PRESS RELEASE FROM RIVERKEEPER & THE INDIAN POINT SAFE ENERGY COALITION
FOR IMMEDIATE RELEASE:
Date: June 23, 2004
For more information contact:
Kyle Rabin, 845-424-4149 x 239
Coalition Blasts Federal Agencies in Official Response to Recent Indian Point
Emergency Exercise
Exercise Scenario Misled the Public
In formal comments filed today with the Federal Emergency Management Agency and
the Nuclear Regulatory Commission, Riverkeeper and the Indian Point Safe Energy
Coalition criticize the agencies over the recent radiological emergency exercise
held for the region surrounding the Indian Point nuclear power plant. According
to the groups, the Department of Homeland Security, the Federal Emergency
Management Agency and the Nuclear Regulatory Commission must not and cannot
certify the Indian Point emergency plan based on the June 8th emergency
exercise.
The official letter states:
“The question that the public, various public interest groups and hundreds of
elected officials would like an answer to is whether the public’s health and
safety can be protected during a radiological emergency at Indian Point. The
June 8th in-sequence exercise fails to provide an answer to this fundamental
question. Failing to incorporate a simulated release of radiation, the exercise
was not able to assess whether official orders issued to the public to evacuate
or shelter would have succeeded in protecting the public from receiving an
unacceptable dose of radiation.”
Other key excerpts from the official comments sent today:
Today, a nuclear power plant could not be built at Indian Point given a variety
of reasons including the site’s location in the midst of such a densely
populated metropolitan region. Your respective agencies would have a difficult
time disputing this fact. But what is so disturbing is how your respective
agencies can justify the plant’s continued operation.
********
Potential For A Catastrophic Scenario
The 767 cargo plane crashed into an on-site electrical transformer. However,
determined terrorists targeting Indian Point may succeed in breaching a reactor
containment dome and damaging the reactor core resulting in a subsequent release
of radiation. A successful terrorist strike could also cause a drain-down of a
spent fuel pool which could result in a pool fire and release of radiation. Both
scenarios can result in large releases of radioactivity. Other possible
scenarios the NRC should be considering include: (a) a cargo plane, fully loaded
with heavy earth-moving machinery (i.e. bulldozers) in the cargo bay, being
flown into a containment dome; and (b) a smaller plane loaded with powerful
explosives flown into the spent fuel pool building.
********
Scenario Separated Terrorist-Related Aspects From Plant Safety System-Related
Facets
The scenario used for the June 8th exercise deliberately separates the initial
terrorist plot to attack the Indian Point nuclear power plant from the safety
system-related events that unfolded later on in the scenario. This is an obvious
and purposeful ploy that is indicative of a broader public relations effort on
the part of the DHS, FEMA, NRC and Entergy designed to dupe the public into
believing Indian Point is not vulnerable to a terrorist attack that could have
direct negative impacts on plant safety systems and ultimately have catastrophic
consequences.
*******
NRC Comments Regarding Exercise Scenario Are Misleading To The Public and
Press
We are troubled by statements made to the press by Brian Holian, deputy director
of reactor projects for NRC Region I. Holian’s statements were clearly
designed to imply that the scenario involved the 767 crashing into a containment
dome but failing to penetrate. A June 10, 2004 MSNBC article which can be viewed
at http://msnbc.msn.com/id/5181243/ features the following quote from Brian
Holian that illustrates our concern:
“The scenario of the crash included no damage to the reactor’s concrete
containment building. Brian Holian, of the Nuclear Regulatory Commission, said
recent studies showed “most plane crashes into containment buildings would not
result in significant releases of radiation.”
Clearly this statement reflects the broader public relations effort described
above.
--30--
RIVERKEEPER/IPSEC LETTER TO FEMA AND NRC
June 23, 2004
Joseph F. Picciano
Acting Regional Director, Region II
Federal Emergency Management Agency
26 Federal Plaza, Suite 1307
New York, NY 10278-0001
Hubert Miller
Regional Administrator, Region I
U.S. Nuclear Regulatory Commission
475 Allendale Road
King of Prussia, PA 19406
Re: Indian Point Radiological Emergency Preparedness Exercise on June 8, 2004
Dear Mr. Picciano and Mr. Miller:
On behalf of Riverkeeper and the Indian Point Safe Energy Coalition (IPSEC),
which includes approximately 70 environmental and citizen organizations, we
submit the following comments regarding the June 8th biennial radiological
emergency preparedness exercise conducted for the Indian Point nuclear power
plant and the surrounding region.
For the reasons explained below, the Department of Homeland Security, the
Federal Emergency Management Agency and the Nuclear Regulatory Commission must
not and cannot certify the Indian Point emergency plan based on the June 8th
emergency exercise.
The question that the public, various public interest groups and hundreds of
elected officials would like an answer to is whether the public’s health and
safety can be protected during a radiological emergency at Indian Point. The
June 8th in-sequence exercise fails to provide an answer to this fundamental
question. Failing to incorporate a simulated release of radiation, the exercise
was not able to assess whether official orders issued to the public to evacuate
or shelter would have succeeded in protecting the public from receiving an
unacceptable dose of radiation.
Today, a nuclear power plant could not be built at Indian Point given a variety
of reasons including the site’s location in the midst of such a densely
populated metropolitan region. Your respective agencies would have a difficult
time disputing this fact. But what is so disturbing is how your respective
agencies can justify the plant’s continued operation.
We remind you that many of the recommendations and concerns raised in this
letter echo those that were described in an October 25, 2002 letter to your
office from Riverkeeper and IPSEC critiquing the September 27, 2002 exercise.
An April 22, 2004 letter to DHS/FEMA from Riverkeeper and IPSEC provided your
agencies with our 15 point plan for improving the biennial exercise in a manner
that would help to better assess the effectiveness of the Indian Point emergency
plan. The 15 point plan is included as Attachment A to these comments in
response to the June 8th exercise.
General Comments On The June 8, 2004 Biennial REP Exercise
The June 8th exercise was based on a badly-flawed federal emergency preparedness
policy and an unworkable emergency plan that fails to take into consideration:
• a fast breaking release of radiation;
• the contamination of a significant portion of the 10-mile emergency planning
zone (EPZ) and the 50-mile ingestion pathway zone exposing citizens with unsafe
doses of radiation;
• citizens from within the 10-mile EPZ spontaneously self-evacuating and
causing immediate traffic problems;
• citizens within the 50-mile radius “shadow evacuating” and triggering
massive traffic problems and hindering those within the 10-mile radius from
escaping from the plume’s pathway;
• that multiple attacks in the region would hamper the initial emergency
response and treatment of those injured. (The recently released statements by
the 9/11 Commission indicate that Al-Qaeda attack planning was much more
aggressive and ambitious than the 9/11 attacks which involved 4 airliners. This
would suggest that multiple attacks are certainly within the scope of terrorist
intentions.);
• that major transportation arteries may be rendered impassable to people
evacuating and first responders traveling to their respective destinations (i.e.
hospitals or traffic control points);
• the challenges involved with safely evacuating and sheltering nursery school
children;
• the challenges involved with safely evacuating and sheltering unsupervised
“latchkey” children;
• the ability of hospitals throughout the region to decontaminate hundreds if
not thousands of contaminated people;
• the ability of hospitals throughout the region to handle people who have
been both injured and contaminated; and
• the ability of hospitals to handle a large influx of the “worried well”
who do not require decontamination but will likely overwhelm the region’s
emergency rooms.
A more rigorous exercise would have taken these scenarios into consideration.
DHS/FEMA and NRC are obligated to incorporate these scenarios into future
exercises. A more rigorous exercise would reveal the flaws within the
preparedness plan and convey to key decision-makers that the emergency plan is
unworkable and, in numerous ways, unfixable. Indian Point should not be allowed
to operate with an unworkable emergency plan that threatens the lives of
millions of residents and the first responders who are being asked to put
themselves in harm’s way.
Indian Point Is A Unique Case
As many citizens, public interest groups, and elected officials have
appropriately noted, Indian Point is a unique case. The following points convey
why Indian Point presents determined terrorists with an attractive target and
why Indian Point’s radiological emergency preparedness and recovery plan faces
numerous challenges:
• Of the nation’s 65 commercial reactor sites, the Indian Point nuclear
power plant, located just 35 miles north of Times Square, tops the list as the
plant with the greatest population density within a 10-mile (300,000 people) and
50-mile radius (20 million people);
• Indian Point presents terrorists with a pre-deployed radiological weapon.
(Indian Point has a large quantity of irradiated - or “spent” - fuel on
site; in fact, one of the largest quantities in the northeast. Exacerbating the
problem, Entergy is providing inadequate protection for this high level
radioactive waste.);
• The catastrophic health consequences of a large radioactive release from the
plant;
• The catastrophic economic consequences of a large radioactive release from
the plant. (The economic impacts of a large radioactive release from Indian
Point could be much more far-reaching than the attacks of 9/11.);
• Indian Point’s vicinity to the reservoir system that supplies 9 million
NYC metropolitan residents with drinking water;
• Indian Point’s vicinity to the nation’s, if not the world’s largest
financial center;
• The impossibility of implementing and enforcing such necessary security
measures as a “no-fly” zone;
• Indian Point’s vulnerabilities and security lapses. Indian Point has had
more security officers speak out about security lapses and lax measures than at
any other nuclear power plant in the nation;
• In an unprecedented move, hundreds of area first responders signed a
petition to FEMA expressing their doubt in the effectiveness of the emergency
plan;
• Inability to account for the behavior of area residents who have directly
experienced and been personally impacted by the terrible 9-11 attacks, not to
mention being perpetually bombarded with warnings of future attacks in the NYC
metropolitan area; and
• Inability to account for the behavior of the region’s first responders
(police, fire, EMS, hospital personnel, etc) who remain under-funded,
under-trained, and poorly equipped. In addition, the media has publicized the
mistreatment of first responders who have fallen ill after heroically performing
their duties at the World Trade Center site on September 11th and the days that
followed. First responders may think twice about performing their duties for a
variety of reasons including putting their families first.
In several sections the March 2003 final report issued by James Lee Witt
Associates highlights a few of the unique circumstances associated with Indian
Point. Provided below are two excerpts from the Witt report:
“The area around the Indian Point site is perhaps the most densely-populated
of any nuclear power plant in the United States. The NRC standard, minimizing
the radiological dose to the public for a spectrum of accidents, is harder to
achieve in such an area. The State of New York should request that FEMA and the
NRC develop unique performance requirements in recognition of the special
challenges posed by population density and the larger number of people who may
be at risk. It is prudent to have higher requirements for emergency management
in this region as compared to less densely populated regions.” (Page 229)
“The public behavior calculus should also include the special concerns of the
people in New York. Having lost many lives in the 9/11 tragedy, they may be
especially vulnerable to concerns about terrorism; accordingly, their behavior
may be markedly different from what may be expected at other regions and
locations.” (Page 230)
If the former head of FEMA recognizes this crucial point, then your respective
agencies should also be able to comprehend this basic and undeniable fact. DHS,
FEMA, and the NRC must factor in these unique aspects when assessing the
adequacy of Indian Point’s emergency plan.
Early Warning Built Into The Scenario
As we understand the scenario, off-site officials began to be notified shortly
after a police investigation of a car crash resulted in the discovery of
diagrams of the Indian Point nuclear power plant found inside a wrecked car.
This notification occurred well before off-site officials learned that a plane
was headed towards Indian Point and prior to the subsequent crash. As a result,
off-site officials were provided with early warning enabling them to take
initial steps to ensure for a timely and effective emergency response.
Additionally, plant operators were provided with early warning and were able to
take initial emergency response procedures even prior to learning that a plane
was headed towards Indian Point. Clearly, this scenario incorporated a “lucky
break” that afforded off-site officials and the plant operators with early
warning. But, what if the diagrams were not discovered in the wrecked car?
The scenario involved another example of early warning when plant operators were
notified that a plane was approaching the plant. This enabled plant operators to
initiate plant shutdown prior to the plane crash.
A real terrorist attack – air, land or river-based – may not allow for early
warning. A more rigorous exercise would have involved a scenario where there was
little to no warning of a pending attack.
Potential For A Catastrophic Scenario
The 767 cargo plane crashed into an on-site electrical transformer. However,
determined terrorists targeting Indian Point may succeed in breaching a reactor
containment dome and damaging the reactor core resulting in a subsequent release
of radiation. A successful terrorist strike could also cause a drain-down of a
spent fuel pool which could result in a pool fire and release of radiation. Both
scenarios can result in large releases of radioactivity. Other possible
scenarios the NRC should be considering include: (a) a cargo plane, fully loaded
with heavy earth-moving machinery (i.e. bulldozers) in the cargo bay, being
flown into a containment dome; and (b) a smaller plane loaded with powerful
explosives flown into the spent fuel pool building.
Scenario Separated Terrorist-Related Aspects From Plant Safety System-Related
Facets
The scenario used for the June 8th exercise deliberately separates the initial
terrorist plot to attack the Indian Point nuclear power plant from the safety
system-related events that unfolded later on in the scenario. This is an obvious
and purposeful ploy that is indicative of a broader public relations effort on
the part of the DHS, FEMA, NRC and Entergy designed to dupe the public into
believing Indian Point is not vulnerable to a terrorist attack that could have
direct negative impacts on plant safety systems and ultimately have catastrophic
consequences.
NRC Comments Regarding Exercise Scenario Are Misleading To The Public and
Press
We are troubled by statements made to the press by Brian Holian, deputy director
of reactor projects for NRC Region I. Holian’s statements were clearly
designed to imply that the scenario involved the 767 crashing into a containment
dome but failing to penetrate. A June 10, 2004 MSNBC article which can be viewed
at http://msnbc.msn.com/id/5181243/ features the following quote from Brian
Holian that illustrates our concern:
“The scenario of the crash included no damage to the reactor’s concrete
containment building. Brian Holian, of the Nuclear Regulatory Commission, said
recent studies showed “most plane crashes into containment buildings would not
result in significant releases of radiation.”
Clearly Mr. Holian’s statements reflect the broader public relations effort
described above.
Notification Of Pre-Schools And Day Care Centers During The Exercise
According to a Lakeland Central School District administrator, the pre-schools
(six in total) in the Lakeland Central School District were not notified during
the exercise. It is our understanding that in general pre-schools or day care
centers were not notified during this exercise. The exercise simply did not
require notification to pre-schools and day care centers. Future exercises
should assess this important step in the notification process.
Public Participation
DHS/FEMA must involve the public to a greater degree in the exercise and
radiological emergency preparedness in general. The March 2003 report by James
Lee Witt Associates recommended that “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.” The Witt report called for greater public involvement in emergency
planning: “Cities, special facilities, private employers, and selected citizen
groups or neighborhoods should be encouraged to participate in exercises…We
further recommend that interested stakeholders be allowed to observe these
exercises.”) The Witt report noted that including the public would only result
in a stronger emergency plan.
Public Exit Meeting
The public exit meeting should be a formal and officially recorded (i.e.
transcript) meeting that is scheduled both during the day and evening to afford
the public an adequate opportunity to participate and provide comments.
Just Who Is Running This Show Anyway?
Entergy should bear the burden of the costs associated with Indian Point’s
radiological emergency preparedness plan. However, that does not mean that
Entergy should have undue influence over the exercise itself. But time and
again, the appearance on the day of the exercise and the public exit meeting was
that Entergy was running the show. There were several situations where Entergy,
playing the role of “gatekeeper,” made unilateral decisions to challenge the
presence of public interest group representatives at the exercise and exit
meeting. If NRC and FEMA are the primary coordinators of the exercise and exit
meeting and the agencies that are responsible for plan evaluations, why has
Entergy assumed such authority? In the future, we urge your respective agencies
to serve as the chief liaisons to the public and public interest group
representatives on the day of the exercise and the exit meeting.
We close by reminding your respective agencies of the statement made by the
NRC’s Director of the Office of State Programs, Robert Ryan, to the
President’s Commission on the Accident at Three Mile Island in the fall of
1979. Ryan declared:
“I think it is insane to have a three-unit reactor on the Hudson River in
Westchester County, 40 miles from Time Square, 20 miles from the Bronx. And if
you describe that 50-mile circle, as I said before, you've got 21 million
people. And that’s crazy. I'm sorry. I just don't think that that's the right
place to put a nuclear facility.
And it was bad enough to put one in, but subsequently they put another and then
yet another … (I)t's a nightmare from the point of view of emergency
preparedness.”
(Refer to Appendix B for additional information)
We hope you find this input helpful and that your agencies will take the time to
seriously consider our recommendations and incorporate them into the policy that
governs radiological emergency preparedness for the Indian Point nuclear power
plant.
Sincerely,
Alex Matthiessen,
Hudson Riverkeeper
& Executive Director
Riverkeeper, Inc.
Melissa Jameson
Coordinator
IPSEC (Indian Point Safe Energy Coalition)