10-MILE AND 50-MILE EMERGENCY PLANNING ZONES

The 10-mile evacuation zone was determined by a multi-agency task force that included the NRC, FEMA, the Environmental Protection Agency (EPA) and others. The 10-mile zone is considered by most experts to extend far beyond an area where the radiation release would cause an immediate threat to public health. A small portion of residents within the 10-mile emergency planning zone would evacuate in the unlikely event of a reactor accident, but sheltering in place would provide the health and safety benefits for most residents in that area. Unfortunately, those who are seeking to shut the plant prematurely imply that everyone within 50 miles of the plant would need to evacuate. That is simply not true. There are, however, requirements in Entergy's emergency plan for the facility to test water, produce and dairy products within a 50-mile radius of the plant to ensure that these products are safe for public consumption.

Nuclear power plant emergency planning zones (EPZ) consist of two major parts. The first is the plant site itself and a 10-mile radius around the plant. The second is a 50-mile radius of the site that does not require evacuation, but rather is an area where products like agriculture and livestock are monitored.

The 10-mile zone was based on the NRC's conservative analysis showing that there would be little impact on public health beyond the 10-mile radius due to a release of radioactivity from a serious reactor accident. Extensive studies have shown that it is extremely unlikely that radiation exposures to persons within the 10-mile EPZ would exceed the limits established by the EPA-1 rem for whole body dose, compared to an average dose of .36 rem per year from natural and man-made radiation sources, and 5 rem for thyroid dose. These levels are far below the doses for which public health effects would occur and for which long-term health effects, primarily cancer, are known to occur. By comparison, a whole body CT scan, a popular elective medical procedure, results in a dose of 2 rem to the body-twice the dose at which protective action would be taken in the case of a release of radiation from a nuclear power plant. At Three Mile Island in 1979, the highest public wholebody dose was 0.08 rem and the highest thyroid dose was about 0.01 rem-too low to cause any health effects.

The industry and the state and counties within the 10-mile zone develop and regularly exercise comprehensive emergency response plans. In the event of an accident, these plans include gathering data from the nuclear plant and collecting independent data from state, county and federal resources to assess possible exposures to the public from the plant. The participants also evaluate action required to protect the plant workers and the public, including evacuation of persons from some parts of the 10-mile zone and sheltering—that is, staying indoors

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The radiation dose to the public in the 10-mile zone is a function of the concentration of the radioactivity in the plume. As the plume expands down wind, the concentration decreases, as docs the radiation dose-quickly and significantly.

Extensive knowledge of plume physics enables emergency planners and decisionmakers to take prompt actions to protect public health and safety. Because radioactivity released from a nuclear power plant does not move in all directions at once, but travels in a plume that covers a small fraction of the emergency planning zone, it is possible to move out of the plume by traveling a short distance perpendicular to the downwind direction of the plume.

In virtually all cases, the concentration and dose of the plume is reduced so significantly as distance from the plant increases, that there is no reason to take protective actions outside the 10-mile EPZ.

The 50-mile radius ingestion pathway EPZ was established to conservatively encompass an area that would be substantially less affected by releases of radioactivity in the event of a serious accident. The concern in the 50-mile EPZ is dose resulting from direct deposition of radioactivity on the ground, on commercial food crops, on surface water reservoirs, and on land used for grazing of dairy herds and meat sources. The radiation doses that could occur in the 50-mile EPZ following a release of radioactivity at Indian Point are very low-about the same level as a person's typical annual background dose levels. Federal guidance does not include evacuation of this zone because the risk of injury during evacuations themselves would be much greater than the minimal potential health effects from low levels of radiation in this zone.

In the case of Indian Point, there are very few commercial farming activities— vegetable, fruit, dairy, cattle or poultry—within 50 miles north and south of the Hudson River valley. Surface reservoirs of drinking water are to the east and northeast. Thus, under typical meteorological conditions, the low-level radioactivity that might be released from Indian Point would not substantially impact food, milk or drinking water supplies for persons living around the plant.

INDUSTRY CONCERNS ABOUT THE WITT REPORT

We are aware that the committee is particularly interested in the findings of a report entitled "Review of Preparedness at Indian Point and Millstone," drafted by James Lee Witt Associates and released on Jan. 10, 2003. We strongly urge the committee to recognize that the Witt report has only been released in draft form. Entergy was not provided a significant amount of time for input to that report. As a

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had the report's authors more extensively reviewed the emergency response plans and detailed implementing procedures currently in place at that facility.

The draft Witt report identified several areas that the industry will review and consider as part of its comprehensive review of security. For example, the report provides recommendations to upgrade equipment, provide training on emergency family protection and improve response times through drills. Other notable issues include notification procedures, the use of probabilistic safety assessments, population reviews and more effective public awareness and education.

However, the Witt report draft also raised many concerns that the industry believes are based on incomplete or inaccurate information. The industry disagrees with several of the key findings of the report. A copy of NEI's Feb. 7, 2003, letter providing industry comments on the Witt report is attached.

I would like to highlight three of our major concerns about statements in the draft report.

Much of the report is based on an assumption that people will not comply with official directions and, as such, evacuation plans for Indian Point do not consider the reality and impacts of a spontaneous evacuation. That assumption is not supported by experience with actual emergency evacuations.

A 1989 industry report provides insights and lessons learned from the analysis of more than 50 large-scale emergencies-both from natural and man-made events— that required the evacuation of up to 300,000 people. The report found that the evacuations proceeded smoothly and safely, even when managed by local response officials without advance preparation and with little or no evacuation training. Although many people may view an evacuation of 300,000 as being irrelevant to the Indian Point area, I urge the subcommittee to consider that the numbers of people that need to consider evacuation due to an accident at that plant have been grossly overestimated.

Second, the industry disagrees with the report's allegations that industry and state and local government emergency plans do not consider the additional ramifications of a radiation release caused by a terrorist and that the plans do not account for the impact of a spontaneous evacuation.

The Witt report ignores recent regulatory and industry actions that address the unlikely potential for a large radiation release resulting from a terrorist attack. Following Sept. 11, the NRC conducted a comprehensive review of nuclear plant security measures and policies and issued new requirements focused in part on emergency preparedness at plant sites in response to the potential for terrorist threats. These new NRC requirements addressed such issues as plant evacuation,

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communications with nearby communities, emergency staffing, procedures and plans.

Third, the draft report asserts that emergency preparedness exercises are of limited use in identifying inadequacies and improving emergency response programs. This assertion simply is not supported by actual evacuations and emergency planning drills. Nuclear plant emergency plans-well tested through regular exercises— have proven effective in evacuating residents during natural disasters such as hurricanes and in non-nuclear emergencies such as chemical spills and train derailments. The industry's success in emergency preparedness programs has been measured by exercises that have been critiqued, reviewed and approved by both the NRC and FEMA. The draft Witt report acknowledges that nuclear plant emergency programs are effective in responding to non-nuclear emergencies, yet it does not recognize the role exercises have played in making them so effective.

NRC Chairman Meserve, in a Feb. 12, 2003, letter, also challenged the conclusion of the Witt report in this area. Meserve wrote that emergency response plans, including the one at Indian Point, are designed to cope "with a spectrum of accidents, including those involving rapid, large releases of radiation." This is an important point that counters one of the principal findings of the draft Witt report and is the basis for other criticism of emergency response planning. A copy of Chairman Meserve's letter is attached.

In addition, a copy of a letter from EPRI to Witt Associates, dated Feb. 6, 2003, is attached. Based on its independent analyses of the consequences of potential ground-based terrorist attacks at a nuclear power plant, EPRI said that the risk to public safety from a terrorist attack on a nuclear power plant is very small. This risk is well within the safety standards established by the NRC and far below risks encountered in countless daily activities.

The analyses by EPRI and other independent engineering experts included issues such as the possibility that these terrorist threats could inflict damage on reactor fuel; the possibility and magnitude of radiation releases from a plant's containment building, which houses the reactor; and the possibility of public health consequences due to potential radiation exposures.

In the unlikely event of a radiation release, the EPRI study estimates that the likelihood of one fatality is less than one chance in 600,000 years-50 times lower than the NRC safety standard. The likelihood of one cancer-induced fatality is less than one chance in 300,000 years-1,000 times lower than the NRC safety standard. The long-term cancer fatality risk is indistinguishable compared to cancer fatality risks from other causes.

The low risk results from a combination of several factors: robust physical security

detailed emergency response plans; the capability of federal, state and local agencies to detect, interdict or disrupt an armed attack force. There is a low likelihood of reactor fuel damage due to plant security features, industry capability to detect "insider" activities, and multiple plant safety and shutdown systems that can be activated to stabilize the plant. The strength of the containment building and the radiation removal capabilities of plant systems further reduce the likelihood of a severe radiation release. Even in the unlikely event of significant radiation release, emergency response actions would limit public health consequences.

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THE WITT REPORT IS FUNDAMENTALLY FLAWED'

Following the release of the draft report, an independent task force of some of the most widely respected experts in emergency planning critiqued the report's findings. The task force issued a 39-page report on Feb. 7, 2003. Copies of this report will be made available to this subcommittee and are worthy of reading in detail. But the following conclusions by the experts stand out:

"[The task force] found the draft Witt report to be fundamentally flawed in several important respects, and therefore we do not consider it to be a valid basis, in its current form, for decision making.

■"The draft Witt report's most serious flaw is that it draws conclusions, on matters of great importance, with little apparent basis other than the opinions of its (unnamed) authors. As an example, it asserts that a terrorist-caused radiation release at Indian Point would likely be worse in magnitude and timing than that caused by accidents previously considered in safety and risk assessments of the plant. And, it compounds that error by asserting that the emergency management process does not accommodate the consequences of such terrorist-caused events. Both assertions are presented without reference, basis or explanation—and, in fact, both are incorrect."

It is unfortunate that the draft Witt report is so replete with factual errors and false assumptions, yet is being used by some as the basis for recommending closure of the Indian Point Energy Center. Entergy and state and local officials participated in an exercise of the Indian Point emergency plan last September and FEMA found no deficiencies in the plan during the exercise.

CONCLUSION

In conclusion, the industry urges Congress to consider security at nuclear power plants in the context of our nation's overall national security and energy security