Nuclear Regulation: Emergency Preparedness Issues at the Indian Point 2 Nuclear Power Plant
Published: 2003-03-10T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: After the September 11, 2001, terrorist attacks, emergency preparedness at nuclear power plants has become of heightened concern. Currently, 104 commercial nuclear power plants operate at 64 sites in 32 states and provide about 20 percent of the nation's electricity. In July 2001, GAO reported on emergency preparedness at the Indian Point 2 nuclear power plant in New York State. This testimony discusses GAO's findings and recommendations in that report and the progress the plant, the Nuclear Regulatory Commission (NRC), and the Federal Emergency Management Agency (FEMA) have made in addressing these problems. GAO also provides its thoughts on the findings of a soon-to-be-issued report (the Witt report) on emergency preparedness at Indian Point and the Millstone nuclear power plant in Connecticut, and the implications of that report for plants nationwide. Since 2001, the Entergy Corporation has assumed ownership of the Indian Point 2 plant from the Consolidated Edison Company of New York (ConEd).
section_title: What GAO Found
paragraphs: In 2001, GAO reported that, over the years, NRC had identified a number of emergency preparedness weaknesses at Indian Point 2 that had gone largely uncorrected. ConEd had some corrective actions underway before a 2000 event raised the possibility of a leak of radioactively contaminated water into the environment. ConEd took other actions to address problems during this event. According to NRC, more than a year later, the plant still had problems similar to those previously identified--particularly in the pager system for activating emergency personnel. However, NRC, in commenting on a draft of GAO's report, stated that ConEd's emergency preparedness program could protect the public. Four counties responsible for responding to a radiological emergency at Indian Point 2 had, with the state and ConEd, developed a new form to better document the nature and seriousness of any radioactive release and thus avoid the confusion that occurred during the February 2000 event. Because they are the first responders in any radiological emergency, county officials wanted NRC and FEMA to communicate more with them in nonemergency situations, in addition to communicating through the states. However, NRC and FEMA primarily rely on the states to communicate with local jurisdictions. Since GAO's 2001 report, NRC has found that emergency preparedness weaknesses have continued. For example, NRC reported that, during an emergency exercise in the fall of 2002, the facility gave out unclear information about the release of radioactive materials, which had also happened during the February 2000 event. Similarly, in terms of communicating with the surrounding jurisdictions, little has changed, according to county officials. County officials told GAO that a videoconference system--promised to ensure prompt meetings and better communication between the plant's technical representatives and the counties--had not been installed. In addition, NRC and FEMA continue to work primarily with the states in nonemergency situations. Although they note that there are avenues for public participation, none of these is exclusively for the county governments. GAO did not evaluate the draft Witt report or verify the accuracy of its findings. The draft Witt report is a much larger, more technical assessment than the 2001 GAO report. While both reports point out difficulties in communications and planning inadequacies, the draft Witt report concludes that the current radiological response system and capabilities are not adequate to protect the public from an unacceptable dose of radiation in the event of a release from Indian Point, especially if the release is faster or larger than the release for which the programs are typically designed. GAO is aware that, in commenting on a draft of the Witt report, FEMA disagreed with some of the issues raised but said the report highlights several issues worth considering to improve emergency preparedness in the communities around Indian Point and nationwide. NRC concluded that the draft report gives "undue weight" to the impact of a terrorist attack.

section_title: Letter
paragraphs: We are pleased to be here today to discuss emergency preparedness at  operating commercial nuclear power plants. Twenty-four years ago, in  March 1979, the accident at the Three Mile Island nuclear power plant in  Pennsylvania created considerable alarm and uncertainty in the  surrounding areas about the plant’s safety and the adequacy of emergency  planning. On the broader front, the American public focused not only on  Three Mile Island but also on safety and emergency preparedness at  nuclear power plants nationwide. With the September 11, 2001, terrorist  attacks, public concern about the plants has increased again. Concerns  have focused principally on ensuring the plants’ physical security and then  on emergency preparedness in case terrorists are successful in their  attacks. The nation currently has 104 commercial nuclear power plants  licensed to operate at 64 sites in 32 states. These plants provide about 20  percent of the nation’s electricity.
To protect the public should a commercial nuclear power plant  accidentally release radiation to the environment, the Nuclear Regulatory  Commission (NRC) requires the plant owner/operator to prepare for  NRC’s approval a radiological emergency preparedness plan. This 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 operator’s own personnel as well as  with federal, state, and local agencies and the media during an emergency.  The plan also identifies the circumstances and the actions—such as  evacuating the local population—the plant owner would recommend that  off-site officials take to protect the public. NRC conducts inspections to  ensure that the plant owner can effectively implement the on-site plan. 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 effects of a  radiological emergency. FEMA oversees the conduct of periodic exercises  to determine whether the off-site response would adequately protect  public health and safety.
My testimony today is grounded in a report we issued in July 2001 to the  Chairman of the House Committee on Government Reform and to  Representatives Gilman, Kelly, and Lowey on emergency preparedness at  the Indian Point 2 plant in New York State. The Indian Point facility is  located within the Village of Buchanan in upper Westchester County,  approximately 24 miles north of New York City along the east bank of the  Hudson River. About 300,000 people live within 10 miles of the plant and  millions more live in New York City and within 50 miles in Connecticut,  New Jersey, New York, and Pennsylvania. Concerns that nuclear power  plants may be targets for terrorists and Indian Point’s close proximity to  these large populations have increased public interest in the adequacy of  the plant’s security and emergency preparedness—leading some to call for  closing the plant. A draft report (the Witt report) commissioned by the  Governor of New York questions the adequacy of emergency preparedness  at Indian Point and raises broader issues about emergency preparedness at  other nuclear power plants.
In my testimony today, I will discuss the (1) findings and  recommendations of our 2001 report on emergency preparedness at the  Indian Point 2 plant and (2) subsequent progress made by the plant, NRC,  and FEMA in addressing problems noted in our report. You also asked for  our thoughts on the findings of the draft Witt report and its potential  implications for emergency planning at other facilities. To follow up on the  progress made to address the problems we identified in 2001, we reviewed  relevant NRC inspection reports prepared since our 2001 report and held  discussions with officials of NRC, FEMA, and the four counties  responsible for emergency preparedness in the surrounding areas. We did  not conduct a comprehensive update of emergency preparedness at the  Indian Point 2 plant nor verify the accuracy of the draft Witt report’s  findings and conclusions. We should also note that, since our 2001 report,  the Entergy Corporation has assumed ownership of the facility from the  Consolidated Edison Company of New York.
In 2001, we reported that, 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 plant’s staff about an emergency.  Consolidated Edison had some corrective actions under way before a  February 2000 event raised the possibility that radioactively  contaminated water would leak into the environment. Consolidated  Edison initiated other actions to address problems that occurred  during this event. However, according to an April 2001 NRC inspection  report, the actions were not fully effective. In evaluating Consolidated  Edison’s response to the February 2000 event, NRC found that critical  emergency response personnel were not notified in a timely manner,  which delayed the staffing and operation of the on-site emergency  response facility. According to NRC, this delay occurred because the  process to activate the pagers was complex and not well understood  and Consolidated Edison had responded to the earlier problems  identified without diagnosing their underlying causes. As a result, NRC  found emergency preparedness problems similar to those it had  identified before and during the event. Despite these weaknesses, NRC,  in commenting on a draft of our report, expressed its view that  Consolidated Edison’s emergency preparedness program could protect  the public.
We reported in 2001 that the four New York counties responsible for  responding to a radiological emergency at Indian Point 2 had  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 and communications (1) between the  counties in responding to a radiological emergency and in providing  the media with information and (2) between Consolidated Edison and  the counties about the emergency and its potential impact on the  public. We reported that Consolidated Edison had not clearly  communicated with the state and counties about whether a radioactive  release had occurred and, if so, its magnitude. Consolidated Edison  reported that a release had occurred but posed no threat to the public,  while county officials reported that no release had occurred. This  contradictory information led to credibility problems with the media  and the public. Consolidated Edison, the state, and the counties revised  the plant’s radiological emergency data form to more clearly show  whether a release had occurred.
As we also reported, county officials suggested changes to 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 operating nuclear power plants are located—counties or  other local governments are responsible for radiological preparedness,  but NRC and FEMA communicated primarily with the states and relied  on the states to communicate with local jurisdictions. In response, NRC  said that meeting with local officials would require considerable  resources, and FEMA said that some states limit its communications  with local officials. However, NRC had not assessed the costs and  benefits of routinely meeting with local officials, and FEMA’s method  of communicating with the states had not effectively provided the four  counties with information on various initiatives that would affect their  programs. Since effective communication is critical to prepare for and  respond to a radiological emergency, we therefore recommended 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.
Since our 2001 report, NRC inspection reports have continued to show  emergency preparedness weaknesses. For example, NRC reported that,  during an emergency exercise in the fall of 2002, the facility gave out  unclear information about the release of radioactive materials, as it did  during the February 2000 event. Similarly, in terms of NRC and FEMA  communicating with the surrounding jurisdictions, little has changed,  according to county officials. County officials told us that a  videoconference system—promised to ensure prompt meetings and  better communication between the plant’s technical representatives  and the counties—had not been installed. During the February 2000  event, these representatives had arrived late at the counties’ emergency  operations centers. NRC officials said that they meet with state  officials concerning emergency preparedness and have instituted  various initiatives to improve public communication, in which local  officials can participate. FEMA officials told us that it would continue  to work with state and local governments on emergency preparedness.
The draft Witt report is a much larger, more technical assessment than  our 2001 report. While both reports talk to difficulties in  communications and planning inadequacies, the draft Witt report  concludes that the current radiological response system and  capabilities are not adequate to protect the public from an  unacceptable dose of radiation in the event of a release from Indian  Point, especially if the release is faster or larger than the release for  which the programs are typically designed. We are aware that, in  commenting on the draft of the Witt report, FEMA disagreed with some  of the issues raised but said that the report does highlight several  issues worth considering in order to improve preparedness levels in the  communities around Indian Point and nationwide. NRC concluded that  the report gives “undue weight” to the impact of a terrorist attack. The  agency said that it saw no difference between emergency plans for  releases caused by terrorist acts and those caused by equipment  malfunctions.
subsections: section_title: Background
paragraphs: 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 1979 accident at the Three  Mile Island nuclear power plant, 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 is 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 facility plan that provides reasonable assurance that  public health and safety are 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  emergency standards for on- and off-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 must address  measures necessary to deal with the potential for the ingestion of  radioactively contaminated foods and water within a 50-mile radius. NRC  and FEMA have supplemented the criteria several times since 1980. For  example in July 1996, 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.
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 within the 50-mile zone at least every 6  years. The exercises are to test the integrated capabilities of appropriate  state and local government agencies, facility emergency personnel, and  others to verify their capability to mobilize and respond if an accident  occurs. 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  plants to conduct exercises of their on-site plans. According to NRC staff,  the plants usually conduct their exercises as part of FEMA’s biennial  exercises.
Indian Point 2 is one of the 104 commercial nuclear power plants  nationwide licensed to operate. The Indian Point site, which is called the  Indian Point Energy Center, has one closed and two operating plants. The  other operating plant is referred to as Indian Point 3.
section_title: In 2001, We Noted That Indian Point 2 Had Struggled to Resolve Emergency Preparedness Weaknesses
paragraphs: Over the years, Consolidated Edison’s efforts to improve emergency  preparedness at Indian Point 2 were not completely successful, and the  company experienced recurring weaknesses in its program, as we  reported in July 2001. The four New York counties surrounding the plant  made improvements in their emergency response programs but suggested  better communication among NRC, FEMA, and nonstate entities in  nonemergency situations.
subsections: section_title: Consolidated Edison Acted to Resolve Emergency Preparedness Weaknesses, but Its Actions Were Incomplete
paragraphs: 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 required procedures, and some  individuals had not taken the annual examination and/or participated in a  drill or exercise within a 2-year period, as required. In response,  Consolidated Edison disciplined the individuals responsible, developed an  improved computer-based roster containing the current status of the  training requirements for emergency response personnel, and began a  process to distribute training modules to those employees before their  qualifications expired.
NRC relied on Consolidated Edison to take corrective actions for other  emergency preparedness problems and weaknesses. However, the  company 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 plant’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 the company’s  managers to specifically discuss and express NRC’s concerns.
Similarly, NRC identified emergency preparedness weaknesses when  evaluating Indian Point 2’s response to the February 2000 event. For  example, NRC found that Consolidated Edison did not activate its  emergency operations facilities within the required 60 minutes, primarily  because of the complex process used to page the emergency response  staff. This problem delayed the on-site response. NRC’s Office of the  Inspector General also identified emergency preparedness issues,  including the state’s difficulties getting information about the emergency  from Consolidated Edison and the fact that English is a second language  for many who lived within 10 miles of the plant. The Office of the  Inspector General concluded, and NRC agreed, that recurring uncorrected  weaknesses at Indian Point 2 had played a role in the company’s response  during the February 2000 event. However, NRC concluded that  Consolidated Edison had taken the necessary steps to protect public  health and safety.
Consolidated Edison subsequently evaluated its entire emergency  preparedness program to determine the causes of the deficiencies and to  develop corrective actions. Consolidated Edison concluded that senior  management did not pay sufficient attention to the emergency  preparedness program or problems at Indian Point 2 because these  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 time, a contractor held the manager’s position. Furthermore, the  professional development and continuing training of the emergency  planning staff had been minimal. The company undertook initiatives to  address the deficiencies noted.
Despite these initiatives, in April 2001, NRC reported that it had found  problems similar to those previously identified at Indian Point 2. NRC  again found weaknesses in communication and information dissemination.  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 plan,  which, if properly implemented, should improve emergency preparedness  at the plant. In commenting on a draft of our July 2001 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.
section_title: The Four Counties Strengthened Their Emergency Preparedness Programs but Suggested Better Communication Among NRC, FEMA, and Nonstate Entities
paragraphs: The need to improve communication between Consolidated Edison and  the counties about the extent of the emergency and the potential impact  on the public was highlighted during the February 2000 event. At that time,  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.
Before the emergency, the counties did not have a defined process to  determine what information they needed and how they would present the  information to the public. At the time of the February 2000 event, the  Radiological Emergency Data Form that Consolidated Edison used to  inform local jurisdictions provided for one of three choices about a release  of radioactive materials: (1) no release (above technical specification  limits), (2) a release to the atmosphere above technical specification  limits, and (3) a release to a body of water (above technical specification  limits). In April 2000, Consolidated Edison, in partnership with the state  and counties, revised the form to ensure that all affected parties were  “speaking with one voice” when providing the media and the public with  information. The change to the form provided for one of four choices: (1)  no release, (2) a release below federally approved operating limits  (technical specifications) and whether it was to the atmosphere or to  water, (3) a release above federally approved operating limits and whether  to the atmosphere or to water, and (4) an unmonitored release requiring  evaluation.
The counties had also taken some other actions to improve their  radiological emergency programs. For example, all four counties agreed to  activate their emergency operation centers at the “alert” level (the second  lowest of four NRC classifications). Before the February 2000 event, the  counties differed on when they would activate their centers, with one  county activating its center at the alert level and the other three counties  at the site-area emergency level (the next level above an alert). As a result,  once the first county activated its center during the event, the media  questioned why the other three counties had not done so. The counties  also connected the “Executive Hot Line,” which linked the state, four  counties, and governor, to the emergency operations facility at Indian  Point 2 to establish and maintain real-time communications during an  emergency.
In addition to these actions, county officials suggested to us in 2001 that  other changes to improve communications among NRC, FEMA, and  nonstate entities could be taken. 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. Absent these direct communications, the  counties were not privy to issues or initiatives that could affect their  emergency preparedness programs.
NRC staff tried to meet every 5 years with officials from all states that  have operating nuclear power plants. NRC staff told us that they met with  some states more frequently and that the requests to meet exceeded the  agency’s capability. Although NRC’s policy was to meet at the state level,  its staff believed that local officials had various options for meeting with  NRC. For example, local officials could participate in the meetings held at  least every 5 years with the states and could interact with NRC staff during  public meetings, including those held annually for all plants. Emergency  preparedness officials from the four counties around Indian Point 2 said  that they did not believe that public meetings were the appropriate forums  for government-to-government interactions. Therefore, the counties  suggested that NRC should meet with them at least annually. According to  NRC staff, routinely communicating with local officials has resource  implications and involves tradeoffs with its other efforts, such as  maintaining safety and enhancing the effectiveness and efficiency of  operations. However, NRC, at the time of our review, had not assessed the  costs and benefits of meeting with local officials nor the impact that such  meetings might have.
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 instances in which this method of communicating with local  jurisdictions had 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. County officials said they  responded to the 2000 event as they would have responded during FEMA’s  exercises, which are conducted to the general emergency level (the  highest of NRC’s action level classifications). Yet, they noted, the response  for an alert like the one that occurred in 2000 is significantly different from  the response needed during a general emergency, when a significant  amount of radiation would be released from the plant site. State and  county officials suggested that it would be more realistic to periodically  conduct biennial exercises at the lower alert level, which, they noted (and  NRC data confirmed), occur more frequently than a general emergency. In  commenting on a draft of our 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.
FEMA officials also noted that the agency’s regulations allow state and  local jurisdictions the flexibility to structure the exercise scenarios to  spend more time at the alert level and less at the general emergency level.  Nevertheless, county officials who participated in the exercises were not  aware of the flexibility allowed by FEMA’s regulations, in part because  they did not participate in developing the exercise scenarios.
section_title: Emergency Preparedness Weaknesses at Indian Point 2 Have Continued
paragraphs: In reviewing NRC’s reports on its on-site inspections and evaluations of  the plant’s emergency preparedness exercises or drills completed since we  issued our 2001 report, we found that the facility’s emergency  preparedness program has continued to experience problems or  weaknesses. For example, NRC reported that, in an emergency exercise  conducted last fall, the facility gave out unclear information about the  release of radioactive materials, which also happened during the February  2000 event. In addition, NRC reported that several actions to correct  previously identified weaknesses had not been completed. For example,  NRC noted that the timely and accurate dissemination of information was  identified as a weakness in the fall 2002 exercise and had been  documented previously in drill critique and condition reports.
In addition, in our 2001 report, we noted that NRC’s Office of the Inspector  General found that, during the February 2000 event, the Indian Point  plant’s technical representatives did not arrive on time at the local  counties’ emergency operations centers. To help address this problem,  Consolidated Edison said that it would install a videoconferencing system  in the centers to enhance communications between the plant and the off- site officials. According to county officials, the videoconferencing system  had not been installed as of February 2003.
With respect to our 2001 recommendation that NRC and FEMA reassess  their practices of primarily communicating with state officials during  nonemergency situations, federal and local officials indicated that little  has changed since our report. NRC officials told us that they did reassess  their policy since our report was issued and determined that no changes  were needed. According to FEMA officials, the agency will continue to  work with state and local officials to carry out its emergency preparedness  program but has not made any changes regarding nonemergency  communication with state and local officials.
Given this history of inadequate efforts to address weaknesses in Indian  Point 2’s emergency preparedness program, we continue to believe that  both NRC and the plant owner could benefit from being more vigilant in  correcting problems as they are identified. In addition to improving the  plant’s program, a better track record in addressing these problems could  go a long way in helping alleviate the heightened concerns in the  surrounding communities about the plant’s safety and preparedness for an  emergency. Similarly, more frequent, direct communication by NRC and  FEMA with officials of the surrounding counties could improve local  emergency preparedness programs and, in turn, help local officials better  communicate with their constituents about the plant’s safety and  preparedness for an emergency.
section_title: The Witt Report Raises Emergency Preparedness Issues at Indian Point and Other Nuclear Power Plants
paragraphs: On August 1, 2002, the Governor of New York announced that James Lee  Witt Associates would conduct a comprehensive and independent review  of emergency preparedness around the Indian Point facility and for that  portion of New York State in proximity to the Millstone nuclear power  plant in Waterford, Connecticut. According to Witt Associates, the review  encompassed many related activities that were designed, when taken  together, to shed light on whether the jurisdictions’ existing plans and  capabilities are sufficient to ensure the safety of the people of the state in  the event of an accident at one of the plants, and how the existing plans  and capabilities might be improved. According to Witt Associates, it has  considered and incorporated public comments on a January 2003 draft of  its report and plans to issue the final report this month.
We have not evaluated the Witt report or verified the accuracy of its  findings and conclusions. We did note that the draft report identifies  various issues—such as planning inadequacies; expected parental  behavior that would compromise school evacuation; difficulties in  communications; the use of outdated technologies; problems caused by  spontaneous evacuation in a post September 11, 2001, environment; and a  limited public education effort—that may warrant consideration at Indian  Point and nationwide. The draft Witt report concludes that NRC and  FEMA regulations need to be revised and updated. We understand that  FEMA agreed, to an extent, in its review of the draft report. According to  the agency, the draft report raises a number of issues that should be  considered for enhancing the level of preparedness in the communities  surrounding the Indian Point facility, such as better public education,  more training of off-site responders, and improved emergency  communications. In addition, FEMA stated that some of these issues  should be evaluated for their applicability nationwide. However, FEMA  also said that a number of the issues raised in the draft report were not  supported by its own exercise evaluations, plan reviews, and knowledge of  the emergency preparedness program. According to NRC, the draft report  gives “undue weight” to the impact of a terrorist attack. The agency said  that it saw no difference between emergency plans for releases caused by  terrorist acts and those caused by equipment malfunctions.