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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