EXECUTIVE SUMMARY
On
August 1, 2002, Governor George E. Pataki announced a
comprehensive and independent
review of
emergency preparedness to be performed by James Lee Witt Associates (JLWA)
for
the area
around the
Associates
subcontracted with Innovative Emergency Management (“IEM”) for portions of
the
review. The
review encompassed many related activities that were designed, when
taken
together, to
determine whether the existing plans and capabilities of the jurisdictions
involved are
sufficient to
ensure the safety of the people of
these plants,
and how those existing plans and capabilities might be improved. In addition to
an
outreach effort
into the surrounding communities, the review included recent exercise results
and
public
information efforts, current radiological emergency response plans, and the
data
underlying the
response plans, such as population data, the methodology of evacuation
time
estimates, alert
and notification system specifications, Off-site accident impact
analysis
methodologies, and
communication capabilities.
It
should be noted that we were not asked to look at the safety of the plants
themselves, the
availability of
alternate energy sources, the economic and environmental costs and benefits of
the
plants, or
other factors relevant to an overall picture of the plants within their
respective
communities.
Consequently, nowhere have we taken a position on the future status of the
plants.
During
our review we were frequently asked whether we were under constraints. We
were
guided by our
experience and were unconstrained in our recommendations.
Major
Findings
Plans and Exercises
1. The
plans are built on compliance with regulations, rather than a strategy that
leads to
structures and
systems to protect from radiation exposure.
2. The
plans appear based on the premise that people will comply with official
government
directions rather
than acting in accordance with what they perceive to be their
best
interests.
3. The
plans do not consider the possible additional ramifications of a terrorist
caused event.
4. The
plans do not consider the reality and impacts of spontaneous
evacuation.
5.
Response exercises designed to test the plans are of limited use in
identifying
inadequacies and
improving subsequent responses.
These
planning problems are more serious because of the large population
concentrations near
the Indian
Point plant, and when the effectiveness of the plan requires a degree of public
and
responder
confidence that is largely absent. Thus the consequences of the five general
findings
James Lee Witt Associates, 2003
Page vi
Review
of Emergency Preparedness of Areas Adjacent to Indian Point and
Millstone
above are
more serious for the communities around Indian Point than for
closest to
Millstone.
Regulations
The
Nuclear Regulatory Commission (“NRC”) has stated as recently as November 18,
2002, that
a
preliminary assessment of the capabilities of, and compliance by, the State and
its jurisdictions
by the
Federal Emergency Management Agency (“FEMA”), based on the September 24,
2002
exercise,
indicates the Off-site emergency plans are adequate to protect public health and
safety.
While
under the current regulations that may be technically true, we are concerned
that when
plans and
exercises, which omit such things as a realistic consideration of
spontaneous
evacuation and the
unique consequences of a terrorist attack, still meet NRC and
FEMA
regulations, then
those regulations need to be revised and updated on a national basis.
We
believe any
plant adjacent to high population areas should have different requirements
than
plants
otherwise situated, because protective actions are more difficult and the
consequences of
failure or
delay are higher. The standard, to minimize the radiological dose to the public,
would
remain the
same; its accomplishment necessitates higher requirements in some communities
than
others.
Some may
look at our findings, conclusions, and recommendations and read them,
incorrectly, as
an
indictment of FEMA or the State and its jurisdictions, and their staff and
leadership. FEMA
has
recognized the need to change in the direction of a more performance-based
approach in its
exercise
program. Although the change does not go far enough, it began with a
multi-year
strategic review
of the Radiological Emergency Preparedness Program, and resulted in a
new
exercise
methodology developed prior to 9/11 and published in the Federal Register
on
September
12, 2001. This beginning of a change in exercise theory to focus on
performance
outcomes was not
found in the planning and exercising practices of the State of
its
jurisdictions however. We hope our recommendations will accelerate both
regulatory and
cultural
changes.
Also,
while we do have many recommendations for further change that impact on the
systems
and
practices of FEMA and others, we recognize that these systems and practices
were
developed in a
different environment. Simply stated, the world has recently changed. What was
once
considered sufficient may now be in need of further revision. We hope that those
at all
levels of
government with emergency management responsibilities will consider our
suggestions
in a
manner that is consistent with their high standards and professional
experience.
Major
Conclusions
Indian Point Safety
In our
report we discuss significant planning inadequacies, expected parental behavior
that
would
compromise school evacuation, difficulties in communications, outdated
vulnerability
assessment, the
use of outdated technologies, lack of first responder confidence in the
plan(s),
problems caused
by spontaneous evacuation, the nature of the road system, the thin
public
education effort,
and how these issues may impact an effective response in a high
population
area. None
of these problems, when considered in isolation, precludes effective response.
When
considered
together, however, it is our conclusion that the current radiological response
system
and
capabilities are not adequate to overcome their combined weight and protect the
people from
an
unacceptable dose of radiation in the event of a release from Indian Point. We
believe this is
especially true if
the release is faster or larger than the typical exercise scenario. Should
our
recommendations be
successfully implemented it is possible that an improved exercise
program
will
demonstrate that a different conclusion is warranted.
Millstone Safety
Although
most of the problems mentioned above also apply to those
Millstone,
their consequences are significantly less for reasons detailed in the report.
The
response system
and capabilities of those jurisdictions, though inferior to those near Indian
Point,
should be able
to protect
most extreme
event. Implementation of our recommendations should dramatically increase
that
margin of
safety.
Major
Recommendations
Plans
Plants
adjacent to high population areas should have different requirements than plants
otherwise
situated,
because protective actions are more difficult and the consequences of failure or
delay
are higher.
Many of our specific recommendations are designed to assist the State and
its
jurisdictions in
meeting the higher requirements we believe need to be developed primarily at
the
Federal
level.
Also,
the plans appear to be based on the assumption that people will comply with
official
directions. We
recommend the implementation of a continuous effort that assesses
existing
attitudes and
expected behaviors, and planning (and public education) that is based on the
results
of these
efforts.
The
plans are designed to allocate responsibilities for emergency functions. The
current format
and
structure does not easily allow integration of information such as evacuation
time estimates,
what
segments of the public believe and intend, and risk and threat assessments. The
plans
should discuss
and evaluate strategies for protecting people in a variety of
scenarios.
Review
of Emergency Preparedness of Areas Adjacent to Indian Point and
Millstone
Terrorism
There
are unique aspects of a terrorist caused incident that should be considered in
planning and
exercising. For
example:
• The
possibility of multiple obstructions of evacuation routes that are additive to
those that
would occur
in a “normal” evacuation. Because they can be assumed to be
deliberately
designed to
cause disruption, they may also be more difficult to address than
normal
evacuation
problems.
• The
possible targeting of responders.
• The
possibility that spontaneous and/or shadow evacuation may be more of a
problem
than it
would be in a non-terrorist event.
• The
probable presence of a crime scene that may significantly change the
communication
and
coordination aspects of a disaster response, as occurred in
• The
probable diversion of those required to respond to the attack from response
related
law
enforcement activities such as the safe evacuation of the affected
populace.
• The
probable involvement of agencies, such as the FBI, in both on site and off
site
activities in ways
planners who now refuse to contemplate the unique implications of
the
terrorist threat
have not yet considered.
It is
important to note that a terrorist event need not result in a release for some
of the above
possible
consequences to come into play. The unique aspects of a terrorist event should
not be
dismissed by
simply asserting that they are covered in current plans and
exercises.
Communications
As is
often the case in emergency response, interoperability and other
communications
shortcomings among
the response agencies and jurisdictions hinders effective
response,
especially in
areas of hilly terrain. The adjacent counties should have a priority in
any
communications project
the State may undertake.
Also,
municipalities within and beyond the ten-mile planning zone should have access
to direct
notification and
information on current plant conditions and projections. A one-way flow
of
information
supplementing current notification processes would help local officials get
ahead of
problems and
retain public confidence.
Ten-Mile Emergency Planning Zone
There is
a likelihood of significant unnecessary evacuation within and beyond the
ten-mile zone.
Such an
evacuation has serious public safety implications. Planning at all levels of
government
must reflect
this likelihood.
Public Education
Because
evacuation is often assumed to be the only effective protective action, and
because
spontaneous
evacuation is a problem for public safety, training relative to
sheltering-in-place is
necessary, well
beyond the ten-mile zone. Also, effective public education must be designed
and
initiated if
aspects of the plan that are sensitive to public response are to be effective.
Because
Review
of Emergency Preparedness of Areas Adjacent to Indian Point and
Millstone
many
essential personnel indicate they will take care of their families, instead of
focusing on
their
response activities, training on emergency family protection should be a
component of this
public
education effort.
Exercises
We
observed the full-scale exercise of Indian Point held in September 24, 2002 but
there was no
comparable
Millstone exercise for us to observe. The exercise program, of which the
September
2002,
exercise was a part, simply does not measure the performance outcome of the
emergency
response system.
The results of the exercises are not as reflective of the status of preparedness
as
some
consider them to be.
The
exercise program uses a functional approach to exercise evaluation. The concept
is to outline
every
function to be performed, analytically break down each function, and review
the
performance of the
system using the functions and the points of review. The notion is that
each
atomized
function can be reviewed separately and can be judged on its own
merit.
The
current approach to exercises is valuable in improving specific parts of plans.
But an
emergency
response system should not be viewed functionally. It is a system where each
part is
connected to the
whole. The system includes warning, dose assessment, protective action
recommendations,
instructions to the public and so forth. A break in the chain of activities
may
mean that
the goal is not met.
The
State should work with FEMA and others to develop a performance outcome-based
exercise
program
distinctly different from the functional exercise approach. A functional
approach
examines each
activity against regulations, guidance, or plans and looks for compliance.
An
outcome-based
approach looks for the effects of the actions on the
community.
Exercise Scenarios
The
implications of a release faster or larger than those now being addressed also
need to be
considered. The
low end of the time range specified in NUREG 0654 (as low as one-half
hour)
is not
being sufficiently exercised. In addition, the participating organizations need
to focus on
measuring how
quickly the population is being affected versus the speed with which
protective
actions are
being accomplished. Similarly, in the case of larger releases, we cannot verify
that
the larger
end of the accident spectrum is being accommodated. The vigorous debate
about
whether a
terrorist event actually increases the probability of such releases, about which
we did
not offer
an opinion, should not detract from the need to address faster and larger
releases.
Large
shadow evacuation, especially for a terrorist event, should be included. These
scenarios
should be
selected for their ability to test varying concepts for protecting people. A
broader part
of the
community, including those publicly skeptical of the plans, needs to be involved
in the
development of the
exercises as well as be able to participate and observe the
exercises.
Review
of Emergency Preparedness of Areas Adjacent to Indian Point and
Millstone
Response Management Technologies
The
Indian Point region is using old technologies in a number of areas. The hazard
assessment
process uses 25
to 30 year old map overlays for determining the area at risk. The
hazard
information
specific to the dose assessment is communicated via phone or fax to the State
and
Counties. Plume
information is currently not available through operable automation systems
that
can show
the State and counties the precise areas that are at risk. Assessments do not
integrate
with
population data and do not show the time that various zones would be at
risk.
In
providing warning to the people, there is an over-reliance on outdated sirens
and the
Emergency
Alert System. Newer
technologies, such as tone alert radios, have not been
widely
implemented.
When
making protective action decisions, officials must consider what has happened,
how it
could affect
people, the time windows available for actions, action alternatives, and the
resources
and
constraints attendant on each action alternative. Currently, the protective
action decisionmaking
process is very
simplistic, and there is virtually no technology support for
these
decisions.
We
recommend that the
protective actions
be significantly upgraded.
Public Review
On
January 10, 2003 James Lee Witt Associates completed the draft review. Because
of the
importance of the
subject to the citizens and stakeholders in the area, and because we
thought
consideration of
comments would improve the report, JLWA thought it appropriate that
the
public have an
opportunity to provide comments on any aspect of it. The State concurred in
this
assessment and
approach.
The
comments received are recorded and discussed in a new appendix, Appendix
K.
FEMA
also commented on our draft report. Although it was sent two weeks after the
close of
the comment
period, and not to us, we requested additional time from the State so that we
could
address their
comments. We requested the additional time, and it was granted, because FEMA
is
the federal
agency with purview over many of the issues we discuss, and we felt they and
others
should have
benefit of our responses in their subsequent actions and decisions.
Our
consideration of the
FEMA report can be found in a second new appendix, Appendix L.