Nuclear Regulation: Progress Made in Emergency Preparedness at Indian Point 2, but Additional Improvements Needed
Published: 2001-07-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Consolidated Edison Company shut down the Indian Point 2 commercial nuclear power plant in February 2000 because a tube had ruptured in a steam generator, raising the possibility that radioactively contaminated water could leak into the environment. In this case, the total amount of radioactivity released posed no threat because the amount of radioactivity released 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. This report reviews issues associated with emergency preparedness protocols associated with the plant.
section_title: What GAO Found
paragraphs: GAO found that a more proactive approach to correct recurring weaknesses could have improved the emergency preparedness plan during the February 2000 emergency. This emergency demonstrated the importance of effective, clear communication networks, both on-site regarding the need to ensure that pagers work well to notify key personnel of an emergency, as well as off-site, regarding communication about the extent and magnitude of the emergency. Exercises, although playing a valuable role in preparing for and assessing radiological emergency readiness, more than likely will not identify the human reactions and all communications issues that could arise in a real radiological emergency. In this regard the Nuclear Regulatory Commission's (NRC) and Federal Emergency Management Agency (FEMA) interact interactions 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 lack of knowledge by the four Indian Point counties 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.

section_title: Letter
paragraphs: 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. 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.
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.
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 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.
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 on- site 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.
section_title: Consolidated Edison Has Taken Actions to Resolve Emergency Preparedness Weaknesses, but More Needs to Be Done
paragraphs: 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.
subsections: section_title: Ineffective Corrective Actions Resulted in Repeat Inspection Findings Before the February 2000 Event
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 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 computer- based 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 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.
section_title: Consolidated Edison’s Actions to Resolve Identified Weaknesses Are Incomplete
paragraphs: 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 response to them.  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.
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 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.
section_title: The Four Counties Strengthened Their Emergency Preparedness Programs as a Result of the Lessons Learned From the February 2000 Event
paragraphs: 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 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.
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.
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.
section_title: Counties Suggest Better Communication Among NRC, FEMA, and Nonstate Entities With a Major Role in Radiological Emergency Preparedness
paragraphs: 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.
subsections: section_title: Increasing Public Confidence May Be Difficult When NRC Does Not Routinely Communicate With Those Responsible for Responding to Radiological Emergencies
paragraphs: 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. 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 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.
section_title: FEMA Has Not Effectively Communicated With New York Counties Responsible for Responding to Radiological Emergencies at Indian Point 2
paragraphs: 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 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.  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 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.
section_title: Conclusions
paragraphs: 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 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.
section_title: Recommendations for Executive Action
paragraphs: 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.
section_title: Agency Comments and Our Evaluation
paragraphs: 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.
section_title: Appendix I: Indian Point 2 Steam Generator
section_title: Appendix II: The Nuclear Regulatory Commission’s Emergency Action Levels and Conditions That Could Cause an Emergency
paragraphs: Appendix II: The Nuclear Regulatory Commission’s Emergency Action Levels and Conditions That Could Cause an Emergency Examples 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. 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. 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.
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. 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.
section_title: Appendix III: Description of NRC’s New Safety Oversight Process for Emergency Preparedness
paragraphs: 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. 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 off- site 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).
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-plan- implementing 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.
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— 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.
section_title: Appendix IV: Some Emergency Preparedness Issues Identified by NRC’s Office of the Inspector General
paragraphs: 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.
section_title: Appendix V: Emergency Preparedness Corrective Actions Initiated by Consolidated Edison Since the February 2000 Event
paragraphs: 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.
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 Issue new pagers to plant personnel. with information.
section_title: Appendix VI: County Officials’ Suggestions to Improve Radiological Emergency Preparedness and NRC’s/FEMA’s Responses
paragraphs: Appendix VI: County Officials’ Suggestions to Improve Radiological Emergency Preparedness and NRC’s/FEMA’s Responses NRC staff’s response 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 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 rule- making 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.
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. 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 response the alert level and less time at the general emergency level.
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.
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.
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. 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. 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.
NRC staff’s response 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’s response 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.
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.
section_title: Appendix VII: Initiatives to Streamline FEMA’s Radiological Emergency Preparedness Program and Their Status
paragraphs: 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.
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.
section_title: Appendix VIII: Comments From the Nuclear Regulatory Commission
paragraphs: The following are GAO’s comments on the Nuclear Regulatory Commission’s (NRC) letter dated July 13, 2001.
subsections: section_title: GAO’s Comments
paragraphs: 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 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 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.
section_title: Appendix IX: Comments From the Federal Emergency Management Agency
paragraphs: The following are GAO’s comments on the Federal Emergency Management Agency’s (FEMA) letter dated July 6, 2001.
subsections: section_title: GAO’s Comments
paragraphs: 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 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.
section_title: Appendix X: Scope and Methodology
paragraphs: 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.
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.