Indian Point Emergency Preparedness 3.2 Specific Shortcomings in Current Emergency Management Processes The bulk of the draft Witt Report is an extensive description and assessment of the emergency management process, including plans, procedures and methods at the state, county, municipality and utility-owner level. The report raises various questions, potential issues, and areas of needed improvement and offers numerous conclusions and recommendations. Despite its evident value as an evaluation tool, we find that the draft Witt Report in this area is in many respects misleading or incorrect, as follows: The report provides little perspective on issues. It does not distinguish between fundamental problems and relatively minor discrepancies, nor does it properly characterize most of its findings as part of the continuum of evaluation and improvement to which emergency management processes are subjected. As one example, it implies [page 209] that the potential for some individuals to be occasionally out of earshot of sirens or tone-alert radios is a significant deficiency in the emergency notification system. This is not the case, and in fact the draft Witt Report itself points out that “the siren coverage requirements of FEMA are indeed being satisfactorily met by the Alert and Notification Plan at Indian Point." [page 110]. There are numerous, significant errors of fact in the draft Witt Report o Contrary to the report assertion [page x], plastic map overlays are not the primary means for determining the area at risk during radiation release conditions. This process is computerized, using state-of the art methods, including transfer of information to state and county response organizations. The overlays and associated hand calculations are used as a check on the computerized calculation and also serve as an independent back-up method. o The Draft Witt Report asserts [page 185] that the Indian Point emergency plan exercise program has not addressed a "fast-evolving accident” (i.e., one with radiological consequences to the population in less than six hours from initiation) in the last seven years (1996 to 2002). This is not correct. In fact, in the last two years nearly all Indian Point exercises use scenarios with significant offsite radiological consequences starting sooner than six hours. The draft Witt Report seems not to recognize that nuclear plant emergency management processes are largely based on experience in actual emergency events at nuclear and other facilities, or that they are prescribed by regulatory requirements at the state and federal level (including those set by FEMA). The report criticizes methods that have proven effective and that are endorsed or Indian Point Emergency Preparedness currently required. Again, an example is its assertion [page 13] of “overreliance on out-dated sirens and the Emergency Alert System" and that "More and better means of reaching and warning people are needed" [page 209]. The existing siren warning system, with EAS for follow-up warning is an established, regulatory and compliant process. IETF Conclusion: The draft Witt Report alleges many specific shortcomings in the processes used by state, county, municipality and plant management in dealing with emergencies at Indian Point. Some of these are valid, some not. Many are minor, and the report provides no perspective as to their relative importance. Many of these observations merit consideration, but they do not form the basis for sweeping conclusions regarding emergency management effectiveness in protecting the public. 3.3 Implications of High-density Population The draft Witt Report argues that nuclear plants (such as Indian Point) "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" [pages vii, viii and 240]. The report fails to provide evidence or support for this conclusion. The logical implication of this assertion is that emergency management processes and requirements are generic and are not configured to accommodate plants with high population densities. That is not the case. Planning for nuclear power plant emergencies is plant specific, and is explicitly mandated to consider population density and other location-specific parameters. The Indian Point plans have taken relevant considerations into account including population distribution, transportation infrastructure, topography and other factors. Thus, the requirements for Indian Point emergency management are in fact "different...than plants otherwise situated", just as the draft Witt Report recommends. Further, the report concurs with the Indian Point treatment of population. - Population estimates used in planning at Indian Point were reasonable [page Alert notification systems met noise levels required for given population The population assumptions used in evacuation time estimates were valid We note also that the draft Witt Report's general assumption regarding the adverse effects of higher population - while perhaps intuitive - is not necessarily correct. In particular, it fails to reflect that emergency response resources co-vary with Indian Point Emergency Preparedness Independent Expert Task Force population density. Plant sites with higher populations also have more transportation resources, emergency responders, and emergency system infrastructure resources. As a practical example, the time it takes to evacuate an area is not solely a function IETF Conclusion: The emergency management regulatory requirements and processes currently in place in the areas around Indian Point already take into account the high population density in that area. 3.4 Increased Threat due to Terrorism 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 terroristinduced 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 terrorist-induced events. Further, there has been a great deal of evaluation of the post 9/11 terrorist threat Indian Point Emergency Preparedness 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 the containment and safety systems. A direct hit on a nuclear plant containment by a large, fully loaded commercial aircraft 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. 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. Based on a comparison of the reference [3] and [4] results with those from probabilistic risk assessments (PRAs) performed for U.S. operating nuclear plants over the last 15 years [5], it is clear that the consequences of terrorist-induced core damage events would be no greater than consequences from accidental core damage events. Emergency Plan Treatment of Terrorist-Caused Events Contrary to draft Witt Report assertions, existing emergency plans do in fact address potential impacts of a terrorist event. Therefore, emergency plan annexes or other separate consideration of terrorist-caused releases, as recommended by the report [page ix] are unnecessary. Consider the following: Nuclear Regulatory Commission (NRC) emergency planning guidance is based on a spectrum of accident types, including accidents with large, rapid release as well as slower accidents. These accidents envelop those from terrorist-induced events, as explained above. Emergency planning is driven by the consequences, not the cause of an event. Indian Point Emergency Preparedness • Existing emergency plans, at the county level, methodically address impediments to evacuation, regardless of cause, including terrorist events. The draft Witt Report asserts [page185] that the Indian Point emergency plan exercise program has not addressed a "fast-evolving accident" (i.e., release within six hours). In fact, nearly all Indian Point exercises in the last two years employed scenarios with offsite radiological consequences beginning sooner than six hours. IETF Conclusion: The draft Witt Report underlying assumption that a terrorist-caused radiation release at Indian Point would be more severe in magnitude and timing than that for which the emergency management process is designed is not correct. Emergency management processes accommodate radiation releases regardless of source or cause. Appendix C discusses the draft Witt Report treatment of terrorist-related events in more detail. 3.5 Adequacy of Current Emergency Management Processes In its single most important conclusion, the draft Witt Report finds that, with respect to the factors discussed in sections 3.1 through 3.4 above, "current radiological response system and capabilities are not adequate to overcome their combined weight (emphasis added) and protect the people from an unacceptable dose of radiation in the event of a release from Indian Point [pages viii and 240]". This conclusion is wholly unsupported by the balance of the report. It does not stem We know from real life experience, and particularly from non-nuclear emergencies that have occurred within the nuclear plant emergency planning zones, that nuclear plant emergency planning processes do work. Two specific examples are: Plans developed for the Waterford Plant were used to successfully warn and evacuate residents of Taft, LA, following a chemical plant accident [20]. This event was acknowledged in the draft Witt Report [page 241] Following a fire at a metal processing plant in Nanticoke, PA, local officials used procedures developed for the Susquehanna Nuclear Station to conduct a successful warning and night-time evacuation. [21] |