Indian Point Emergency Preparedness Independent Expert Task Force Appendix B: EM Treatment of Public Protection Challenges Challenge Parental behavior that would compromise school evacuation Examples of EM Actions Umatilla, Oregon has dramatically increased parent's awareness of the need to stay away from the school in the event of a chemical accident [9]. Difficulties in communications systems Communication is both a hardware and a Lack of first responder confidence in the plan(s) Problems caused by spontaneous evacuation human problem [10]. Research has extensively The events of 9/11 shook first responder Problems caused by shadow evacuation Shadow evacuation occurs in most events. Road system inadequacies Public education Large day-time transient populations (commuters) Non-English speaking populations Hurricane planning assumes that it will occur [13]. Evacuation planners use traffic control strategies, such as lane reversal, to increase road capacity [14]. Although the adequacy of public information with respect to amount, content and channel of Indian Point Emergency Preparedness Independent Expert Task Force Appendix C: Release Threats due to Terrorism This appendix is an expansion of Section 3.4 in the main report, regarding the draft Witt Report treatment of terrorist-related events. Although not mentioned in the stated purpose of the draft Witt Report, it is clear that the underlying context of the JLWA assessment is the implicit threat of terrorism, post September 11. It is also clear that its assumptions regarding the potential consequences of a terrorist-induced radiological release at Indian Point had strong bearing on the report's conclusions. The report's conclusions in this area are rooted in two premises: (1) the consequences of a terrorist-induced accident at a nuclear plant are unique, and (2) existing Indian Point emergency planning does not accommodate the ramifications of a terrorist-caused release. Neither is correct, as explained in the following sections. Consequences of Terrorist-induced Event: The assumption that the consequences of a radionuclide release caused by terrorist action are unique [pages vii and 240] is not correct. From a technical standpoint, there is no difference in the magnitude and timing of radionuclide releases from accidental core damage events (i.e., core damage events caused by accidental equipment failure and/or human error) which are the basis for existing emergency planning, and the magnitude and timing of radionuclide releases from terrorist-induced core damage events. Since existing emergency planning considers very severe accidents, including large-break loss of coolant accidents and impaired containment, this is, the case even for extreme terroristinduced events. Further, there has been a great deal of evaluation of the post 9/11 terrorist threat and its implications on nuclear safety. The IETF reviewed two recent studies on the consequences of terrorist attacks on nuclear plants [3, 4]. These studies conclude that: The risk to the public resulting from a core damage event caused by an armed terrorist ground attack on a U.S. commercial nuclear power plant is small, and less than the risk from accidental core damage events postulated for U.S. commercial nuclear plants. Given an armed terrorist ground attack, core damage is unlikely because of nuclear plant owner capabilities to detect insider activities, to physically deter the attackers, and to mitigate accident propagation with operator actions and safety systems. The likelihood of severe release is further reduced by the inherent strength of containment and radioactivity removal capabilities of containment and systems. A direct hit on a nuclear plant containment by a large, fully loaded commercial aircraft (Boeing 767-400) would not breach the containment structure, and thus the reactor fuel would be protected. Similarly, a direct aircraft hit on spent fuel storage structures would not cause breech. Indian Point Emergency Preparedness Independent Expert Task Force Because of their very strong and effective security systems, safety systems, and containment structures, and the attendant likelihood that the health consequences of a terrorist-induced event would be relatively minor, commercial nuclear plants are considered unattractive targets for terrorist groups intent on causing loss of life. While the study details are safeguards information and thus cannot be released to the public, the study clearly shows that the probabilities and consequences (i.e., the likelihood of core damage, and the resulting fission product release magnitude and release timing) of terrorist-induced core damage events are no greater than consequences from accidental core damage events (i.e., core damage events caused by accidental equipment failure and/or human error) based on a comparison of the reference [3] results with results from probabilistic risk assessments (PRAs) performed for U.S. operating nuclear plants over the last 15 years. Table C-1 illustrates these results, comparing the calculated core damage frequency and the large, early release frequency (a measure of the likelihood of a large, fast radioactive release) for an armed terrorist ground attack event with those calculated for previously evaluated accidents. The results for accidental events are taken from an NRC study that set the standard for U.S. operating plant PRAs in the late 1980s [5]. The Indian Point plant PRAS give similar results to the NRC study. As is evident from Table C-1, the probabilities and consequences of the terrorist-induced event are a small fraction of that from accidental events. Table C-1: Comparison of Core Damage and Release Frequencies for The results of the study on aircraft impact [4] indicate that a direct hit on a nuclear plant containment by a large, fully loaded commercial aircraft (Boeing 767-400) would not breach the containment structure, and thus the reactor fuel would be protected. The study reached the same conclusion for spent fuel storage structures. Emergency Plan Treatment of Terrorist-Caused Events The IETF evaluation of terrorist-caused release indicates that existing emergency plans do in fact address potential impacts of a terrorist event, and that annexes or other separate consideration of terrorist-caused releases are unnecessary in emergency plans. Thus Indian Point Emergency Preparedness terrorist-caused release is not expected to have significant ramifications on emergency plans. This is based on the following: The fact that the radiological consequences of terrorist-induced accidents, both armed ground attack and commercial aircraft impact, are not unique as discussed above. The fact that existing emergency planning guidance is based on a spectrum of accident types. NRC/EPA report NUREG-0396 [6], which is the technical basis for the 10 mile plume exposure pathway emergency planning zone (EPZ), is in turn based on work which includes accidents with large, rapid release as well as slower accidents. NRC/FEMA report NUREG-0654 [7], which provides criteria to licensees and offsite agencies on emergency plan preparation and implementation, specifies that the time at which the major portion of the release can occur is from 1 hour to 24 hours after the initiating event (see Table 2 of reference [7]). Reference [3] indicates that this time for terrorist-induced core damage accidents is approximately 2 hours to 24 hours. The fact that existing emergency plans, at the county level, have a process in place to address Impediments to Evacuation. Such impediments can result from a variety of non-terrorist causes including overturned tractor-trailers, downed trees or high voltage wires, and stalled vehicles. Other than extreme, act of war events, the process to address such impediments would also be expected to be applicable in addressing potential terrorist-caused impediments. The draft Witt report contained a statement that the Indian Point emergency plan exercise program has not addressed a "fast-evolving accident” (potential to cause radiological consequences to the population in less than 6 hours) in the last seven years (1996 to 2002). To evaluate this assertion, the IETF assessed the accident scenarios used in exercises and drills over a several year period. The results indicate that most Indian Point exercises used scenarios with radiological consequences to the public starting sooner than six hours. It should be noted that the need to address fastevolving accidents in exercises exists independent of terrorist-induced events. Table C-2 lists each of the statements in the draft Witt Report regarding the terrorist threat, along with the Independent Expert Task Force (IETF) response to the statements. Inaran Point Emergency Preparedness Table C-2: Summary of Witt Report Terrorist-Related Statements and IETF Responses Executive Draft Witt Report Statement and Source "We are concerned that when plans and exercises, which omit such things as... 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. " "Terrorist annexes or components should be added to Summary (Major the plans, along with consideration of the unique Recommendations) | implications of a terrorist event.' Executive "The exercise system should include a number of Summary (Major scenarios, including fast-breaking events that occur Recommendations) with little or no warning. Large shadow evacuation, especially for a terrorist event, should be included." "Plans that are developed and exercised to protect the population against an accidental release can be effective in preparing for an intentional (i.e., terroristinitiated) release as well. Section 3.1 Section 3.1 " "There may be significant differences in the release IETF Response Existing emergency plans are based on a broad spectrum of As noted above, the radiological consequences of a terrorist The consequences of a terrorist event are not unique, as noted above; separate plan annexes or components for terrorist accident consequences are not necessary. The exercise process already includes a number of scenarios with a range of timing; shadow evacuation is not unique to terrorist events. We agree. As noted above, the release characteristics associated with a Page 28 |