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. Over the years, NRC has identified a number of emergency preparedness weaknesses at Indian Point 2 that have gone largely uncorrected and made Consolidated Edison’s response during the February 2000 event less than satisfactory. For example, in 1998 and again in 1999, NRC identified several communication weaknesses, including delays in activating the pagers used to alert the utility’s staff about an emergency. In evaluating Consolidated Edison’s response to the emergency, NRC found that the notification of critical personnel was delayed, which delayed the staffing and operation of the on-site emergency response facility. This occurred because the process to activate the pagers was complex and not well understood. Consolidated Edison already had actions under way to correct emergency preparedness weaknesses before the February 2000 event and initiated others to address the problems that occurred during it. However, these efforts have been ineffective and incomplete. As a result, in an April 2001 inspection report, NRC identified emergency preparedness weaknesses similar to those that occurred before and during the February 2000 event. Beginning in 1996, NRC identified numerous weaknesses with the emergency preparedness program at Indian Point 2. NRC found, for example, that Consolidated Edison was not training its emergency response staff in accordance with procedures and some individuals had not taken the annual examination and/or participated in a drill or exercise in a 2-year period as required. In response, Consolidated Edison disciplined the individuals responsible, developed an improved 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. 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.