letter of certification-related regulations Complete but not as recommended. FEMA will not revise its

regulations. Instead, it directed regional offices to ensure

submission, consistency, and completeness of the letters.

Revise the annual letter of certification submittal requirements Completed in July 2000.

Appendix VII: Initiatives to Streamline

FEMA’s Radiological Emergency

Preparedness Program and Their Status
Appendix VII: Initiatives to Streamline

FEMA’s Radiological Emergency

Preparedness Program and Their Status

Page 33 GAO-01-605 Indian Point 2

Initiative Implementation status

Verify the documentation provided with the annual letter of

certification

Completed in July 2000.

Negotiate agreements to conduct only two exercises over a 6-year

period; revise regulations (FEMA and NRC) to allow for this change

Rulemaking in process. Implementing policy posted for public

comment. FEMA expects to finalize its regulation late in calendar

year 2003.

Conduct staff visits to assist states, tribal nations, and local

governments

Completed; policy took effect in August 2000.

Develop a radiological emergency preparedness program manual

that reflects revised and updated policies and guidance

FEMA expects to complete this initiative by October 1, 2001.

Revise the joint NRC/FEMA criteria and memorandum of

understanding

Criteria will not be revised. Rather, an addendum updating the

outdated references was provided to the agencies that are

members of the Federal Radiological Preparedness Coordinating

Committee for comment. In addition, in May 2001, FEMA and

NRC published the addendum in the Federal Register for

comment. The comment period ends on August 1, 2001.

Review all program guidance at least once every 2 years Ongoing.

Post program guidance on FEMA’s Web site Completed; documents are placed on the Web site as they

become available.

Increase federal participation in exercises

Have FEMA take the lead in planning and coordinating exercises Completed in September 2000.

Complete the Radiological Incident Annex The information will be published as a revision to the Federal

Response Plan.

Establish an interagency task force to review the charters of

various response committees

Completed but not as recommended. FEMA recommended that

the Federal Radiological Protection Coordinating Committee

consider establishing the task force.

Identify additional resources needed Completed.

Reinforce the role of the Federal Radiological Preparedness

Coordinating Committee

Completed.

Review and revise training courses Completed.

Establish a position in FEMA to facilitate communication Completed.

Use state, local, and tribal personnel as exercise evaluators

Establish conditions to use state, tribal, and local personnel as

exercise evaluators

Completed.

Develop a memorandum of understand with state, tribal, and local

governments that agree to provide exercise evaluators

Completed in June 2001.

Develop qualification standards for the nonfederal evaluators Completed in June 2001.

Include Native American tribal nations in the radiological

emergency preparedness process

Identify areas for federal and tribal relationships Completed.

Identify all federally recognized tribes in the 10- and 50-mile radius

of nuclear plant sites

Completed.

Identify current government-to-government policies and practices Completed.

Develop an approach to increase tribal involvement Completed.

Enhance training requirements and curriculum

Establish qualification standards for federal exercise evaluators Completed.

Increase opportunities for FEMA staff to teach evaluator training Completed.
Appendix VII: Initiatives to Streamline

FEMA’s Radiological Emergency

Preparedness Program and Their Status

Page 34 GAO-01-605 Indian Point 2

Initiative Implementation status

Revise radiological courses Short refresher course used during the pilot program at four

nuclear plants. FEMA is developing a resident evaluator course

using the new evaluation areas.

Develop an administration course for all FEMA radiological

emergency preparedness staff

On hold, pending completion of the radiological emergency

preparedness manual.

As can be seen from table 5, FEMA’s major initiative related to

streamlining its radiological emergency preparedness program. FEMA had

more than 15 separate activities to attain this objective. For example,

FEMA is proposing to move from an objective-based, checklist format,

exercise evaluation, which is very structured and leaves little latitude to

satisfy the exercise objectives by alternative means, to a more

comprehensive/holistic approach. To this end, FEMA examined the 33

exercise objectives that it had developed to clarify what constituted an

exercise and to ensure consistency in the method used to evaluate the

exercises. FEMA consolidated the 33 objectives into six evaluation areas

to support a results-oriented process. A results-oriented process will allow

participants to complete an exercise activity without following a specific

checklist and with more latitude to reach the desired results. This would

allow FEMA to concentrate on the exercise results—not the methods used

to reach the results—and would allow states or local jurisdictions to use

an alternative method(s) to attain a result.

FEMA pilot tested the new exercise evaluation areas from October

through December 2000 at four nuclear plant sites. The sites included

Susquehanna 1 and 2 in Pennsylvania, Crystal River in Florida, Point

Beach 1 and 2 in Wisconsin, and Duane Arnold in Iowa. Overall, the

exercise participants at all four pilot projects were very positive about the

new evaluation process. Likewise, feedback from FEMA’s evaluators was

mostly positive, but the evaluators identified three issues that FEMA

needed to address. First, training needs to focus on how the evaluators

must prepare for an exercise and become very familiar with the plans and

facilities for which they are responsible. Second, FEMA needs to

document the required components of off-site radiological emergency

response plans, since the joint NRC/FEMA criteria leave room for

interpretation in many planning areas. Finally, FEMA should establish a

mentor program for new staff to help them achieve an acceptable

evaluation capability. In June 2001, FEMA published its report on all four

pilot projects in the Federal Register and allowed the public 60 days to

comment. On the basis of the lessons learned from the pilot projects and

public comments on them, FEMA expects to revise its proposed

streamlined approach, if necessary, and implement it in October 2001.
Appendix VIII: Comments From the Nuclear

Regulatory Commission

Page 35 GAO-01-605 Indian Point 2

Appendix VIII: Comments From the Nuclear

Regulatory Commission

Note: GAO's comments

supplementing those in

the report's text appear at

the end of this appendix.
Appendix VIII: Comments From the Nuclear

Regulatory Commission

Page 36 GAO-01-605 Indian Point 2

See comment 1.
Appendix VIII: Comments From the Nuclear

Regulatory Commission

Page 37 GAO-01-605 Indian Point 2

See comment 3.

See comment 2.
Appendix VIII: Comments From the Nuclear

Regulatory Commission

Page 38 GAO-01-605 Indian Point 2

Now on p. 31.

Now on p. 29.

See comment 6.

See comment 5.

See comment 4.
Appendix VIII: Comments From the Nuclear

Regulatory Commission

Page 39 GAO-01-605 Indian Point 2

See comment 7.
Appendix VIII: Comments From the Nuclear

Regulatory Commission

Page 40 GAO-01-605 Indian Point 2

See comment 8.
Appendix VIII: Comments From the Nuclear

Regulatory Commission

Page 41 GAO-01-605 Indian Point 2

See comment 15.

See comment 14.

See comment 13.

Now on p. 5.

See comment 12.

See comment 11.

See comment 10.

See comment 9.
Appendix VIII: Comments From the Nuclear

Regulatory Commission

Page 42 GAO-01-605 Indian Point 2

Now on p. 25.

See comment 21.

Now on p. 24.

See comment 20.

Now on p. 23.

See comment 19.

See comment 18.

See comment 17.

See comment 16.
Appendix VIII: Comments From the Nuclear

Regulatory Commission

Page 43 GAO-01-605 Indian Point 2

Now on p. 29.

See comment 25.

 Now on p. 26.

 See comment 23.

Now on p. 25.

See comment 22.

Now on p. 29.

See comment 24.
Appendix VIII: Comments From the Nuclear

Regulatory Commission

Page 44 GAO-01-605 Indian Point 2

The following are GAO’s comments on the Nuclear Regulatory

Commission’s (NRC) letter dated July 13, 2001.

1. The report notes that the utility's radiological emergency preparedness

plan identifies the process for notifying and communicating with

federal, state, and local agencies and the media during an event. In

addition, the counties' suggestion to interact and meet with NRC

annually applies to nonemergency situations. Furthermore, the report

clearly sets out some of the opportunities that the counties have to

meet with NRC, including the annual meetings held to discuss all

plants. As noted, however, emergency preparedness officials from the

four counties did not believe that public meetings are the appropriate

forums for government-to-government interactions. In addition,

although the counties could be invited to the state outreach meetings

that NRC attempts to hold with all the states every 5 years, NRC could

not provide documentation that inviting the counties to such meetings

is a routine practice. In fact, NRC staff told us that they were

developing protocols for the state outreach program because no such

documentation existed.

2. We revised the recommendation to clarify that it relates to routine,

nonemergency communications. In addition, the recommendation is

not intended to change the "coordinated approach" used by NRC to

interact with the 31 states with commercial nuclear power plants.

Rather, the recommendation is intended to supplement the actions

that NRC takes. In addition, New York State and the counties did not

say that they wanted to meet with NRC in lieu of the "coordinated

approach" now used. Rather, since they are the entities primarily

responsible for emergency preparedness—not the state—they want to

meet and interact with NRC to obtain information about the status of

the plant and any issues or problems that could affect their emergency

preparedness programs.

3. We continue to believe that NRC does not routinely communicate with

nonstate entities responsible for responding to radiological

emergencies. NRC cites various activities in which local governments

have communicated with or could communicate with it. For example,

NRC notes that ingestion pathway exercises include the counties.

However, FEMA conducts such exercises every 6 years and on a

rotating basis among the three nuclear plant sites in New York State.

As a result, an ingestion pathway exercise for Indian Point 2 would be

held every 18 years. In addition, NRC said that it participated with

GAO’s Comments
Appendix VIII: Comments From the Nuclear

Regulatory Commission

Page 45 GAO-01-605 Indian Point 2

state and county officials in a tabletop exercise. On the basis of our

discussions with NRC staff, this occurred only once in January 2001

and, at that time, the staff had not determined whether they would

continue to attend the quarterly meetings held among New York State,

county, and utility officials. Furthermore, NRC noted that the counties

surrounding Indian Point 2 are routinely sent notices of meetings and

inspection reports. But NRC has missed the point. The four New York

counties did not say that they did not receive information about

meetings or copies of inspection reports; rather, they said that they

would like the opportunity to meet on a government-to-government

basis with NRC. Being aware of public meetings and receiving copies

of inspection reports cannot take the place of face-to-face interaction

between NRC and the counties. Whatever NRC ultimately decides, one

important consideration should be the large number of people that

could be affected by a severe accident at Indian Point 2.

4. NRC does not routinely communicate with local jurisdictions either

during an emergency or during nonemergency situations. Its

"coordinated approach" relies on the state as a single point of contact.

Therefore, we did not revise the report as NRC suggested.

5. We revised the report as NRC suggested.

6. See comment 1.

7. We revised the report to reflect that the September 1999 special

inspection confirmed Consolidated Edison's capability to respond to

an emergency and that the problems experienced during the February

2000 event did not result in the loss of reasonable assurance that

adequate protective measures could or would be taken during an

emergency. In addition, we continue to believe—and NRC's inspection

reports and Consolidated Edison's self-assessment support—that the

emergency preparedness problems at Indian Point 2 worsened after

1995. Finally, we never took a position on the safety significance of

the emergency preparedness weaknesses that NRC identified at Indian

Point 2. Such a determination is solely NRC's responsibility.

8. We added NRC's conclusion to the report; i.e., Consolidated Edison's

emergency preparedness program would provide reasonable

assurance to protect the public. However, we do not believe that it is

misleading to state that Consolidated Edison's efforts to correct the

emergency preparedness weaknesses that occurred before and during
Appendix VIII: Comments From the Nuclear

Regulatory Commission

Page 46 GAO-01-605 Indian Point 2

the February 2000 event were incomplete and ineffective since in April

2001, NRC reported identified similar weaknesses.

9. We revised the report as NRC suggested.

10. We revised the report as NRC suggested.

11. We did not revise the report because the information that NRC

suggested was already in the report.

12. We revised the report as NRC suggested.

13. We revised the report to include the information that NRC provided.

14. We did not revise the report because the information that NRC

suggested was already in the report.

15. We revised the report to include the information that NRC suggested.

16. We revised the report as NRC suggested.

17. We did not revise the report as NRC suggested because the

information was already in the report. In addition, the report later

notes that NRC staff met with Consolidated Edison to discuss the

agency's concerns about the emergency preparedness weaknesses at

Indian Point 2.

18. We revised the report as NRC suggested.

19. We revised the report to include the information that NRC provided.

20. We revised the report as NRC suggested.

21. We revised the report as NRC suggested.

22. We revised the report to include the essence of the information that

NRC provided.

23. We revised the report to include the information that NRC provided.

24. We did not revise the report because the information suggested by

NRC was already in the report.

25. We revised the report to include the information that NRC provided.
Appendix IX: Comments From the Federal Emergency Management Agency

Page 47 GAO-01-605 Indian Point 2

Appendix IX: Comments From the Federal

Emergency Management Agency

Note: GAO's comments

supplementing those in

the report's text appear at

the end of this appendix.

See comment 2.

See comment 1.
Appendix IX: Comments From the Federal Emergency Management Agency

Page 48 GAO-01-605 Indian Point 2

Now on p. 10.

See comment 5.

See comment 4.

See comment 3.
Appendix IX: Comments From the Federal Emergency Management Agency

Page 49 GAO-01-605 Indian Point 2

See comment 7.

See comment 6.
Appendix IX: Comments From the Federal Emergency Management Agency

Page 50 GAO-01-605 Indian Point 2

See comment 9.

See comment 8.
Appendix IX: Comments From the Federal Emergency Management Agency

Page 51 GAO-01-605 Indian Point 2

Now on p. 31.

See comment 14.

Now on p. 30.

See comment 13.

Now on p. 29.

See comment 12.

Now on p. 27.

See comment 11.

See comment 10.
Appendix IX: Comments From the Federal Emergency Management Agency

Page 52 GAO-01-605 Indian Point 2

See comment 19.

See comment 18.

See comment 17.

Now on p. 32.

See comment 16.

Now on p 31.

See comment 15.
Appendix IX: Comments From the Federal Emergency Management Agency

Page 53 GAO-01-605 Indian Point 2
Appendix IX: Comments From the Federal

Emergency Management Agency

Page 54 GAO-01-605 Indian Point 2

The following are GAO’s comments on the Federal Emergency

Management Agency’s (FEMA) letter dated July 6, 2001.

1. Since we clearly state in the introduction of the report the differences

in responsibilities between the NRC and FEMA for on- and off-site

radiological emergency preparedness, respectively, we did not revise

the report as FEMA suggested.

2. We revised the report to show that FEMA expects to increase its

interaction with local officials in the coming years.

3. FEMA reiterated information provided in the draft report. As a result,

we did not revise the report.

4. We revised the report to show that, as a Department of Defense

facility, the U.S. Military Academy at West Point is exempt from state

and local emergency-planning requirements but is connected to the

emergency communication system that links Indian Point 2 with state

and county officials. The Academy is developing a radiological

response plan for its population and visitors. However, until the

Department of Defense approves a plan, the population and visitors to

the Academy are not provided the same level of protection as that

provided to the public in Orange County.

5. FEMA provided historical information on the evolution of the "reverse

911" system implemented after the February 2000 event. However,

table 1 shows the corrective actions following the event. As a result,

we did not revise the report to incorporate the additional information

that FEMA provided.

6. See comment 2.

7. We revised the report to show that the emergency plans for the four

counties require them to conduct off-site monitoring and dose

calculations at the alert level. This information would seem to provide

support for the counties' suggestion to spend more time at the alert

level during off-site exercises. In addition, although FEMA provided

information on the time spent at the various emergency action levels

for the biennial exercises conducted since May 1982, it did not provide

an exercise completion time. We found, however, that the general

emergency portion of the exercises conducted in April 1996, June 1998,

and November 2000, ended between 3 and 4 hours after they started

GAO’s Comments
Appendix IX: Comments From the Federal

Emergency Management Agency

Page 55 GAO-01-605 Indian Point 2

while the time spent at the unusual event level ranged from 1/2 hour to

1 hour; at the alert level, from 1-1/4 hours to 1-3/4 hours; and at the

site-area level, from about 1 hour to 1-1/2 hours. Therefore, FEMA's

information supports the counties; that is, more time is spent at the

general emergency level than at the three lower emergency levels

during an exercise.

8. We revised the report to show that the county officials with whom we

met did not participate in developing the exercise scenarios and that

FEMA will consider the counties' suggestions when finalizing its new

streamlined exercise process.

9. We revised the report to briefly discuss the actions that FEMA took to

distribute information about the new streamlined exercise process.

Nevertheless, FEMA's placing information on its Web page or

discussing it at an annual conference were not successful in providing

information about the new process to Westchester, Putnam, Orange,

and Rockland county officials with whom we met.

10. We did not revise the report because our recommendation to FEMA

did not say that the agency should deal "exclusively" with the counties.

11. We revised the report to include the information that FEMA suggested.

12. See comment 6.

13. We revised the report to show that FEMA has used tabletop exercises

for the 50-mile ingestion pathway exercises.

14. We revised the report to show that FEMA will continue to conduct

unannounced drills for a specific situation—a fast-breaking

emergency.

15. FEMA reiterated the information provided in the draft report. As a

result, we did not revise the report.

16. We revised the report as FEMA suggested.

17. We revised the report to include the information that FEMA suggested.

18. We revised the report as FEMA suggested.

19. We revised the report by adding "if necessary" as FEMA suggested.
Appendix X: Scope and Methodology

Page 56 GAO-01-605 Indian Point 2

To identify the emergency preparedness weaknesses at Indian Point 2 and

the actions that Consolidated Edison has taken to resolve the weaknesses

identified, we analyzed NRC’s inspection reports and met with NRC staff

in the Office of Nuclear Reactor Regulation and in Region I, King of

Prussia, Pennsylvania, which is responsible for overseeing Indian Point 2.

We also reviewed an August 2000 report by NRC’s Office of the Inspector

General, which discussed technical and emergency preparedness issues

related to Indian Point 2 since at least 1997. We analyzed NRC’s report on

its planned actions to address the issues raised in the Office of the

Inspector General's report. To put the weaknesses into perspective, we

reviewed the relevant NRC regulations, policies, and procedures related to

emergency preparedness and analyzed NRC’s information on the number

and types of emergencies that have occurred at nuclear power plants

nationwide since 1981. We also reviewed a March 2000 report by the New

York State Public Service Commission on the problems that occurred

during the February 2000 event at Indian Point 2. To determine the actions

that Consolidated Edison has taken to resolve the weaknesses identified,

we analyzed relevant condition reports, root cause analyses, and sections

of the 2000 and 2001 business plan concerning emergency preparedness

improvements at Indian Point 2. We met with the Vice President for

Engineering, Consolidated Edison, and the Chief Nuclear Officer and

Emergency Preparedness Manager for Indian Point 2 to determine the

company’s commitment to following through on the identified corrective

actions.

To determine the lessons learned from the emergency by the four Indian

Point counties, we reviewed a March 2000 report by the New York State

Public Service Commission on the problems that occurred during the

emergency. We met with officials from New York State and Westchester,

Putnam, Orange, and Rockland counties to obtain their perspective of the

response taken during the emergency. We determined whether the

response identified needed improvements in the counties' radiological

emergency plans and the status of their actions to address the

improvements identified. We also toured the state’s and Rockland, Orange,

and Putnam counties’ emergency operations centers.

To determine suggestions for improving NRC’s and FEMA’s radiological

emergency preparedness process beyond the actions already taken, we

met with New York State; Westchester, Putnam, Orange, and Rockland

county; and Consolidated Edison officials. We also met with FEMA

headquarters officials in the Radiological Emergency Preparedness Branch

and FEMA Region II in New York City and with NRC staff in the Office of

Nuclear Reactor Regulation, Office of Public Affairs, and Incident

Appendix X: Scope and Methodology
Appendix X: Scope and Methodology

Page 57 GAO-01-605 Indian Point 2

Response Operations Office, to obtain their views on the suggestions

offered. We also analyzed FEMA's documents related to its strategic

review and the resulting 34 initiatives, the status of the initiatives, and

FEMA’s proposal to implement a streamlined exercise process.

(360018)

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