    Nuclear Regulation: Progress Made in Emergency Preparedness at
    Indian Point 2, but Additional Improvements Needed (30-JUL-01,
    GAO-01-605).

    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 since 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. 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, while 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.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-01-605
        ACCNO:   A01246
      TITLE:     Nuclear Regulation: Progress Made in Emergency
                 Preparedness at Indian Point 2, but Additional Improvements
                 Needed
         DATE:   07/30/2001
      SUBJECT:   Electric utilities
    	     Emergency preparedness
    	     Federal/state relations
    	     Intergovernmental relations
    	     Nuclear powerplants
    	     Radioactive pollution
    	     Safety regulation
    	     Indian Point Nuclear Power Plant (NY)

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    GAO-01-605

    Report to Congressional Requesters

    United States General Accounting Office

    GAO

    July 2001 NUCLEAR REGULATION

    Progress Made in Emergency Preparedness at Indian Point 2, but Additional
    Improvements Needed

    GAO- 01- 605

    Page i GAO- 01- 605 Indian Point 2 Letter 1

    Results in Brief 2 Background 4 Consolidated Edison Has Taken Actions to
    Resolve Emergency

    Preparedness Weaknesses, but More Needs to Be Done 7 The Four Counties
    Strengthened Their Emergency Preparedness

    Programs as a Result of the Lessons Learned From the February 2000 Event 11
    Counties Suggest Better Communication Among NRC, FEMA, and

    Nonstate Entities With a Major Role in Radiological Emergency Preparedness
    13 Conclusions 17 Recommendations for Executive Action 18 Agency Comments
    and Our Evaluation 19

    Appendix I Indian Point 2 Steam Generator 22

    Appendix II The Nuclear Regulatory Commission?s Emergency Action Levels and
    Conditions That Could Cause an Emergency 23

    Appendix III Description of NRC?s New Safety Oversight Process for Emergency
    Preparedness 24

    Appendix IV Some Emergency Preparedness Issues Identified by NRC?s Office of
    the Inspector General 27

    Appendix V Emergency Preparedness Corrective Actions Initiated by
    Consolidated Edison Since the February 2000 Event 28 Contents

    Page ii GAO- 01- 605 Indian Point 2 Appendix VI County Officials?
    Suggestions to Improve

    Radiological Emergency Preparedness and NRC?s/ FEMA?s Responses 29

    Appendix VII Initiatives to Streamline FEMA?s Radiological Emergency
    Preparedness Program and Their Status 32

    Appendix VIII Comments From the Nuclear Regulatory Commission 35

    Appendix IX Comments From the Federal Emergency Management Agency 47

    Appendix X Scope and Methodology 56

    Tables

    Table 1: Selected Emergency Preparedness Weaknesses That Occurred During the
    February 2000 Event and the Corrective Actions Taken by Consolidated Edison
    9 Table 2: The Nuclear Regulatory Commission?s Emergency Action

    Levels and Some Examples of Nuclear Power Plant Conditions That Could Cause
    an Emergency 23 Table 3: Performance Indicator Data Through March 2001 25
    Table 4: Suggestions Made by County Officials to Improve

    Radiological Emergency Preparedness and NRC?s and FEMA?s Responses 29 Table
    5: FEMA?s Initiatives and Their Status 32

    Figures

    Figure 1: 10- and 50- Mile Emergency Planning Zones for Indian Point 2 6

    Page iii GAO- 01- 605 Indian Point 2

    Figure 2: Comparison of the Relevant Section of the Radiological Emergency
    Data Form During and After the Event 12 Figure 3: Indian Point 2 Steam
    Generator in Relation to Other Plant

    Equipment and the Locations Where a Leak Could Release Radioactive Material
    to the Environment 22

    Abbreviations

    FEMA Federal Emergency Management Agency NRC Nuclear Regulatory Commission

    Page 1 GAO- 01- 605 Indian Point 2

    July 30, 2001 Congressional Requesters In February 2000, Consolidated Edison
    Company shut down the Indian Point 2 commercial nuclear power plant in New
    York State because a tube had ruptured in a steam generator, raising the
    possibility that radioactively contaminated water could leak into the
    environment. 1 In this particular instance, the total amount of
    radioactivity released posed no threat: It was about one thousandth of the
    dose an individual receives from a chest X- ray. However, in the event of a
    more serious emergency at Indian Point 2, protecting the public from a
    radioactive release presents more substantial challenges because the plant
    is located in a heavily populated area. More than 280,000 people reside
    within 10 miles of the plant in four counties; millions more live in New
    York City- about 25 miles distant- and within 50 miles in Connecticut, New
    Jersey, New York, and Pennsylvania. Other commercial nuclear power plants
    are generally located in less- populated areas.

    To protect the public if a commercial nuclear power plant accidentally
    releases radiation to the environment, the responsible regulatory agency,
    the Nuclear Regulatory Commission (NRC), requires the utility to prepare and
    NRC to approve a radiological emergency preparedness plan. The on- site plan
    describes what is to be done in an emergency, how it is to be done, and who
    is to do it. Among other things, the plan identifies the process for
    notifying and communicating with the utility?s own personnel as well as with
    state, federal, and local agencies and the media during an emergency. The
    plan also identifies the circumstances and actions, such as providing
    shelter or evacuating the local population, the utility would recommend that
    off- site officials take to protect the public. NRC conducts inspections to
    ensure that the utility can effectively implement the on- site plan.

    1 Steam generators are one of two major systems used to convert heat into
    electrical power for industrial and residential use. Heat from the plant?s
    fuel is transferred through pipes to the steam generator. The steam produced
    by the generator is transferred to the turbines, where it is converted into
    electricity. App. I shows one of the four steam generators in relation to
    other systems within a plant and the locations where a leak could release
    radioactive material to the environment.

    United States General Accounting Office Washington, DC 20548

    Page 2 GAO- 01- 605 Indian Point 2

    In addition, the Federal Emergency Management Agency (FEMA) is responsible
    for ensuring that state and local communities develop emergency preparedness
    plans to address the off- site impacts of a nuclear emergency. FEMA also
    oversees the conduct of periodic exercises to determine whether the off-
    site response would adequately protect public health and safety. In New York
    State, the counties are responsible for protecting public health and safety
    during a natural, radiological, or other disaster, except when the governor
    declares a state of emergency. The four counties that have major
    responsibilities for responding to an emergency at Indian Point 2 are
    Westchester, Rockland, Putnam, and Orange. Because of the number of parties
    involved both on- and off- site, good communication is essential to prepare
    for and respond to a radiological emergency.

    Concerned about the safety of the communities near Indian Point 2, you asked
    us to examine the emergency preparedness issues associated with the plant.
    Specifically, this report describes the (1) emergency preparedness
    weaknesses at the plant and the actions that Consolidated Edison has taken
    to resolve them, (2) lessons learned by the four Indian Point counties from
    the February 2000 event, and (3) suggestions offered by the counties to
    improve the radiological emergency preparedness process beyond the actions
    already taken.

    Over the years, NRC had identified a number of emergency preparedness
    weaknesses at Indian Point 2 that had gone largely uncorrected. For example,
    in 1998 and again in 1999, NRC identified several communication weaknesses,
    including delays in activating the pagers used to alert the utility?s staff
    about an emergency. Consolidated Edison had some actions under way to
    correct emergency preparedness weaknesses before the February 2000 event and
    initiated others to address the problems that occurred during it. However,
    according to an April 2001 NRC inspection report, the actions had not been
    fully effective. With respect to the aforementioned communications
    weaknesses in particular, in evaluating Consolidated Edison?s response to
    the February 2000 emergency, NRC found that critical personnel were not
    notified in a timely fashion, which delayed the staffing and operation of
    the on- site emergency response facility. NRC found that this occurred
    because the process to activate the pagers was complex and not well
    understood and that Consolidated Edison had acted without diagnosing the
    underlying causes of the problems. As a result, NRC found emergency
    preparedness problems similar to those it had identified before and during
    the February 2000 event. Despite the weaknesses identified, in commenting on
    a draft of this Results in Brief

    Page 3 GAO- 01- 605 Indian Point 2

    report, NRC noted that Consolidated Edison's emergency preparedness program
    could protect the public.

    The four counties in New York State that are responsible for responding to a
    radiological emergency at Indian Point 2 have strengthened their emergency
    preparedness programs as a result of the lessons learned from the February
    2000 event. These lessons included the need for better coordination between
    the counties in responding to a radiological emergency and in providing the
    media with information. Another important lesson learned was the need to
    improve communication during an emergency between Consolidated Edison and
    the counties about the extent of the problems and their potential impact on
    the public. This lesson resulted in one important change to improve
    communications among the state, counties, and Consolidated Edison. In
    partnership, they revised the form that Consolidated Edison used to provide
    information on whether radiation was released from the plant. Although the
    February 2000 event posed no danger to the public, Consolidated Edison had
    not clearly communicated with the state and counties about whether a
    radioactive release had occurred and its magnitude. Consolidated Edison
    reported that a radioactive release had occurred but that this release posed
    no danger to the public; county officials reported that no release had
    occurred. This contradictory information led to credibility problems with
    the media and the public. The form now clearly shows whether a release has
    occurred.

    Beyond the actions already taken by Consolidated Edison and the counties to
    improve their emergency response programs, county officials suggested
    changes that would improve communications among NRC, FEMA, and nonstate
    entities. In particular, county officials said that since they are
    responsible for radiological emergency preparedness for Indian Point 2, NRC
    and FEMA should communicate directly with them during nonemergency
    situations. In New York and 16 other states- where more than half of the
    nation?s 103 operating nuclear power plants are located- counties or other
    local governments are responsible for radiological preparedness, but NRC and
    FEMA communicate primarily with the states and rely on the states to
    communicate with local jurisdictions. In response to the counties?
    suggestion, NRC said that meeting with local officials would be resource
    intensive, and FEMA said that some states limit it from communicating with
    local officials. However, NRC has not assessed the costs and benefits of
    routinely meeting with local officials, and FEMA's method of communicating
    with the states has not been effective in providing the four counties with
    information on various initiatives that will affect their radiological
    emergency preparedness programs. Given that

    Page 4 GAO- 01- 605 Indian Point 2

    effective communication is critical to prepare for and respond to a
    radiological emergency, we are recommending that NRC and FEMA reassess their
    policies for communicating primarily with the state in those instances where
    other entities have a major role for responding to a radiological emergency.
    In commenting on a draft of this report, NRC said that it did not have the
    resources to routinely communicate with 160 counties, and FEMA said that it
    expects to increase its interactions with local officials in the coming
    years.

    Emergency plans for commercial nuclear power plants are intended to protect
    public health and safety whenever plant accidents cause radiation to be
    released to the environment. Since the March 1979 accident at the Three Mile
    Island nuclear power plant in Pennsylvania, significantly more attention has
    been focused on emergency preparedness. For example, the NRC Authorization
    Act for Fiscal Year 1980 established a requirement for off- site emergency
    planning around nuclear power plants and allowed NRC to issue a nuclear
    plant operating license only if it determines that there exists either a

    related state or local emergency preparedness plan that provides for
    responding to accidents at the specific plant and complies with NRC?s
    emergency planning guidelines or

    state, local, or utility plan that provides reasonable assurance that public
    health and safety is not endangered by the plants? operation in the absence
    of a related state or local emergency preparedness plan.

    In November 1980, NRC and FEMA published regulations that provided the
    criteria for radiological emergency plans. The regulations include 16
    emergency standards- 15 related to both on- and off- site safety and 1
    related solely to on- site safety- and require that emergency plans be
    prepared to cover the population within a 10- mile radius of a commercial
    nuclear power plant. In addition, state plans are required to address
    measures necessary to deal with the potential for the ingestion of
    radioactively contaminated foods and water out to a radius of 50 miles. The
    10- mile and 50- mile radii are called ?emergency planning zones.? NRC and
    FEMA have supplemented the criteria several times since November 1980, most
    recently in July 1996 when the agencies endorsed the prompt evacuation of
    the public within a 2- mile radius and about 5 miles downwind of the plant,
    rather than sheltering the public, in the event of a severe accident.
    Background

    Page 5 GAO- 01- 605 Indian Point 2

    NRC has established four emergency classification levels in order of
    increasing concern- unusual events, alerts, site- area emergencies, and
    general emergencies. A "general emergency" involves the actual or imminent
    substantial degradation of the plant with the potential for a significant
    release of radiation to the environment. The emergency at Indian Point 2 was
    an ?alert,? which is a low- level event that poses no threat to public
    health and safety. Appendix II describes the emergency action levels and
    provides examples of plant conditions that could lead to an emergency. Since
    1981, NRC?s data show that utilities reported at least 2,500 unusual events,
    140 alerts, 6 site- area emergencies, and no general emergencies.

    FEMA and the affected state and local governments within the 10- mile
    emergency planning zone conduct exercises at least every 2 years at each
    nuclear power plant site. In addition, each state with a nuclear power plant
    must conduct an exercise at least every 6 years within the 50- mile zone.
    The Indian Point site has two operating plants with different licensees-
    Consolidated Edison and Entergy. As a result, the practice has been to
    alternate the off- site biennial exercises between the two plants.
    Therefore, FEMA conducts an off- site exercise for Indian Point 2 every 4
    years. Later this year, Entergy expects to assume ownership of Indian Point
    2. Under federal regulations, each licensee must participate in a biennial
    off- site exercise every 2 years. Since Entergy would own both plants on the
    site once NRC approves the transfer, NRC said that the practice of
    alternating the off- site exercises will not be necessary.

    The state of New York has three nuclear power plant sites, and FEMA conducts
    a 50- mile exercise at one of the three sites every 6 years. Therefore, FEMA
    would conduct a 50- mile exercise for the Indian Point site only once every
    18 years. The purpose of the exercises is to test the integrated
    capabilities of appropriate state and local government agencies, utility
    emergency personnel, and others to verify their capability to mobilize and
    respond if an accident occurred. Before the exercises, generally, FEMA and
    state officials not involved in them agree to the accident scenarios and the
    aspects of emergency preparedness that will be tested.

    In addition, NRC requires utilities to conduct exercises of the plant?s
    onsite plan during the interval between the biennial exercises. According to
    NRC staff, the utilities usually conduct their exercises as part of FEMA?s
    biennial exercises. Figure 1 shows the 10- and 50- mile emergency planning
    zones for Indian Point 2.

    Page 6 GAO- 01- 605 Indian Point 2

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

    Note: The U. S. Military Academy at West Point, with a resident population
    of about 9,000, is located within the 10- mile emergency planning zone in
    Orange County. Since the Academy is a Department of Defense facility, it is
    exempt from state and local emergency planning requirements. However, the
    Academy is connected to the emergency communication system that links Indian
    Point 2 with state and local officials.

    Source: Developed by GAO from maps obtained from Consolidated Edison.

    Page 7 GAO- 01- 605 Indian Point 2

    Over the years, NRC has identified a number of emergency preparedness
    weaknesses at Indian Point 2 that have gone largely uncorrected and made
    Consolidated Edison?s response during the February 2000 event less than
    satisfactory. For example, in 1998 and again in 1999, NRC identified several
    communication weaknesses, including delays in activating the pagers used to
    alert the utility?s staff about an emergency. In evaluating Consolidated
    Edison?s response to the emergency, NRC found that the notification of
    critical personnel was delayed, which delayed the staffing and operation of
    the on- site emergency response facility. This occurred because the process
    to activate the pagers was complex and not well understood. Consolidated
    Edison already had actions under way to correct emergency preparedness
    weaknesses before the February 2000 event and initiated others to address
    the problems that occurred during it. However, these efforts have been
    ineffective and incomplete. As a result, in an April 2001 inspection report,
    NRC identified emergency preparedness weaknesses similar to those that
    occurred before and during the February 2000 event.

    Beginning in 1996, NRC identified numerous weaknesses with the emergency
    preparedness program at Indian Point 2. NRC found, for example, that
    Consolidated Edison was not training its emergency response staff in
    accordance with procedures and some individuals had not taken the annual
    examination and/ or participated in a drill or exercise in a 2- year period
    as required. In response, Consolidated Edison disciplined the individuals
    responsible, developed an improved computerbased roster containing the
    current status of the training requirements for emergency response
    personnel, and instituted a process to distribute training modules to those
    employees prior to the expiration of their qualifications.

    Although NRC cited Consolidated Edison for the training weaknesses, NRC
    relied on the utility to take corrective actions for other emergency
    preparedness problems and weaknesses. However, Consolidated Edison did not
    correct the weaknesses identified. For example, in 1998 and again in 1999,
    NRC identified problems with activating the pagers used to alert the
    utility?s staff about an emergency as well as other communication
    weaknesses. In 1999, NRC concluded that Consolidated Edison lacked the
    ability to detect and correct problems and determine their causes, resulting
    in weak oversight of the emergency preparedness program. In response, NRC
    staff said that they met with utility managers to specifically discuss and
    express NRC?s concerns with the emergency preparedness program. In
    commenting on a draft of this report, NRC noted that a Consolidated Edison

    Has Taken Actions to Resolve Emergency Preparedness Weaknesses, but More
    Needs to Be Done

    Ineffective Corrective Actions Resulted in Repeat Inspection Findings Before
    the February 2000 Event

    Page 8 GAO- 01- 605 Indian Point 2

    September 1999 special inspection confirmed that Consolidated Edison's
    emergency preparedness program would provide reasonable assurance of
    protecting the public and that the utility could or would take adequate
    protective measures during an emergency.

    Utilities' commitment to take timely corrective action and effective NRC
    oversight of the actions taken became even more important when, in April
    2000, NRC implemented its new safety oversight process. (App. III provides a
    brief description of the new process for emergency preparedness.) This is
    because under the new safety oversight process, NRC will rely even more on
    utilities to track and correct certain problems through their corrective
    action programs. During subsequent inspections, NRC will select a sample of
    corrective actions taken to verify that they resolve the findings and limit
    the potential that they will recur. Therefore, without a strong commitment
    by the utility to follow through to fix problems or when NRC does not hold
    utilities accountable for fixing them, problems can worsen. This is what
    happened at Indian Point 2. As described in the next section, some of the
    problems that occurred during the February 2000 event were uncorrected from
    the past, which confirmed that Consolidated Edison did not effectively
    correct its many emergency preparedness weaknesses.

    NRC conducted an intensified inspection effort to determine the causes of
    and response to the February 2000 event. During the inspections, NRC
    identified several emergency preparedness problems. Although Consolidated
    Edison has taken actions to correct these problems, a recent NRC inspection
    found that similar problems persist.

    Despite concluding that Consolidated Edison took the necessary steps to
    protect public health and safety during the February 2000 event, NRC
    identified several weaknesses with the emergency preparedness program at
    Indian Point 2. For example, Consolidated Edison did not activate its
    emergency operation facilities within the required 60 minutes primarily
    because of the complex process used to page the emergency response staff. As
    a result, the on- site response was delayed and the utility had no process
    to ensure that all emergency response staff were notified. In addition,
    NRC?s Office of the Inspector General identified other emergency
    preparedness issues that are discussed in appendix IV along with NRC?s
    Consolidated Edison?s

    Actions to Resolve Identified Weaknesses Are Incomplete

    Page 9 GAO- 01- 605 Indian Point 2

    response to them. 2 The Office of the Inspector General concluded, and NRC
    agrees, that recurring uncorrected weaknesses at Indian Point 2 played a
    role in the utility?s response during the February 2000 event. Table 1
    briefly describes some of the weaknesses that occurred during the event and
    the actions that the utility has taken to resolve them.

    Table 1: Selected Emergency Preparedness Weaknesses That Occurred During the
    February 2000 Event and the Corrective Actions Taken by Consolidated Edison

    Emergency preparedness weakness Corrective action taken

    Consolidated Edison did not activate its emergency operation facilities
    within the required 60 minutes primarily because of the complex process used
    to page the emergency response staff.

    Consolidated Edison revised its pager activation process and upgraded its
    pagers. It trained emergency response personnel and tested their ability to
    respond during 10 training drills and an unannounced call. It activates the
    pagers weekly to verify that they are functional. Consolidated Edison did
    not keep track of emergency response personnel as they entered the plant
    site and could not account for them within the required 30 minutes- it took
    about 20 minutes to activate the pagers.

    Consolidated Edison revised its accountability process, trained personnel in
    the new process, and tested their ability to respond during four unannounced
    drills.

    Consolidated Edison failed to properly communicate information about whether
    a radiation release had occurred and its magnitude.

    Consolidated Edison, the state, and counties revised the form used to report
    whether a release of radiation had occurred and its magnitude. In addition,
    the counties have agreed that they, rather than Consolidated Edison, will
    notify elected officials. To do so, Consolidated Edison paid for the
    counties to install a ?reverse 911? system, which supplements an existing
    manual system. The ?reverse 911? system dials the necessary telephone
    numbers and records whether the individual has received the message. The
    system is programmed to make three separate attempts to notify each relevant
    local official. Consolidated Edison?s technical representatives were late to
    arrive at the counties? emergency operations centers. Consolidated Edison
    has assigned to the counties technical

    representatives who will respond immediately to an emergency. It is also
    working with the counties to install a videoconferencing system in the four
    emergency operations centers to enhance communications between the plant and
    off- site officials. The emergency response data system (the real- time data
    link between the plant and NRC) was inoperable for the first several hours
    because of a preexisting equipment problem.

    Consolidated Edison implemented surveillance testing and routine monitoring
    to help ensure that the system is operational.

    2 See NRC?s Response to the February 15, 2000, Steam Generator Tube Rupture
    at Indian Point Unit 2 Power Plant (Case No. 00- 03S, Aug. 29, 2000).

    Page 10 GAO- 01- 605 Indian Point 2

    Emergency preparedness weakness Corrective action taken

    Problems arose in implementing the media response plan. For example,
    technical and support personnel lacked familiarity with their jobs, and an
    outdated telephone list prevented Consolidated Edison from contacting a
    local official.

    Consolidated Edison established new procedures for the joint news center,
    trained relevant personnel, and purchased new computers to improve
    information availability. It has established a process to update telephone
    lists. In addition, the counties have agreed that they, rather than
    Consolidated Edison, will notify elected officials. To do so, Consolidated
    Edison paid for the counties to install a ?reverse 911? system, which
    supplements an existing manual system. The ?reverse 911? system dials the
    necessary telephone numbers and records whether the individual has received
    the message. The system is programmed to make three separate attempts to
    notify each relevant local official. The technical support needed to resolve
    procedural and other plant technical issues was not timely and was of
    limited help. Consolidated Edison has revised its procedures, added staff,
    and

    provided additional training for its staff. It conducted 11 training drills,
    including 5 that were unannounced, during calendar year 2000 to test the
    staff?s knowledge about procedural and plant configuration issues.

    Consolidated Edison subsequently undertook an evaluation of its entire
    emergency preparedness program to determine the causes of the deficiencies
    and develop corrective actions. In its evaluation, Consolidated Edison
    concluded that senior management did not pay sufficient attention to the
    emergency preparedness program or problems at Indian Point 2 because such
    problems were not viewed as a high priority warranting close attention and
    improvement. As a result, emergency preparedness had relatively low
    visibility, minimal direction, and inadequate resources. The company also
    found that (1) the emergency response organization had been stagnant,
    understaffed, poorly equipped, and consistently ineffective; (2) the
    emergency manager performed collateral and competing duties; and (3) for a
    period of time, a contractor held the manager's position. Consolidated
    Edison also found that the professional development and continuing training
    of the emergency planning staff had been minimal. Consolidated Edison
    undertook various initiatives to address the deficiencies noted. The
    initiatives, including those identified in table 1, are described in its
    business plan for calendar years 2000 and 2001. Appendix V shows some of
    these initiatives.

    Despite the various actions that Consolidated Edison took to correct its
    emergency preparedness problems, in April 2001, NRC reported that it had
    found problems similar to those previously identified at Indian Point 2. NRC
    again found communication and information dissemination weaknesses. It also
    found that the utility?s training program had not prevented the recurrence
    of these issues during on- site drills and that its actions to resolve other
    weaknesses had not been fully effective. NRC said that Consolidated Edison
    had identified the major issues in its business

    Page 11 GAO- 01- 605 Indian Point 2

    plan, which, if properly implemented, should improve emergency preparedness
    at the plant. In commenting on a draft of this report, NRC noted that its
    April 2001 inspection report concluded that Consolidated Edison's emergency
    preparedness program would provide reasonable assurance of protecting the
    public.

    Although Consolidated Edison has been making improvements in its emergency
    preparedness program, officials recognize that these actions alone will not
    enhance the public?s confidence in its ability to effectively respond to a
    radiological emergency. The company must, for example, follow through on its
    commitments to help achieve public confidence and to have a strong emergency
    preparedness program. More importantly, Entergy, which expects to assume
    ownership of the plant later this year, will need to continue the corrective
    actions begun by Consolidated Edison.

    The four counties that are responsible for responding to a radiological
    emergency at Indian Point 2 have strengthened their programs as a result of
    the lessons learned from the February 2000 event. The lessons learned
    included the need to improve (1) communications during an emergency, (2) how
    the media is provided with information, and (3) coordination among the
    counties in the way they respond to a radiological emergency.

    The need to improve communications between Consolidated Edison and the
    counties about the extent of the emergency and the potential impact on the
    public was an important lesson learned from the event. This lesson resulted
    in one important change to improve communications among the state, counties,
    and Consolidated Edison- that is, revising the Radiological Emergency Data
    Form. The utility completes the form 15 minutes after declaring an emergency
    and updates it at 30- minute intervals thereafter. Although the February
    2000 event posed no danger to the public, Consolidated Edison reported that
    a radioactive release had occurred but that it posed no danger to the
    public. County officials, on the other hand, reported that no release had
    occurred. This contradictory information led to credibility problems with
    the media and the public.

    In April 2000, Consolidated Edison, in partnership with the state and
    counties, revised the form to ensure that all affected parties are ?speaking

    with one voice? when providing the media and the public with information.
    Before the emergency, the counties did not have a defined process to
    determine the information they needed and how they would The Four Counties

    Strengthened Their Emergency Preparedness Programs as a Result of the
    Lessons Learned From the February 2000 Event

    Page 12 GAO- 01- 605 Indian Point 2

    present that information to the public. Figure 2 shows the relevant section
    of the form used during the February 2000 event and the revisions made to
    it.

    Figure 2: Comparison of the Relevant Section of the Radiological Emergency
    Data Form During and After the Event

    Source: New York State Emergency Management Office.

    As can be seen from figure 2, the form now clearly shows whether a release
    has occurred.

    Some other actions that the counties have taken to improve their
    radiological emergency programs include the following:

    All four counties have agreed to activate their emergency operation centers
    at the alert level (a low- level event). Before the event, the counties
    differed on when they would activate their centers. Rockland County
    activated its center at the alert level; the other three counties activated
    their centers at the site- area emergency level (the next level above an
    alert). As a result, once Rockland activated its center during the February
    2000 event, the media questioned why the other three counties had not done
    so. According to FEMA officials, Rockland County activated its center
    earlier than the other counties because it is the only county whose center
    is located within 10 miles of the plant.

    The counties will activate the Joint News Center (located at Westchester
    County airport) at the alert level. Before the February 2000 event, the
    counties individually decided when to activate the Joint News Center.

    Page 13 GAO- 01- 605 Indian Point 2

    The ?Executive Hot Line? that linked the state, four counties, and governor
    has been linked to the emergency operations facility at Indian Point 2 to
    establish and maintain real- time communications during an emergency.

    Even before strengthening their programs, county officials believed- and
    continue to believe- they can protect public health and safety during a
    radiological emergency. They take this position because they have used as
    much as 80 percent of the plan for Indian Point to respond to such natural
    disasters as hurricanes, snow and ice storms, and Y2K.

    Beyond the actions already taken by Consolidated Edison and the counties to
    improve their emergency response programs, county officials suggested
    changes that would improve communications among NRC, FEMA, and nonstate
    entities. In particular, county officials said that since they are
    responsible for radiological emergency preparedness for Indian Point 2, NRC
    and FEMA should communicate directly with them during nonemergency
    situations. In New York and 16 other states- where more than half of the
    nation?s 103 operating nuclear power plants are located- counties or other
    local governments are responsible for radiological preparedness, but NRC and
    FEMA communicate primarily with the states and rely on the states to
    communicate with local jurisdictions. In response to the counties?
    suggestion, NRC said that routinely meeting with local officials would be
    resource intensive, and FEMA said that some states limit it from routinely
    communicating with local officials. However, NRC has not assessed the costs
    and benefits of meeting with local officials, and the four New York counties
    have not been privy to information concerning various FEMA initiatives that
    will affect their emergency preparedness programs. Counties Suggest

    Better Communication Among NRC, FEMA, and Nonstate Entities With a Major
    Role in Radiological Emergency Preparedness

    Page 14 GAO- 01- 605 Indian Point 2

    One of NRC?s four performance goals, established to comply with the
    Government Performance and Results Act of 1993, is to increase public
    confidence in it as a regulator. 3 Yet, NRC routinely communicates with the
    states rather than other entities that are responsible for radiological
    emergency preparedness and response. FEMA?s information shows that in 17
    states where more than half of the 103 operating commercial nuclear power
    plants are located, other entities, such as counties or local governments,
    are responsible for radiological emergency preparedness and response. Not
    communicating with these other entities could threaten NRC's ability to
    achieve its public confidence goal.

    At least every 5 years, NRC staff expect to meet with officials from all 31
    states that have operating nuclear power plants. NRC also provides state
    officials with training on such issues as the agency?s role and the
    resources it can provide in the event of a radiological emergency as well as
    the resources that other federal agencies can provide. According to NRC
    staff, they meet with some states more frequently, and the requests to meet
    exceed the agency?s capability. As a result, NRC is examining ways to
    combine training and meetings on different subjects to maximize its outreach
    efforts and improve the manner in which it communicates with the states.

    Although NRC?s policy is to meet at the state level, its staff believe that
    local officials have various options for meeting with NRC. For example,
    local officials are not precluded from participating in the meetings held at
    least every 5 years with the states and can interact with NRC staff during
    public meetings, including those held annually for all plants. They also
    noted that NRC would likely meet with local officials if asked to do so. But
    emergency preparedness officials from the four counties around Indian Point
    2 said they do not believe that public meetings are the appropriate forums
    for government- to- government interactions. Therefore, the counties
    suggested that NRC should meet with them at least annually.

    NRC has also been considering other changes in its relationship with local
    officials that could improve routine communications about emergency
    preparedness. For example, earlier this year, NRC staff considered the
    following questions: What should the resident inspectors (inspectors

    3 The four performance goals are to maintain safety, increase public
    confidence, make NRC?s activities and decisions more effective and
    efficient, and reduce unnecessary regulatory burden on stakeholders.
    Increasing Public

    Confidence May Be Difficult When NRC Does Not Routinely Communicate With
    Those Responsible for Responding to Radiological Emergencies

    Page 15 GAO- 01- 605 Indian Point 2

    assigned to each nuclear plant) do differently in the future concerning
    interacting with local officials, and should the inspectors participate in
    public meetings to discuss a plant? NRC staff considered various options to
    resolve these issues. NRC has considered, for example, inviting local
    officials to meet privately with resident inspectors at the conclusion of
    the biennial exercise briefings or having resident inspectors attend the
    annual meetings that NRC holds with the public to discuss the results of the
    new safety oversight process for each plant. In an April 2001 memorandum,
    the staff said they would modify NRC?s internal guidance to encourage using
    resident inspectors to increase communications with local officials.
    Resident inspectors generally live near the plants, are the most likely
    candidates to communicate with local officials, and should be the most
    knowledgeable about plant operations that could affect off- site officials.
    However, NRC also has staff in four regional offices around the country and
    at its headquarters in Rockville, Maryland, that could meet with local
    officials. NRC has not assessed the costs and benefits of using staff other
    than resident inspectors to meet with local officials.

    In addition, in assessing the first year of the new safety oversight
    process?s implementation, NRC expects to determine whether the annual plant
    meetings help the agency meet its public confidence goal. Since the public
    would be most concerned about how it could be affected by the plant in the
    event of an emergency, NRC?s attaining this goal could be enhanced by
    interacting with those responsible for responding to radiological
    emergencies at nuclear power plants. According to NRC staff, routinely
    communicating with local officials has resource implications and meeting its
    public confidence performance goal entails a trade- off with the agency?s
    other three goals- maintain safety, reduce unnecessary regulatory burden,
    and enhance the effectiveness and efficiency of its operations. However, NRC
    has not assessed the costs and benefits of meeting with local officials or
    the impact that such meetings would have on achieving its performance goals.

    FEMA generally implements its programs through the states and relies on the
    states to communicate relevant information to local jurisdictions. County
    officials responsible for emergency preparedness at Indian Point 2
    identified examples where this method of communicating with local
    jurisdictions has not been effective.

    For example, both New York State and county officials told us that the
    February 2000 event identified the need for flexibility in FEMA?s off- site
    exercises. According to county officials, they responded to the event as
    FEMA Has Not Effectively

    Communicated With New York Counties Responsible for Responding to
    Radiological Emergencies at Indian Point 2

    Page 16 GAO- 01- 605 Indian Point 2

    they would have responded during FEMA?s exercises, which are conducted to
    the general emergency level. Yet, they noted, the response for an alert like
    the one that occurred at Indian Point 2 is significantly different from the
    response that would be taken during a general emergency when a significant
    amount of radiation would be released off the plant site, and the counties
    would monitor the magnitude of the release and calculate the dose that the
    public would receive. As a result, state and county officials suggested that
    it would be more realistic to periodically conduct biennial exercises at the
    alert level, which they noted, and NRC's data confirm, occur more frequently
    than a general emergency, which has never occurred in this country. At the
    alert level, the counties would activate their emergency operations centers
    and take other response actions as they did during the February 2000 event.
    In commenting on a draft of this report, FEMA said that the emergency plans
    for the four New York counties require them to conduct off- site monitoring
    and dose calculations at the alert level.

    According to FEMA officials, because the exercises at Indian Point 2 were
    conducted at the general emergency level, the counties were able to respond
    appropriately to the February 2000 event. They also noted that FEMA?s
    regulations allow state and local jurisdictions the flexibility to structure
    the exercise scenarios to spend more time at the alert level and less time
    at the general emergency level. Nevertheless, county officials who
    participate in the exercises were not aware of the flexibility allowed by
    FEMA's regulations. One reason for their lack of knowledge is that county
    officials with whom we met did not participate in developing the exercise
    scenarios. In commenting on a draft of this report, FEMA said that it would
    consider the counties' suggestions when finalizing its new streamlined
    exercise process.

    In another example, county officials suggested that FEMA should consider
    using tabletop exercises to supplement the biennial exercises. 4 Since 1999,
    FEMA has been considering a proposal that would allow state and local
    jurisdictions to use alternative techniques, including tabletop exercises,
    for one of the three exercises conducted over a 6- year period. (App. VII
    briefly describes FEMA's initiatives and their status.) FEMA expects to
    revise its regulations in calendar year 2003 to allow the alternative

    4 A tabletop exercise is a structured discussion, which is based on a
    scenario or set of conditions for potential emergency response situations,
    among decisionmakers or responders in a low- stress environment. Tabletops
    are intended to be a teaching, training, and developmental aid.

    Page 17 GAO- 01- 605 Indian Point 2

    techniques. Yet, county officials with whom we met were not aware that FEMA
    was considering a regulatory change or how it would affect their emergency
    preparedness programs. Communicating such information to the counties would
    be invaluable, since a NRC document on conducting tabletop exercises for
    radiological emergency response notes that it can take as long as 6 months
    to plan the exercise and up to 6 months to report on the lessons learned and
    the corrective actions for the issues identified.

    Finally, although county officials knew that FEMA expected to implement a
    streamlined exercise process in October 2001, they were not aware of the
    particulars of the process or how it would affect their actions during the
    exercises. According to a New York State official, the state participated in
    developing the streamlined process and briefed the counties about it. In
    commenting on a draft of this report, FEMA said that one Westchester County
    official received information related to the new streamlined exercise
    process; it had posted information on its Web page; and it provided state,
    tribal, and local governments with information at an annual conference.
    Despite these actions, as late as April 2001, county officials responsible
    for emergency preparedness at Indian Point 2 told us that they had received
    no information on the particulars of the streamlined exercise process. Good
    business practices would seem to indicate that FEMA would ensure that local
    jurisdictions are privy to information that will affect their responses
    during the exercises and ultimately to a radiological emergency.

    We do not know whether the communication issues experienced by the four New
    York counties are typical of the experience of the other locations where the
    responsibility for radiological emergency preparedness rests with an entity
    other than the state. Nevertheless, the impact that a radiological
    emergency- even one like an alert that does not endanger the public- can
    have on communities around nuclear power plants would seem to highlight the
    need for effective communication to prepare for and respond to such
    emergencies.

    A more proactive approach by Consolidated Edison to fix recurring weaknesses
    that had been identified over several years could have improved the
    implementation of its emergency preparedness plan during the February 2000
    event. NRC's vigilance is needed to ensure that Consolidated Edison and the
    new owner, Entergy, complete the planned improvements. This event also
    demonstrated the importance of effective, clear communication networks, both
    on- site in regard to the need to ensure that pagers work well to notify key
    personnel of an emergency, as Conclusions

    Page 18 GAO- 01- 605 Indian Point 2

    well as off- site, in regard to communicating about the extent and magnitude
    of the emergency. The ultimate measure of Consolidated Edison?s, the
    state?s, and counties? readiness in a radiological emergency is the manner
    in which they respond to an actual event. Exercises, while playing a
    valuable role in preparing for and assessing such readiness, more than
    likely will not identify the human reactions and all communications issues
    that could arise in a real radiological emergency. This was demonstrated
    during the February 2000 event.

    In addition, the way the February 2000 event played out underlines the
    critical importance of following through with lessons learned for
    Consolidated Edison, the state, and counties and determining whether some of
    these lessons could be applied to other plants. In this regard, NRC?s and
    FEMA?s interacting primarily with the states for routine communications
    needs to be reassessed at least for the 17 states where another entity is
    responsible for radiological emergency responses. The four Indian Point
    counties' lack of knowledge regarding the flexibility in FEMA?s regulations
    to spend more time at various emergency levels and its proposed streamlined
    exercise process demonstrate that FEMA?s reliance on the state to
    communicate with the local communities did not work in this case. Now may be
    an opportune time for NRC and FEMA to assess the extent to which they
    communicate with those responsible for effecting radiological emergency
    response.

    Since the responsibility for responding to radiological emergencies at a
    large percentage of this nation?s nuclear power plants rests with an entity
    other than the state, we recommend that the Commissioners direct NRC staff
    to assess the agency?s position of generally communicating with state
    officials during nonemergency situations.

    To improve communications with local governments, we recommend that the
    Director of FEMA determine the reasons why the four counties responsible for
    emergency response at Indian Point 2 are not knowledgeable about FEMA's
    initiatives and, if necessary, reassess its current practice of
    communicating through the state during nonemergency situations.
    Recommendations for

    Executive Action

    Page 19 GAO- 01- 605 Indian Point 2

    We provided NRC and FEMA with a draft of this report for their review and
    comment. NRC?s comments are in appendix VIII; FEMA?s comments are in
    appendix IX. NRC neither agreed nor disagreed with our recommendation.
    However, NRC reiterated its position that communicating with about 160
    counties during nonemergency times would be resource intensive. NRC also
    raised three issues. First, NRC said that we should make it clear our
    recommendation relates to nonemeregency communications. We have done so.
    Second, NRC noted that it maintained a very strong regulatory posture at
    Indian Point 2 in the emergency preparedness area and that its actions were
    commensurate with the safety significance of the emergency preparedness
    problems at the plant. Since we had not inferred otherwise, we did not
    revise the report. Third, NRC noted that despite the problems at the plant,
    Consolidated Edison's emergency preparedness program would protect the
    public in the event of a radiological emergency. We added this information
    to the report, where appropriate. Although FEMA expressed the view that it
    would be inappropriate to deal exclusively with the counties (something we
    did not recommend), it plans to increase its interaction with local
    officials nationwide in the coming years.

    NRC and FEMA provided technical clarifications, which we incorporated as
    appropriate.

    We conducted our work from November 2000 through July 2001 in accordance
    with generally accepted government auditing standards. Appendix X provides
    details on our scope and methodology.

    Unless you publicly announce its contents earlier, we plan no further
    distribution of this report until 10 days after the date of this letter. At
    that time, we will send copies to the Chairman, Nuclear Regulatory
    Commission; the Commissioners, Nuclear Regulatory Commission; the Director,
    Federal Emergency Management Agency; and the Director, Office of Management
    and Budget. We will make copies available to others on request. Agency
    Comments

    and Our Evaluation

    Page 20 GAO- 01- 605 Indian Point 2

    If you or your staff have any questions about this report, please call me on
    (202) 512- 3841. Key contributors to this report were Mary Ann Kruslicky,
    Philip Olson, and Carrie Stevens.

    (Ms.) Gary L. Jones Director, Natural Resources and Environment

    Page 21 GAO- 01- 605 Indian Point 2

    List of Congressional Requesters

    The Honorable Dan Burton Chairman, Committee on Government Reform House of
    Representatives

    The Honorable Benjamin A. Gilman House of Representatives

    The Honorable Sue Kelly House of Representatives

    The Honorable Nita M. Lowey House of Representatives

    Appendix I: Indian Point 2 Steam Generator Page 22 GAO- 01- 605 Indian Point
    2

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

    Source: Nuclear Regulatory Commission.

    Appendix I: Indian Point 2 Steam Generator

    Appendix II: The Nuclear Regulatory Commission?s Emergency Action Levels and
    Conditions That Could Cause an Emergency

    Page 23 GAO- 01- 605 Indian Point 2

    Table 2: The Nuclear Regulatory Commission?s Emergency Action Levels and
    Some Examples of Nuclear Power Plant Conditions That Could Cause an
    Emergency

    Emergency action level and definition Examples

    Unusual event An extremely low- level emergency that poses no threat to
    public safety but warrants increased awareness on the part of utility and
    off- site personnel.

    Reactor coolant samples indicate measurable damage to the metal tubes that
    hold the uranium fuel pellets. The water level in the spent fuel pool is
    low. Water leaks from the reactor coolant system in excess of The Nuclear
    Regulatory Commission?s allowed limits. The main turbine is severely
    damaged. Loss of all on- and off- site communication equipment occurs. Alert
    A low- level emergency that poses no threat to public safety but for which
    precautionary mobilization of certain emergency response functions is
    appropriate. Any radioactive release is expected to be limited.

    High radiation readings occur inside the primary containment- a large
    concrete and steel structure that surrounds the reactor vessel and its
    coolant system. Water leaks from the reactor coolant system at a rate
    greater than 50 gallons per minute. Radiation levels in one or more vital
    areas (equipment necessary for the safe operation and shutdown of the plant)
    are high. Damage to the main turbine results in damage to vital equipment.
    Unauthorized personnel enter the protected area (area that includes vital
    plant structures and is surrounded by a security fence). A fire occurs that
    could potentially affect safety systems and an explosion occurs that damages
    permanent plant equipment. A toxic or flammable gas is released in or near a
    vital area. Site- area emergency Plant conditions degrade to a point where
    full activation of response functions is warranted. Any radioactive release
    is not expected to exceed the Environmental Protection Agency's exposure
    levels, except near the site's boundary.

    The normal methods of cooling the reactor- feed water system, main steam
    system, or steam generators- do not function. All alternating current
    electrical power to vital busses (on- site network to supply electric power)
    is lost for more than 15 minutes. Unauthorized personnel enter a vital area
    of the plant.

    General emergency Actual or imminent substantial degradation or melting of
    the reactor with the potential for a significant radioactive release to the
    environment beyond the plant?s boundary occurs.

    Two of the three fission product barriers (fuel cladding, reactor coolant
    system, and containment) fail. All alternating current electrical power (on-
    and off- site) is lost and not expected to be available for an extended
    period of time. Unauthorized personnel take over the control room so that
    the utility looses the ability to safely operate or shut down the plant.

    Appendix II: The Nuclear Regulatory Commission?s Emergency Action Levels and
    Conditions That Could Cause an Emergency

    Appendix III: Description of NRC?s New Safety Oversight Process for
    Emergency Preparedness

    Page 24 GAO- 01- 605 Indian Point 2

    In April 2000, the Nuclear Regulatory Commission (NRC) implemented its new
    safety oversight process for nuclear power plants. Emergency preparedness is
    one of seven ?cornerstones? of the new safety oversight process. 1 The
    cornerstones represent the activities that are essential for the safe
    operation of the plants. The new safety oversight process also includes
    performance indicators, inspections, and an assessment of the safety
    significance of the inspection findings for all seven cornerstones. NRC
    integrates the indicator results with inspection findings to arrive at a
    conclusion about the overall safety performance of the plants and the
    regulatory response that should be taken, if any.

    Under its new safety oversight process, NRC has stratified emergency
    preparedness requirements on the basis of their safety significance. The
    focus of inspections is the 16 standards in 10 C. F. R. 50.47( b). NRC
    concluded that the standards are not equally important to safety. As a
    result, NRC identified the following four planning standards that are the
    most significant from a safety standpoint:

    Timely and accurate classification of events because untimely and inaccurate
    classification can delay the activation of the utility?s emergency response
    organization and notification of off- site governmental authorities.

    Timely and accurate notification of off- site governmental authorities.

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

    Assessment of the off- site consequences of a radiological emergency
    condition.

    NRC focuses its oversight and inspection resources in emergency preparedness
    on these four standards. NRC?s procedures set out the agency?s expectations
    for inspectors and the methodology to be used to prioritize and expend
    resources for the remaining 12 standards. In addition, each year, NRC
    expects its staff to verify the accuracy of performance indicator data, the
    utilities? problem identification and resolution programs, and the tests of
    the emergency response organization and public alert and notification system
    (sirens).

    1 The seven cornerstones are initiating events, mitigating systems, barrier
    integrity, emergency preparedness, public radiation safety, occupational
    radiation safety, and

    physical protection.

    Appendix III: Description of NRC?s New Safety Oversight Process for
    Emergency Preparedness

    Appendix III: Description of NRC?s New Safety Oversight Process for
    Emergency Preparedness

    Page 25 GAO- 01- 605 Indian Point 2

    As part of the new safety oversight process, NRC identified three
    performance indicators for emergency preparedness: drill/ exercise
    performance, emergency response organization drill participation, and
    reliability of the alert and notification system. The drill/ exercise
    indicator measures performance in specific risk- significant activities; the
    emergency response organization indicator provides information to assess the
    licensees? development and maintenance of key skills. From these two
    indicators, NRC can assess the quality of training and emergency-
    planimplementing procedures as well as facility and equipment readiness,
    including communications; personnel performance; and organizational and
    management changes. In addition, a high rate of reliability of the alert and
    notification system increases assurances that the utility can protect public
    health and safety during an emergency. Table 3 shows performance indicator
    data for Indian Point 2 from April 2000, when NRC instituted the new safety
    oversight process, through March 2001, the month of the most currently
    available data.

    Table 3: Performance Indicator Data Through March 2001

    Shown as a percentage

    Performance indicator April 2000 December 2000 March 2001

    Drill/ exercise performance 91.2 94.5 95.2 Emergency response organization
    drill participation 100.0 98.4 100.0 Reliability of the alert and
    notification system 99.1 99.0 98.9

    Source: NRC.

    For each indicator, NRC has established thresholds for increased agency
    oversight of commercial nuclear plants. For example, if the utility?s drill/
    exercise performance is less than 90 percent, if the emergency response
    organization drill participation is less than 80 percent, or if the
    reliability of the alert and notification system is less than 94 percent,
    NRC will focus greater attention on emergency preparedness activities at a
    plant. As shown in table 3, since the inception of these performance
    indicators in April 2000, Indian Point 2 has always exceeded NRC?s
    thresholds.

    In commenting on a draft of this report, NRC noted that it selected the
    three performance indicators in conjunction with stakeholders because they
    represented objective measures to monitor safety- significant emergency
    preparedness activities. According to a representative of the Union of
    Concerned Scientists, two of the performance indicators-

    Appendix III: Description of NRC?s New Safety Oversight Process for
    Emergency Preparedness

    Page 26 GAO- 01- 605 Indian Point 2

    drill/ exercise performance and emergency response organization drill
    participation- are appropriate, but the alert and notification system
    indicator is not. The reason is that the indicator reflects only the results
    of monthly tests done on the alert and notification system and how many pass
    or fail. However, if the equipment is inoperable between the time that the
    tests are conducted, this is not reflected in the indicator. Yet, inoperable
    equipment and equipment failure do happen. The Union?s representative
    believes a better indicator would be ?availability?; that is, the total
    hours in a month that the equipment does not operate and for how many hours
    it is inoperable. NRC staff expect to assess the first- year implementation
    of the new safety oversight process and recommend changes to the Commission.
    In commenting on a draft of this report, NRC noted that although an
    availability indicator could enhance the current performance indicators, it
    selected the reliability indicator to be consistent with the Federal
    Emergency Management Agency's guidance for siren testing and reporting.

    Appendix IV: Some Emergency Preparedness Issues Identified by NRC?s Office
    of the Inspector General

    Page 27 GAO- 01- 605 Indian Point 2

    In August 2000, NRC?s Office of the Inspector General reported on emergency
    preparedness and other issues at Indian Point 2. Selected issues and the
    affected parties? plans to address them are discussed below.

    Local officials want increased interaction with NRC on a routine basis. As
    of April 3, 2001, NRC had determined that it would modify its inspection
    guidance to encourage using resident inspectors for increased communications
    to enhance local public confidence in NRC.

    Communication between county emergency operations centers and NRC was
    nonexistent during the emergency. NRC does not expect to take any action on
    this issue because the agency does not normally communicate with local
    centers but, rather, relies on the state as a single point of contact. The
    state is responsible for providing the counties with information as well as
    evaluating the emergency and the appropriate response to it.

    NRC did not notify the U. S. Secret Service about the emergency. NRC
    transmitted information about the emergency to the White House Situation
    Room, which was responsible for informing the Secret Service. However,
    because of the proximity of former President and Senator Clinton?s residence
    to the plant (11- 1/ 2 miles), NRC and the Secret Service finalized a new
    protocol, whereby NRC will notify the Secret Service whenever a problem
    occurs at any NRC- licensed facility, including commercial nuclear power
    plants.

    The release of information was not timely. According to NRC staff, in a
    December 2000 letter, Consolidated Edison provided information that refuted
    the Inspector General?s findings and concluded that information was released
    in a timely manner.

    The state experienced difficulties in getting information about the
    emergency from Consolidated Edison. The utility expects to stress the
    importance of communications with off- site agencies in its training
    program. NRC will monitor the actions taken.

    English is a second language for many who live within 10 miles of the plant.
    According to NRC staff, FEMA is responsible for evaluating this issue. FEMA
    officials said they will evaluate this issue after the final 2000 Census
    data are available. They noted, however, that they expect the 2000 Census
    data to show that Spanish is a second language for more than 5 percent of
    the population within 10 miles of Indian Point and that the various oriental
    language groups are likely to approach and may exceed 5 percent. According
    to FEMA officials, this could be a significant issue for Indian Point, which
    has an estimated 280,000 people within 10 miles of the site. FEMA expects to
    complete a draft report on this issue by the end of calendar year 2001.
    Appendix IV: Some Emergency Preparedness

    Issues Identified by NRC?s Office of the Inspector General

    Appendix V: Emergency Preparedness Corrective Actions Initiated by
    Consolidated Edison Since the February 2000 Event

    Page 28 GAO- 01- 605 Indian Point 2

    Establish a minimum of three emergency response organization teams.

    Implement an improved emergency drill and exercise program.

    Implement an improved emergency facility and equipment check surveillance
    program.

    Implement an improved self- assessment and performance indicator process.

    Implement an improved training program for emergency management staff.

    Revise the process for staffing the emergency notification telephone system
    in the technical support center.

    Develop surveillance tests for the emergency response data system.

    Establish an emergency off- site technical advisor program.

    Upgrade the Meteorological Information Data Acquisition System.

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

    Upgrade the siren verification system.

    Revise and implement an off- site monitor training program.

    Develop and implement a Web page for Indian Point 2.

    Issue new pagers to plant personnel.

    Conduct off- hours drills.

    Train joint news center personnel.

    Train company personnel who communicate with the media.

    Develop communication and visual aids to better provide the public with
    information. Appendix V: Emergency Preparedness

    Corrective Actions Initiated by Consolidated Edison Since the February 2000
    Event

    Appendix VI: County Officials? Suggestions to Improve Radiological Emergency
    Preparedness and NRC?s/ FEMA?s Responses

    Page 29 GAO- 01- 605 Indian Point 2

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

    Suggested action NRC staff?s response FEMA?s response NRC and FEMA

    NRC and FEMA need to condition off- site jurisdictions that an alert does
    not equate to a general emergency.

    Any outreach effort is beneficial and would help NRC meet its ?increase
    public confidence? performance goal. However, NRC does not normally
    communicate with local jurisdictions but, rather, relies on the state as a
    single point of contact. NRC believes that its state outreach efforts have
    been successful. In addition, it would be very resource- intensive if NRC
    were to routinely meet with local officials.

    FEMA?s guidance allows states and local jurisdictions the flexibility to
    structure the exercise scenarios to spend more time at the alert level and
    less time at the general emergency level.

    FEMA only

    FEMA should not always conduct exercises at the general emergency level. In
    other words, FEMA should vary the emergency action level during its
    exercises.

    NRC's Region I staff said that conducting exercises at the general emergency
    level contributed to the positive responses taken by local jurisdictions
    during the February 2000 event. However, the probability that a general
    emergency will occur is very small while the probability for an alert is
    greater.

    FEMA?s guidance allows states and local jurisdictions the flexibility to
    structure the exercise scenarios to spend more time at the alert level and
    less time at the general emergency level.

    FEMA should establish liaisons with the counties that would be familiar with
    the relevant emergency plan. The liaisons would participate in the off- site
    exercises.

    With only one exception, FEMA implements its programs through the states.
    The states are responsible for assisting local jurisdictions and providing
    them with information. New York State officials have asked FEMA to
    coordinate its communications/ interactions with local jurisdictions through
    the state.

    FEMA has assigned five staff involved with emergency preparedness at Indian
    Point. FEMA has a site manager (at all nuclear plant sites) and a team
    leader for each New York county within 10 miles of the plant. Although the
    site manager and team leaders are not located at the plant, they are
    familiar with the local emergency plans and participate in the exercises.
    FEMA could conduct tabletop exercises in lieu of the off- site exercises on
    a rotating basis.

    One of the initiatives resulting from FEMA?s strategic review would allow
    state and local jurisdictions to use alternative techniques in one of the
    three exercises conducted over a 6- year period. NRC is developing a 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.

    Tabletop exercises have limited usefulness in the radiological emergency
    preparedness program. Tabletop exercises could be used to test the decisions
    made by off- site officials but would not be beneficial for testing the
    participants? ability to appropriately measure radiation releases and
    calculate the dose received.

    FEMA?s regulations allow states and local jurisdictions the flexibility to
    structure the exercise scenarios to spend more time at

    Appendix VI: County Officials? Suggestions to Improve Radiological Emergency
    Preparedness and NRC?s/ FEMA?s Responses

    Appendix VI: County Officials? Suggestions to Improve Radiological Emergency
    Preparedness and NRC?s/ FEMA?s Responses

    Page 30 GAO- 01- 605 Indian Point 2

    Suggested action NRC staff?s response FEMA?s response

    the alert level and less time at the general emergency level.

    One of the initiatives resulting from FEMA?s strategic review would allow
    states and local jurisdictions to use alternative techniques in one of the
    three exercises conducted over a 6- year period. FEMA will revise its
    emergency preparedness regulations to implement this initiative. FEMA
    expects to finalize its regulations in calendar year 2003. FEMA could use
    tabletop exercises to assess the state?s and counties? ability to respond
    within the 50- mile ingestion pathway.

    NRC staff said that nothing in FEMA?s regulations would preclude states and
    local jurisdictions from conducting more exercises.

    Although FEMA uses tabletop exercises to test other emergency responses, it
    has not used them for assessing radiological emergency responses within the
    10- mile emergency planning zone at Indian Point 2. FEMA would have no
    objections to states and local jurisdictions using tabletop exercises to
    supplement the required 6- year exercises. In commenting on a draft of this
    report, FEMA noted that it has used tabletop exercises for the 50- mile
    ingestion pathway exercises. FEMA should be at the counties? emergency
    operations centers during an alert. This would allow a real- time evaluation
    of performance and could eliminate the need for a biennial exercise.

    Some alerts are short lived. It would be inappropriate for FEMA to establish
    an expectation that staff would be at emergency operations centers during an
    alert and then not meet that expectation.

    FEMA?s regulations set out policies and procedures for state and local
    jurisdictions to obtain credits for their response to an actual emergency or
    natural disaster. FEMA could not, however, give credit for radiation
    monitoring and dose assessments. So, an exercise of some aspects of the
    radiological emergency plan would need to be conducted.

    Appendix VI: County Officials? Suggestions to Improve Radiological Emergency
    Preparedness and NRC?s/ FEMA?s Responses

    Page 31 GAO- 01- 605 Indian Point 2

    Suggested action NRC staff?s response FEMA?s response

    FEMA should conduct unannounced exercises. NRC staff did not believe it was
    viable or

    practical for FEMA to conduct unannounced exercises. They noted that a full-
    participation exercise can involve hundreds of participants, including
    volunteers, and that a large part of the training benefits of the exercise
    would be lost if FEMA did not announce them. They also noted that although
    FEMA, state and local jurisdictions, and the utility develop the exercise
    scenario, FEMA does not give the scenario to participants nor is the exact
    time of the exercise announced. Rather, FEMA announces the week in which the
    exercise will occur. Therefore, the exercise is ?unannounced? since the
    state and local jurisdictions do not know the exact date on which it will
    occur.

    FEMA conducts unannounced exercises for some aspects of radiological
    emergency preparedness. For example, in October 1999, FEMA conducted an
    unannounced and off- hours drill of the four Indian Point counties? ability
    to activate their emergency operations centers, mobilize their staff, and
    establish communication links with the plant.

    As part of its efforts to streamline its program, FEMA is considering a
    proposal to eliminate unannounced exercises because of opposition from off-
    site officials throughout the country. In commenting on a draft of this
    report, FEMA said that it will continue to conduct unannounced drills for a
    specific situation- a fast- breaking emergency.

    NRC only

    NRC should meet with officials from the four Indian Point 2 counties at
    least annually (i. e., during nonemergency times).

    NRC does not normally interact with local officials but, rather, relies on
    the state as a single point of contact during emergencies and at other
    times. It would be very resource- intensive to meet with all local
    jurisdictions. However, NRC staff have assessed this issue and developed
    options to resolve it. Whatever option is selected must be applied
    consistently to all plants but must allow for regional and headquarters
    management flexibility in implementing the option because different plants
    may need to be treated differently, depending on the level of public
    interest about the plant.

    FEMA officials said that they would have no objection to NRC?s meeting with
    county officials.

    In addition, if the Indian Point counties have issues or concerns about
    receiving information, FEMA?s regional office could obtain the information
    for them or provide a bridge to other federal agencies.

    Other

    Consolidated Edison or NRC needs to provide more public education on the
    actual and fictional hazards of nuclear power.

    Although NRC and the licensee are responsible for educating the public, the
    licensee is primarily responsible for doing so. However, NRC?s Web site
    provides some educational material and its Office of Public Affairs
    periodically conducts a workshop for the media. In addition, NRC's technical
    staff visit schools to discuss NRC?s role and functions and how plants are
    designed.

    Some states have active public education programs.

    NRC could conduct education programs without violating the restriction that
    prohibits it from promoting nuclear power. A significant difference exists
    between conducting education programs and being an industry proponent.

    Appendix VII: Initiatives to Streamline FEMA?s Radiological Emergency
    Preparedness Program and Their Status

    Page 32 GAO- 01- 605 Indian Point 2

    In June 1996, FEMA announced that it would review its radiological emergency
    preparedness program to identify opportunities to improve, streamline, and
    enhance its efficiency and effectiveness. The resulting 1999 report included
    34 initiatives to improve the program. One group of initiatives is intended
    to streamline the radiological emergency preparedness program. Since that
    time, FEMA has completed 24 initiatives. FEMA expects to implement a
    streamlined exercise process in October 2001.

    Some FEMA officials have raised concerns about the streamlined process. In
    particular, they are concerned with the (1) expanded use of granting credits
    for the responses taken for nonradiological emergencies, (2) increased use
    of out- of- sequence exercises (conducted separately from the biennial
    exercise) for some radiological preparedness activities and functions, and
    (3) possibility of eliminating unannounced exercises. We did not examine the
    validity of these concerns because they were outside the scope of this
    report. In commenting on a draft of this report, FEMA noted that it would
    monitor the implementation of the initiatives and will, if necessary, revise
    any that are not attaining the desired result. Table 5 shows the initiatives
    and their implementation status, according to FEMA officials.

    Table 5: FEMA?s Initiatives and Their Status Initiative Implementation
    status Streamline the program

    Consolidate evaluation objectives into six areas to support a results-
    oriented process Interim evaluation areas published; four pilot exercises

    completed. On June 11, 2001, FEMA published the results of the pilot
    projects in the Federal Register, which included the new evaluation areas,
    for comment. FEMA expects to implement the new evaluation areas for the
    exercises conducted after September 30, 2001. Conduct medical services
    drills biennially Completed; policy took effect in October 1999. Use out-
    of- sequence demonstrations of evaluation areas Completed; policy took
    effect in October 1999. Provide feedback at the conclusion of an exercise
    Completed; policy took effect in October 1999. Take immediate corrective
    actions during out- of- sequence demonstrations Completed; policy took
    effect in March 2000. Provide credit for unannounced and off- hours
    exercises and drills on the basis of the response to an actual emergency
    Policy paper issued in September 2000 for comment. Implement new exercise
    scenario options Draft policy issued in October 2000. Policy will be
    finalized after

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

    regulations. Instead, it directed regional offices to ensure submission,
    consistency, and completeness of the letters. Revise the annual letter of
    certification submittal requirements Completed in July 2000.

    Appendix VII: Initiatives to Streamline FEMA?s Radiological Emergency
    Preparedness Program and Their Status

    Appendix VII: Initiatives to Streamline FEMA?s Radiological Emergency
    Preparedness Program and Their Status

    Page 33 GAO- 01- 605 Indian Point 2

    Initiative Implementation status

    Verify the documentation provided with the annual letter of certification
    Completed in July 2000. Negotiate agreements to conduct only two exercises
    over a 6- year period; revise regulations (FEMA and NRC) to allow for this
    change Rulemaking in process. Implementing policy posted for public

    comment. FEMA expects to finalize its regulation late in calendar year 2003.
    Conduct staff visits to assist states, tribal nations, and local governments
    Completed; policy took effect in August 2000. Develop a radiological
    emergency preparedness program manual that reflects revised and updated
    policies and guidance FEMA expects to complete this initiative by October 1,
    2001. Revise the joint NRC/ FEMA criteria and memorandum of understanding
    Criteria will not be revised. Rather, an addendum updating the

    outdated references was provided to the agencies that are members of the
    Federal Radiological Preparedness Coordinating Committee for comment. In
    addition, in May 2001, FEMA and NRC published the addendum in the Federal
    Register for comment. The comment period ends on August 1, 2001. Review all
    program guidance at least once every 2 years Ongoing. Post program guidance
    on FEMA?s Web site Completed; documents are placed on the Web site as they

    become available.

    Increase federal participation in exercises

    Have FEMA take the lead in planning and coordinating exercises Completed in
    September 2000. Complete the Radiological Incident Annex The information
    will be published as a revision to the Federal

    Response Plan. Establish an interagency task force to review the charters of
    various response committees Completed but not as recommended. FEMA
    recommended that

    the Federal Radiological Protection Coordinating Committee consider
    establishing the task force. Identify additional resources needed Completed.
    Reinforce the role of the Federal Radiological Preparedness Coordinating
    Committee Completed. Review and revise training courses Completed. Establish
    a position in FEMA to facilitate communication Completed.

    Use state, local, and tribal personnel as exercise evaluators

    Establish conditions to use state, tribal, and local personnel as exercise
    evaluators Completed. Develop a memorandum of understand with state, tribal,
    and local governments that agree to provide exercise evaluators Completed in
    June 2001. Develop qualification standards for the nonfederal evaluators
    Completed in June 2001.

    Include Native American tribal nations in the radiological emergency
    preparedness process

    Identify areas for federal and tribal relationships Completed. Identify all
    federally recognized tribes in the 10- and 50- mile radius of nuclear plant
    sites Completed. Identify current government- to- government policies and
    practices Completed. Develop an approach to increase tribal involvement
    Completed.

    Enhance training requirements and curriculum

    Establish qualification standards for federal exercise evaluators Completed.
    Increase opportunities for FEMA staff to teach evaluator training Completed.

    Appendix VII: Initiatives to Streamline FEMA?s Radiological Emergency
    Preparedness Program and Their Status

    Page 34 GAO- 01- 605 Indian Point 2

    Initiative Implementation status

    Revise radiological courses Short refresher course used during the pilot
    program at four nuclear plants. FEMA is developing a resident evaluator
    course using the new evaluation areas. Develop an administration course for
    all FEMA radiological emergency preparedness staff On hold, pending
    completion of the radiological emergency

    preparedness manual.

    As can be seen from table 5, FEMA?s major initiative related to streamlining
    its radiological emergency preparedness program. FEMA had more than 15
    separate activities to attain this objective. For example, FEMA is proposing
    to move from an objective- based, checklist format, exercise evaluation,
    which is very structured and leaves little latitude to satisfy the exercise
    objectives by alternative means, to a more comprehensive/ holistic approach.
    To this end, FEMA examined the 33 exercise objectives that it had developed
    to clarify what constituted an exercise and to ensure consistency in the
    method used to evaluate the exercises. FEMA consolidated the 33 objectives
    into six evaluation areas to support a results- oriented process. A results-
    oriented process will allow participants to complete an exercise activity
    without following a specific checklist and with more latitude to reach the
    desired results. This would allow FEMA to concentrate on the exercise
    results- not the methods used to reach the results- and would allow states
    or local jurisdictions to use an alternative method( s) to attain a result.

    FEMA pilot tested the new exercise evaluation areas from October through
    December 2000 at four nuclear plant sites. The sites included Susquehanna 1
    and 2 in Pennsylvania, Crystal River in Florida, Point Beach 1 and 2 in
    Wisconsin, and Duane Arnold in Iowa. Overall, the exercise participants at
    all four pilot projects were very positive about the new evaluation process.
    Likewise, feedback from FEMA?s evaluators was mostly positive, but the
    evaluators identified three issues that FEMA needed to address. First,
    training needs to focus on how the evaluators must prepare for an exercise
    and become very familiar with the plans and facilities for which they are
    responsible. Second, FEMA needs to document the required components of off-
    site radiological emergency response plans, since the joint NRC/ FEMA
    criteria leave room for interpretation in many planning areas. Finally, FEMA
    should establish a mentor program for new staff to help them achieve an
    acceptable evaluation capability. In June 2001, FEMA published its report on
    all four pilot projects in the Federal Register and allowed the public 60
    days to comment. On the basis of the lessons learned from the pilot projects
    and public comments on them, FEMA expects to revise its proposed streamlined
    approach, if necessary, and implement it in October 2001.

    Appendix VIII: Comments From the Nuclear Regulatory Commission

    Page 35 GAO- 01- 605 Indian Point 2

    Appendix VIII: Comments From the Nuclear Regulatory Commission

    Note: GAO's comments supplementing those in the report's text appear at the
    end of this appendix.

    Appendix VIII: Comments From the Nuclear Regulatory Commission

    Page 36 GAO- 01- 605 Indian Point 2

    See comment 1.

    Appendix VIII: Comments From the Nuclear Regulatory Commission

    Page 37 GAO- 01- 605 Indian Point 2

    See comment 3. See comment 2.

    Appendix VIII: Comments From the Nuclear Regulatory Commission

    Page 38 GAO- 01- 605 Indian Point 2

    Now on p. 31. Now on p. 29.

    See comment 6. See comment 5.

    See comment 4.

    Appendix VIII: Comments From the Nuclear Regulatory Commission

    Page 39 GAO- 01- 605 Indian Point 2

    See comment 7.

    Appendix VIII: Comments From the Nuclear Regulatory Commission

    Page 40 GAO- 01- 605 Indian Point 2

    See comment 8.

    Appendix VIII: Comments From the Nuclear Regulatory Commission

    Page 41 GAO- 01- 605 Indian Point 2

    See comment 15. See comment 14.

    See comment 13. Now on p. 5.

    See comment 12. See comment 11.

    See comment 10. See comment 9.

    Appendix VIII: Comments From the Nuclear Regulatory Commission

    Page 42 GAO- 01- 605 Indian Point 2

    Now on p. 25. See comment 21. Now on p. 24.

    See comment 20. Now on p. 23.

    See comment 19. See comment 18. See comment 17.

    See comment 16.

    Appendix VIII: Comments From the Nuclear Regulatory Commission

    Page 43 GAO- 01- 605 Indian Point 2

    Now on p. 29. See comment 25. Now on p. 26.

    See comment 23. Now on p. 25.

    See comment 22. Now on p. 29. See comment 24.

    Appendix VIII: Comments From the Nuclear Regulatory Commission

    Page 44 GAO- 01- 605 Indian Point 2

    The following are GAO?s comments on the Nuclear Regulatory Commission?s
    (NRC) letter dated July 13, 2001.

    1. The report notes that the utility's radiological emergency preparedness
    plan identifies the process for notifying and communicating with federal,
    state, and local agencies and the media during an event. In addition, the
    counties' suggestion to interact and meet with NRC annually applies to
    nonemergency situations. Furthermore, the report clearly sets out some of
    the opportunities that the counties have to meet with NRC, including the
    annual meetings held to discuss all plants. As noted, however, emergency
    preparedness officials from the four counties did not believe that public
    meetings are the appropriate forums for government- to- government
    interactions. In addition, although the counties could be invited to the
    state outreach meetings that NRC attempts to hold with all the states every
    5 years, NRC could not provide documentation that inviting the counties to
    such meetings is a routine practice. In fact, NRC staff told us that they
    were developing protocols for the state outreach program because no such
    documentation existed.

    2. We revised the recommendation to clarify that it relates to routine,
    nonemergency communications. In addition, the recommendation is not intended
    to change the "coordinated approach" used by NRC to interact with the 31
    states with commercial nuclear power plants. Rather, the recommendation is
    intended to supplement the actions that NRC takes. In addition, New York
    State and the counties did not say that they wanted to meet with NRC in lieu
    of the "coordinated approach" now used. Rather, since they are the entities
    primarily responsible for emergency preparedness- not the state- they want
    to meet and interact with NRC to obtain information about the status of the
    plant and any issues or problems that could affect their emergency
    preparedness programs.

    3. We continue to believe that NRC does not routinely communicate with
    nonstate entities responsible for responding to radiological emergencies.
    NRC cites various activities in which local governments have communicated
    with or could communicate with it. For example, NRC notes that ingestion
    pathway exercises include the counties. However, FEMA conducts such
    exercises every 6 years and on a rotating basis among the three nuclear
    plant sites in New York State. As a result, an ingestion pathway exercise
    for Indian Point 2 would be held every 18 years. In addition, NRC said that
    it participated with GAO?s Comments

    Appendix VIII: Comments From the Nuclear Regulatory Commission

    Page 45 GAO- 01- 605 Indian Point 2

    state and county officials in a tabletop exercise. On the basis of our
    discussions with NRC staff, this occurred only once in January 2001 and, at
    that time, the staff had not determined whether they would continue to
    attend the quarterly meetings held among New York State, county, and utility
    officials. Furthermore, NRC noted that the counties surrounding Indian Point
    2 are routinely sent notices of meetings and inspection reports. But NRC has
    missed the point. The four New York counties did not say that they did not
    receive information about meetings or copies of inspection reports; rather,
    they said that they would like the opportunity to meet on a government- to-
    government basis with NRC. Being aware of public meetings and receiving
    copies of inspection reports cannot take the place of face- to- face
    interaction between NRC and the counties. Whatever NRC ultimately decides,
    one important consideration should be the large number of people that could
    be affected by a severe accident at Indian Point 2.

    4. NRC does not routinely communicate with local jurisdictions either during
    an emergency or during nonemergency situations. Its "coordinated approach"
    relies on the state as a single point of contact. Therefore, we did not
    revise the report as NRC suggested.

    5. We revised the report as NRC suggested. 6. See comment 1. 7. We revised
    the report to reflect that the September 1999 special

    inspection confirmed Consolidated Edison's capability to respond to an
    emergency and that the problems experienced during the February 2000 event
    did not result in the loss of reasonable assurance that adequate protective
    measures could or would be taken during an emergency. In addition, we
    continue to believe- and NRC's inspection reports and Consolidated Edison's
    self- assessment support- that the emergency preparedness problems at Indian
    Point 2 worsened after 1995. Finally, we never took a position on the safety
    significance of the emergency preparedness weaknesses that NRC identified at
    Indian Point 2. Such a determination is solely NRC's responsibility.

    8. We added NRC's conclusion to the report; i. e., Consolidated Edison's
    emergency preparedness program would provide reasonable assurance to protect
    the public. However, we do not believe that it is misleading to state that
    Consolidated Edison's efforts to correct the emergency preparedness
    weaknesses that occurred before and during

    Appendix VIII: Comments From the Nuclear Regulatory Commission

    Page 46 GAO- 01- 605 Indian Point 2

    the February 2000 event were incomplete and ineffective since in April 2001,
    NRC reported identified similar weaknesses.

    9. We revised the report as NRC suggested. 10. We revised the report as NRC
    suggested. 11. We did not revise the report because the information that NRC

    suggested was already in the report. 12. We revised the report as NRC
    suggested. 13. We revised the report to include the information that NRC
    provided. 14. We did not revise the report because the information that NRC

    suggested was already in the report. 15. We revised the report to include
    the information that NRC suggested. 16. We revised the report as NRC
    suggested. 17. We did not revise the report as NRC suggested because the

    information was already in the report. In addition, the report later notes
    that NRC staff met with Consolidated Edison to discuss the agency's concerns
    about the emergency preparedness weaknesses at Indian Point 2.

    18. We revised the report as NRC suggested. 19. We revised the report to
    include the information that NRC provided. 20. We revised the report as NRC
    suggested. 21. We revised the report as NRC suggested. 22. We revised the
    report to include the essence of the information that

    NRC provided. 23. We revised the report to include the information that NRC
    provided. 24. We did not revise the report because the information suggested
    by

    NRC was already in the report. 25. We revised the report to include the
    information that NRC provided.

    Appendix IX: Comments From the Federal Emergency Management Agency Page 47
    GAO- 01- 605 Indian Point 2

    Appendix IX: Comments From the Federal Emergency Management Agency

    Note: GAO's comments supplementing those in the report's text appear at the
    end of this appendix.

    See comment 2. See comment 1.

    Appendix IX: Comments From the Federal Emergency Management Agency Page 48
    GAO- 01- 605 Indian Point 2

    Now on p. 10. See comment 5. See comment 4.

    See comment 3.

    Appendix IX: Comments From the Federal Emergency Management Agency Page 49
    GAO- 01- 605 Indian Point 2

    See comment 7. See comment 6.

    Appendix IX: Comments From the Federal Emergency Management Agency Page 50
    GAO- 01- 605 Indian Point 2

    See comment 9. See comment 8.

    Appendix IX: Comments From the Federal Emergency Management Agency Page 51
    GAO- 01- 605 Indian Point 2

    Now on p. 31. See comment 14. Now on p. 30.

    See comment 13. Now on p. 29.

    See comment 12. Now on p. 27.

    See comment 11. See comment 10.

    Appendix IX: Comments From the Federal Emergency Management Agency Page 52
    GAO- 01- 605 Indian Point 2

    See comment 19. See comment 18.

    See comment 17. Now on p. 32.

    See comment 16. Now on p 31.

    See comment 15.

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

    Appendix IX: Comments From the Federal Emergency Management Agency

    Page 54 GAO- 01- 605 Indian Point 2

    The following are GAO?s comments on the Federal Emergency Management
    Agency?s (FEMA) letter dated July 6, 2001.

    1. Since we clearly state in the introduction of the report the differences
    in responsibilities between the NRC and FEMA for on- and off- site
    radiological emergency preparedness, respectively, we did not revise the
    report as FEMA suggested.

    2. We revised the report to show that FEMA expects to increase its
    interaction with local officials in the coming years.

    3. FEMA reiterated information provided in the draft report. As a result, we
    did not revise the report.

    4. We revised the report to show that, as a Department of Defense facility,
    the U. S. Military Academy at West Point is exempt from state and local
    emergency- planning requirements but is connected to the emergency
    communication system that links Indian Point 2 with state and county
    officials. The Academy is developing a radiological response plan for its
    population and visitors. However, until the Department of Defense approves a
    plan, the population and visitors to the Academy are not provided the same
    level of protection as that provided to the public in Orange County.

    5. FEMA provided historical information on the evolution of the "reverse
    911" system implemented after the February 2000 event. However, table 1
    shows the corrective actions following the event. As a result, we did not
    revise the report to incorporate the additional information that FEMA
    provided.

    6. See comment 2. 7. We revised the report to show that the emergency plans
    for the four

    counties require them to conduct off- site monitoring and dose calculations
    at the alert level. This information would seem to provide support for the
    counties' suggestion to spend more time at the alert level during off- site
    exercises. In addition, although FEMA provided information on the time spent
    at the various emergency action levels for the biennial exercises conducted
    since May 1982, it did not provide an exercise completion time. We found,
    however, that the general emergency portion of the exercises conducted in
    April 1996, June 1998, and November 2000, ended between 3 and 4 hours after
    they started GAO?s Comments

    Appendix IX: Comments From the Federal Emergency Management Agency

    Page 55 GAO- 01- 605 Indian Point 2

    while the time spent at the unusual event level ranged from 1/ 2 hour to 1
    hour; at the alert level, from 1- 1/ 4 hours to 1- 3/ 4 hours; and at the
    site- area level, from about 1 hour to 1- 1/ 2 hours. Therefore, FEMA's
    information supports the counties; that is, more time is spent at the
    general emergency level than at the three lower emergency levels during an
    exercise.

    8. We revised the report to show that the county officials with whom we met
    did not participate in developing the exercise scenarios and that FEMA will
    consider the counties' suggestions when finalizing its new streamlined
    exercise process.

    9. We revised the report to briefly discuss the actions that FEMA took to
    distribute information about the new streamlined exercise process.
    Nevertheless, FEMA's placing information on its Web page or discussing it at
    an annual conference were not successful in providing information about the
    new process to Westchester, Putnam, Orange, and Rockland county officials
    with whom we met.

    10. We did not revise the report because our recommendation to FEMA did not
    say that the agency should deal "exclusively" with the counties.

    11. We revised the report to include the information that FEMA suggested.
    12. See comment 6. 13. We revised the report to show that FEMA has used
    tabletop exercises

    for the 50- mile ingestion pathway exercises. 14. We revised the report to
    show that FEMA will continue to conduct

    unannounced drills for a specific situation- a fast- breaking emergency.

    15. FEMA reiterated the information provided in the draft report. As a
    result, we did not revise the report.

    16. We revised the report as FEMA suggested. 17. We revised the report to
    include the information that FEMA suggested. 18. We revised the report as
    FEMA suggested. 19. We revised the report by adding "if necessary" as FEMA
    suggested.

    Appendix X: Scope and Methodology Page 56 GAO- 01- 605 Indian Point 2

    To identify the emergency preparedness weaknesses at Indian Point 2 and the
    actions that Consolidated Edison has taken to resolve the weaknesses
    identified, we analyzed NRC?s inspection reports and met with NRC staff in
    the Office of Nuclear Reactor Regulation and in Region I, King of Prussia,
    Pennsylvania, which is responsible for overseeing Indian Point 2. We also
    reviewed an August 2000 report by NRC?s Office of the Inspector General,
    which discussed technical and emergency preparedness issues related to
    Indian Point 2 since at least 1997. We analyzed NRC?s report on its planned
    actions to address the issues raised in the Office of the Inspector
    General's report. To put the weaknesses into perspective, we reviewed the
    relevant NRC regulations, policies, and procedures related to emergency
    preparedness and analyzed NRC?s information on the number and types of
    emergencies that have occurred at nuclear power plants nationwide since
    1981. We also reviewed a March 2000 report by the New York State Public
    Service Commission on the problems that occurred during the February 2000
    event at Indian Point 2. To determine the actions that Consolidated Edison
    has taken to resolve the weaknesses identified, we analyzed relevant
    condition reports, root cause analyses, and sections of the 2000 and 2001
    business plan concerning emergency preparedness improvements at Indian Point
    2. We met with the Vice President for Engineering, Consolidated Edison, and
    the Chief Nuclear Officer and Emergency Preparedness Manager for Indian
    Point 2 to determine the company?s commitment to following through on the
    identified corrective actions.

    To determine the lessons learned from the emergency by the four Indian Point
    counties, we reviewed a March 2000 report by the New York State Public
    Service Commission on the problems that occurred during the emergency. We
    met with officials from New York State and Westchester, Putnam, Orange, and
    Rockland counties to obtain their perspective of the response taken during
    the emergency. We determined whether the response identified needed
    improvements in the counties' radiological emergency plans and the status of
    their actions to address the improvements identified. We also toured the
    state?s and Rockland, Orange, and Putnam counties? emergency operations
    centers.

    To determine suggestions for improving NRC?s and FEMA?s radiological
    emergency preparedness process beyond the actions already taken, we met with
    New York State; Westchester, Putnam, Orange, and Rockland county; and
    Consolidated Edison officials. We also met with FEMA headquarters officials
    in the Radiological Emergency Preparedness Branch and FEMA Region II in New
    York City and with NRC staff in the Office of Nuclear Reactor Regulation,
    Office of Public Affairs, and Incident Appendix X: Scope and Methodology

    Appendix X: Scope and Methodology Page 57 GAO- 01- 605 Indian Point 2

    Response Operations Office, to obtain their views on the suggestions
    offered. We also analyzed FEMA's documents related to its strategic review
    and the resulting 34 initiatives, the status of the initiatives, and FEMA?s
    proposal to implement a streamlined exercise process.

    (360018)

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