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United States General Accounting Office:



GAO:



Testimony:



Before the Subcommittee on National Security, Emerging Threats and 

International Relations, Committee on Government Reform, House of 

Representatives:



For Release on Delivery:



Expected at 2:00 p.m. 

Monday, March 10, 2003:



NUCLEAR REGULATION:



Emergency Preparedness Issues at the Indian Point 2 Nuclear Power 

Plant:



Statement of Jim Wells, Director:



Natural Resources and Environment:



GAO-03-528T:



GAO Highlights:



Highlights of GAO-03-528T, a report to the Subcommittee on National 

Security, Emerging Threats and International Relations, Committee on 

Government Reform, House of Representatives 



Why GAO Did This Study:



After the September 11, 2001, terrorist attacks, emergency 

preparedness at nuclear power plants has become of heightened 

concern. Currently, 104 commercial nuclear power plants operate at 

64 sites in 32 states and provide about 20 percent of the nation’s 

electricity. In July 2001, GAO reported on emergency preparedness 

at the Indian Point 2 nuclear power plant in New York State (Nuclear 

Regulation:  Progress Made in Emergency Preparedness at Indian Point 

2, but Additional Improvements Needed [GAO-01-605, July 30, 2001]).  

This testimony discusses GAO’s findings and recommendations in that 

report and the progress the plant, the Nuclear Regulatory Commission 

(NRC), and the Federal Emergency Management Agency (FEMA) have made 

in addressing these problems. GAO also provides its thoughts on the 

findings of a soon-to-be-issued report (the Witt report) on 

emergency preparedness at Indian Point and the Millstone nuclear 

power plant in Connecticut, and the implications of that report for 

plants nationwide.



Since 2001, the Entergy Corporation has assumed ownership of the 

Indian Point 2 plant from the Consolidated Edison Company of New 

York (ConEd).



What GAO Found:



In 2001, GAO reported that, over the years, NRC had identified a 

number of emergency preparedness weaknesses at Indian Point 2 that 

had gone largely uncorrected. ConEd had some corrective actions 

underway before a 2000 event raised the possibility of a leak of 

radioactively contaminated water into the environment. ConEd took 

other actions to address problems during this event. According to 

NRC, more than a year later, the plant still had problems similar to 

those previously identified—particularly in the pager system for 

activating emergency personnel. However, NRC, in commenting on a 

draft of GAO’s report, stated that ConEd’s emergency preparedness 

program could protect the public. Four counties responsible for 

responding to a radiological emergency at Indian Point 2 had, with 

the state and ConEd, developed a new form to better document the 

nature and seriousness of any radioactive release and thus avoid the 

confusion that occurred during the February 2000 event. Because they 

are the first responders in any radiological emergency, county 

officials wanted NRC and FEMA to communicate more with them in 

nonemergency situations, in addition to communicating through the 

states. However, NRC and FEMA primarily rely on the states to 

communicate with local jurisdictions.  



Since GAO’s 2001 report, NRC has found that emergency preparedness 

weaknesses have continued. For example, NRC reported that, during 

an emergency exercise in the fall of 2002, the facility gave out 

unclear information about the release of radioactive materials, 

which had also happened during the February 2000 event. Similarly, 

in terms of communicating with the surrounding jurisdictions, 

little has changed, according to county officials. County officials 

told GAO that a videoconference system—promised to ensure prompt 

meetings and better communication between the plant’s technical 

representatives and the counties—had not been installed. In 

addition, NRC and FEMA continue to work primarily with the states 

in nonemergency situations. Although they note that there are 

avenues for public participation, none of these is exclusively for 

the county governments. 



GAO did not evaluate the draft Witt report or verify the accuracy 

of its findings. The draft Witt report is a much larger, more 

technical assessment than the 2001 GAO report. While both reports 

point out difficulties in communications and planning inadequacies, 

the draft Witt report concludes that the current radiological 

response system and capabilities are not adequate to protect the 

public from an unacceptable dose of radiation in the event of a 

release from Indian Point, especially if the release is faster or 

larger than the release for which the programs are typically 

designed. GAO is aware that, in commenting on a draft of the Witt 

report, FEMA disagreed with some of the issues raised but said the 

report highlights several issues worth considering to improve 

emergency preparedness in the communities around Indian Point and 

nationwide. NRC concluded that the draft report gives “undue 

weight” to the impact of a terrorist attack.



www.gao.gov/cgi-bin/getrpt?GAO-03-528.



To view the full report, including the scope

and methodology, click on the link above.

For more information, contact Jim Wells at (202) 512-3841 or 

wellsj@gao.gov.



Mr. Chairman and Members of the Subcommittee:



We are pleased to be here today to discuss emergency preparedness at 

operating commercial nuclear power plants. Twenty-four years ago, in 

March 1979, the accident at the Three Mile Island nuclear power plant 

in Pennsylvania created considerable alarm and uncertainty in the 

surrounding areas about the plant’s safety and the adequacy of 

emergency planning. On the broader front, the American public focused 

not only on Three Mile Island but also on safety and emergency 

preparedness at nuclear power plants nationwide. With the September 11, 

2001, terrorist attacks, public concern about the plants has increased 

again. Concerns have focused principally on ensuring the plants’ 

physical security and then on emergency preparedness in case terrorists 

are successful in their attacks. The nation currently has 104 

commercial nuclear power plants licensed to operate at 64 sites in 32 

states. These plants provide about 20 percent of the nation’s 

electricity.



To protect the public should a commercial nuclear power plant 

accidentally release radiation to the environment, the Nuclear 

Regulatory Commission (NRC) requires the plant owner/operator to 

prepare for NRC’s approval a radiological emergency preparedness plan. 

This on-site plan describes what is to be done in an emergency, how it 

is to be done, and who is to do it. Among other things, the plan 

identifies the process for notifying and communicating with the 

operator’s own personnel as well as with federal, state, and local 

agencies and the media during an emergency. The plan also identifies 

the circumstances and the actions--such as evacuating the local 

population--the plant owner would recommend that off-site officials 

take to protect the public. NRC conducts inspections to ensure that the 

plant owner can effectively implement the on-site plan. In addition, 

the Federal Emergency Management Agency (FEMA) is responsible for 

ensuring that state and local communities develop emergency 

preparedness plans to address the off-site effects of a radiological 

emergency. FEMA oversees the conduct of periodic exercises to determine 

whether the off-site response would adequately protect public health 

and safety.



My testimony today is grounded in a report we issued in July 2001 to 

the Chairman of the House Committee on Government Reform and to 

Representatives Gilman, Kelly, and Lowey on emergency preparedness at 

the Indian Point 2 plant in New York State.[Footnote 1] The Indian 

Point facility is located within the Village of Buchanan in upper 

Westchester County, approximately 24 miles north of New York City along 

the east bank of the Hudson River. About 300,000 people live within 10 

miles of the plant and millions more live in New York City and within 

50 miles in Connecticut, New Jersey, New York, and Pennsylvania. 

Concerns that nuclear power plants may be targets for terrorists and 

Indian Point’s close proximity to these large populations have 

increased public interest in the adequacy of the plant’s security and 

emergency preparedness--leading some to call for closing the plant. A 

draft report (the Witt report) commissioned by the Governor of New York 

questions the adequacy of emergency preparedness at Indian Point and 

raises broader issues about emergency preparedness at other nuclear 

power plants.[Footnote 2]



In my testimony today, I will discuss the (1) findings and 

recommendations of our 2001 report on emergency preparedness at the 

Indian Point 2 plant and (2) subsequent progress made by the plant, 

NRC, and FEMA in addressing problems noted in our report. You also 

asked for our thoughts on the findings of the draft Witt report and its 

potential implications for emergency planning at other facilities. To 

follow up on the progress made to address the problems we identified in 

2001, we reviewed relevant NRC inspection reports prepared since our 

2001 report and held discussions with officials of NRC, FEMA, and the 

four counties responsible for emergency preparedness in the surrounding 

areas. We did not conduct a comprehensive update of emergency 

preparedness at the Indian Point 2 plant nor verify the accuracy of the 

draft Witt report’s findings and conclusions. We should also note that, 

since our 2001 report, the Entergy Corporation has assumed ownership of 

the facility from the Consolidated Edison Company of New York.



In summary:



In 2001, we reported that, over the years, NRC had identified a number 

of emergency preparedness weaknesses at Indian Point 2 that had gone 

largely uncorrected. For example, in 1998 and again in 1999, NRC 

identified several communication weaknesses, including delays in 

activating the pagers used to alert the plant’s staff about an 

emergency. Consolidated Edison had some corrective actions under way 

before a February 2000 event raised the possibility that radioactively 

contaminated water would leak into the environment.[Footnote 3] 

Consolidated Edison initiated other actions to address problems that 

occurred during this event. However, according to an April 2001 NRC 

inspection report, the actions were not fully effective. In evaluating 

Consolidated Edison’s response to the February 2000 event, NRC found 

that critical emergency response personnel were not notified in a 

timely manner, which delayed the staffing and operation of the on-site 

emergency response facility. According to NRC, this delay occurred 

because the process to activate the pagers was complex and not well 

understood and Consolidated Edison had responded to the earlier 

problems identified without diagnosing their underlying causes. As a 

result, NRC found emergency preparedness problems similar to those it 

had identified before and during the event. Despite these weaknesses, 

NRC, in commenting on a draft of our report, expressed its view that 

Consolidated Edison’s emergency preparedness program could protect the 

public.



We reported in 2001 that the four New York counties responsible for 

responding to a radiological emergency at Indian Point 2 had 

strengthened their emergency preparedness programs as a result of the 

lessons learned from the February 2000 event. These lessons included 

the need for better coordination and communications (1) between the 

counties in responding to a radiological emergency and in providing the 

media with information and (2) between Consolidated Edison and the 

counties about the emergency and its potential impact on the public. We 

reported that Consolidated Edison had not clearly communicated with the 

state and counties about whether a radioactive release had occurred 

and, if so, its magnitude. Consolidated Edison reported that a release 

had occurred but posed no threat to the public, while county officials 

reported that no release had occurred. This contradictory information 

led to credibility problems with the media and the public. Consolidated 

Edison, the state, and the counties revised the plant’s radiological 

emergency data form to more clearly show whether a release had 

occurred.



As we also reported, county officials suggested changes to improve 

communications among NRC, FEMA, and nonstate entities. In particular, 

county officials said that since they are responsible for radiological 

emergency preparedness for Indian Point 2, NRC and FEMA should 

communicate directly with them during nonemergency situations. In New 

York and 16 other states--where more than half of the nation’s 

operating nuclear power plants are located--counties or other local 

governments are responsible for radiological preparedness, but NRC and 

FEMA communicated primarily with the states and relied on the states to 

communicate with local jurisdictions. In response, NRC said that 

meeting with local officials would require considerable resources, and 

FEMA said that some states limit its communications with local 

officials. However, NRC had not assessed the costs and benefits of 

routinely meeting with local officials, and FEMA’s method of 

communicating with the states had not effectively provided the four 

counties with information on various initiatives that would affect 

their programs. Since effective communication is critical to prepare 

for and respond to a radiological emergency, we therefore recommended 

that NRC and FEMA reassess their policies for communicating primarily 

with the state in those instances where other entities have a major 

role for responding to a radiological emergency.



Since our 2001 report, NRC inspection reports have continued to show 

emergency preparedness weaknesses. For example, NRC reported that, 

during an emergency exercise in the fall of 2002, the facility gave out 

unclear information about the release of radioactive materials, as it 

did during the February 2000 event. Similarly, in terms of NRC and FEMA 

communicating with the surrounding jurisdictions, little has changed, 

according to county officials. County officials told us that a 

videoconference system--promised to ensure prompt meetings and better 

communication between the plant’s technical representatives and the 

counties--had not been installed. During the February 2000 event, these 

representatives had arrived late at the counties’ emergency operations 

centers. NRC officials said that they meet with state officials 

concerning emergency preparedness and have instituted various 

initiatives to improve public communication, in which local officials 

can participate. FEMA officials told us that it would continue to work 

with state and local governments on emergency preparedness.



The draft Witt report is a much larger, more technical assessment than 

our 2001 report. While both reports talk to difficulties in 

communications and planning inadequacies, the draft Witt report 

concludes that the current radiological response system and 

capabilities are not adequate to protect the public from an 

unacceptable dose of radiation in the event of a release from Indian 

Point, especially if the release is faster or larger than the release 

for which the programs are typically designed. We are aware that, in 

commenting on the draft of the Witt report, FEMA disagreed with some of 

the issues raised but said that the report does highlight several 

issues worth considering in order to improve preparedness levels in the 

communities around Indian Point and nationwide. NRC concluded that the 

report gives “undue weight” to the impact of a terrorist attack. The 

agency said that it saw no difference between emergency plans for 

releases caused by terrorist acts and those caused by equipment 

malfunctions.



Background:



Emergency plans for commercial nuclear power plants are intended to 

protect public health and safety whenever plant accidents cause 

radiation to be released to the environment. Since the 1979 accident at 

the Three Mile Island nuclear power plant, significantly more attention 

has been focused on emergency preparedness. For example, the NRC 

Authorization Act for fiscal year 1980 established a requirement for 

off-site emergency planning around nuclear power plants and allowed NRC 

to issue a nuclear plant operating license only if it determines that 

there is either a

related state or local emergency preparedness plan that provides for 

responding to accidents at the specific plant and complies with NRC’s 

emergency planning guidelines or

state, local, or facility plan that provides reasonable assurance that 

public health and safety are not endangered by the plants’ operation in 

the absence of a related state or local emergency preparedness plan.



In November 1980, NRC and FEMA published regulations that provided the 

criteria for radiological emergency plans. The regulations include 

emergency standards for on-and off-site safety and require that 

emergency plans be prepared to cover the population within a 10-mile 

radius of a commercial nuclear power plant. In addition, state plans 

must address measures necessary to deal with the potential for the 

ingestion of radioactively contaminated foods and water within a 50-

mile radius. NRC and FEMA have supplemented the criteria several times 

since 1980. For example in July 1996, the agencies endorsed the prompt 

evacuation of the public within a 2-mile radius and about 5 miles 

downwind of the plant, rather than sheltering the public, in the event 

of a severe accident.



FEMA and the affected state and local governments within the 10-mile 

emergency planning zone conduct exercises at least every 2 years at 

each nuclear power plant site. In addition, each state with a nuclear 

power plant must conduct an exercise within the 50-mile zone at least 

every 6 years. The exercises are to test the integrated capabilities of 

appropriate state and local government agencies, facility emergency 

personnel, and others to verify their capability to mobilize and 

respond if an accident occurs. Before the exercises, generally, FEMA 

and state officials not involved in them agree to the accident 

scenarios and the aspects of emergency preparedness that will be 

tested. In addition, NRC requires plants to conduct exercises of their 

on-site plans. According to NRC staff, the plants usually conduct their 

exercises as part of FEMA’s biennial exercises.



Indian Point 2 is one of the 104 commercial nuclear power plants 

nationwide licensed to operate. The Indian Point site, which is called 

the Indian Point Energy Center, has one closed and two operating 

plants. The other operating plant is referred to as Indian Point 3.



In 2001, We Noted That Indian Point 2 Had Struggled:



to Resolve Emergency Preparedness Weaknesses:



Over the years, Consolidated Edison’s efforts to improve emergency 

preparedness at Indian Point 2 were not completely successful, and the 

company experienced recurring weaknesses in its program, as we reported 

in July 2001. The four New York counties surrounding the plant made 

improvements in their emergency response programs but suggested better 

communication among NRC, FEMA, and nonstate entities in nonemergency 

situations.



Consolidated Edison Acted to Resolve Emergency Preparedness:



Weaknesses, but Its Actions Were Incomplete:



Beginning in 1996, NRC identified numerous weaknesses with the 

emergency preparedness program at Indian Point 2. NRC found, for 

example, that Consolidated Edison was not training its emergency 

response staff in accordance with required procedures, and some 

individuals had not taken the annual examination and/or participated in 

a drill or exercise within a 2-year period, as required. In response, 

Consolidated Edison disciplined the individuals responsible, developed 

an improved computer-based roster containing the current status of the 

training requirements for emergency response personnel, and began a 

process to distribute training modules to those employees before their 

qualifications expired.



NRC relied on Consolidated Edison to take corrective actions for other 

emergency preparedness problems and weaknesses. However, the company 

did not correct the weaknesses identified. For example, in 1998 and 

again in 1999, NRC identified problems with activating the pagers used 

to alert the plant’s staff about an emergency, as well as other 

communication weaknesses. In 1999, NRC concluded that Consolidated 

Edison lacked the ability to detect and correct problems and determine 

their causes, resulting in weak oversight of the emergency preparedness 

program. In response, NRC staff said that they met with the company’s 

managers to specifically discuss and express NRC’s concerns.



Similarly, NRC identified emergency preparedness weaknesses when 

evaluating Indian Point 2’s response to the February 2000 event. For 

example, NRC found that Consolidated Edison did not activate its 

emergency operations facilities within the required 60 minutes, 

primarily because of the complex process used to page the emergency 

response staff. This problem delayed the on-site response. NRC’s Office 

of the Inspector General also identified emergency preparedness issues, 

including the state’s difficulties getting information about the 

emergency from Consolidated Edison and the fact that English is a 

second language for many who lived within 10 miles of the plant. The 

Office of the Inspector General concluded, and NRC agreed, that 

recurring uncorrected weaknesses at Indian Point 2 had played a role in 

the company’s response during the February 2000 event. However, NRC 

concluded that Consolidated Edison had taken the necessary steps to 

protect public health and safety.



Consolidated Edison subsequently evaluated its entire emergency 

preparedness program to determine the causes of the deficiencies and to 

develop corrective actions. Consolidated Edison concluded that senior 

management did not pay sufficient attention to the emergency 

preparedness program or problems at Indian Point 2 because these 

problems were not viewed as a high priority warranting close attention 

and improvement. As a result, emergency preparedness had relatively low 

visibility, minimal direction, and inadequate resources. The company 

also found that (1) the emergency response organization had been 

stagnant, understaffed, poorly equipped, and consistently ineffective; 

(2) the emergency manager performed collateral and competing duties; 

and (3) for a time, a contractor held the manager’s position. 

Furthermore, the professional development and continuing training of 

the emergency planning staff had been minimal. The company undertook 

initiatives to address the deficiencies noted.



Despite these initiatives, in April 2001, NRC reported that it had 

found problems similar to those previously identified at Indian Point 

2. NRC again found weaknesses in communication and information 

dissemination. It also found that the utility’s training program had 

not prevented the recurrence of these issues during on-site drills and 

that its actions to resolve other weaknesses had not been fully 

effective. NRC said that Consolidated Edison had identified the major 

issues in its business plan, which, if properly implemented, should 

improve emergency preparedness at the plant. In commenting on a draft 

of our July 2001 report, NRC noted that its April 2001 inspection 

report concluded that Consolidated Edison’s emergency preparedness 

program would provide reasonable assurance of protecting the public.



The Four Counties Strengthened Their Emergency:



Preparedness Programs but Suggested Better:



Communication Among NRC, FEMA, and Nonstate Entities:



The need to improve communication between Consolidated Edison and the 

counties about the extent of the emergency and the potential impact on 

the public was highlighted during the February 2000 event. At that 

time, Consolidated Edison reported that a radioactive release had 

occurred but that it posed no danger to the public. County officials, 

on the other hand, reported that no release had occurred. This 

contradictory information led to credibility problems with the media 

and the public.



Before the emergency, the counties did not have a defined process to 

determine what information they needed and how they would present the 

information to the public. At the time of the February 2000 event, the 

Radiological Emergency Data Form that Consolidated Edison used to 

inform local jurisdictions provided for one of three choices about a 

release of radioactive materials: (1) no release (above technical 

specification limits), (2) a release to the atmosphere above technical 

specification limits, and (3) a release to a body of water (above 

technical specification limits). In April 2000, Consolidated Edison, in 

partnership with the state and counties, revised the form to ensure 

that all affected parties were “speaking with one voice” when providing 

the media and the public with information. The change to the form 

provided for one of four choices: (1) no release, (2) a release below 

federally approved operating limits (technical specifications) and 

whether it was to the atmosphere or to water, (3) a release above 

federally approved operating limits and whether to the atmosphere or to 

water, and (4) an unmonitored release requiring evaluation.



The counties had also taken some other actions to improve their 

radiological emergency programs. For example, all four counties agreed 

to activate their emergency operation centers at the “alert” level (the 

second lowest of four NRC classifications). Before the February 2000 

event, the counties differed on when they would activate their centers, 

with one county activating its center at the alert level and the other 

three counties at the site-area emergency level (the next level above 

an alert). As a result, once the first county activated its center 

during the event, the media questioned why the other three counties had 

not done so. The counties also connected the “Executive Hot Line,” 

which linked the state, four counties, and governor, to the emergency 

operations facility at Indian Point 2 to establish and maintain real-

time communications during an emergency.



In addition to these actions, county officials suggested to us in 2001 

that other changes to improve communications among NRC, FEMA, and 

nonstate entities could be taken. In particular, county officials said 

that since they are responsible for radiological emergency preparedness 

for Indian Point 2, NRC and FEMA should communicate directly with them 

during nonemergency situations. Absent these direct communications, the 

counties were not privy to issues or initiatives that could affect 

their emergency preparedness programs.



NRC staff tried to meet every 5 years with officials from all states 

that have operating nuclear power plants. NRC staff told us that they 

met with some states more frequently and that the requests to meet 

exceeded the agency’s capability. Although NRC’s policy was to meet at 

the state level, its staff believed that local officials had various 

options for meeting with NRC. For example, local officials could 

participate in the meetings held at least every 5 years with the states 

and could interact with NRC staff during public meetings, including 

those held annually for all plants. Emergency preparedness officials 

from the four counties around Indian Point 2 said that they did not 

believe that public meetings were the appropriate forums for 

government-to-government interactions. Therefore, the counties 

suggested that NRC should meet with them at least annually. According 

to NRC staff, routinely communicating with local officials has resource 

implications and involves tradeoffs with its other efforts, such as 

maintaining safety and enhancing the effectiveness and efficiency of 

operations. However, NRC, at the time of our review, had not assessed 

the costs and benefits of meeting with local officials nor the impact 

that such meetings might have.



FEMA generally implements its programs through the states and relies on 

the states to communicate relevant information to local jurisdictions. 

County officials responsible for emergency preparedness at Indian Point 

2 identified instances in which this method of communicating with local 

jurisdictions had not been effective. For example, both New York State 

and county officials told us that the February 2000 event identified 

the need for flexibility in FEMA’s off-site exercises. County officials 

said they responded to the 2000 event as they would have responded 

during FEMA’s exercises, which are conducted to the general emergency 

level (the highest of NRC’s action level classifications). Yet, they 

noted, the response for an alert like the one that occurred in 2000 is 

significantly different from the response needed during a general 

emergency, when a significant amount of radiation would be released 

from the plant site. State and county officials suggested that it would 

be more realistic to periodically conduct biennial exercises at the 

lower alert level, which, they noted (and NRC data confirmed), occur 

more frequently than a general emergency. In commenting on a draft of 

our report, FEMA said that the emergency plans for the four New York 

counties require them to conduct off-site monitoring and dose 

calculations at the alert level.



FEMA officials also noted that the agency’s regulations allow state and 

local jurisdictions the flexibility to structure the exercise scenarios 

to spend more time at the alert level and less at the general emergency 

level. Nevertheless, county officials who participated in the exercises 

were not aware of the flexibility allowed by FEMA’s regulations, in 

part because they did not participate in developing the exercise 

scenarios.



Emergency Preparedness Weaknesses at Indian Point 2 Have Continued:



In reviewing NRC’s reports on its on-site inspections and evaluations 

of the plant’s emergency preparedness exercises or drills completed 

since we issued our 2001 report, we found that the facility’s emergency 

preparedness program has continued to experience problems or 

weaknesses. For example, NRC reported that, in an emergency exercise 

conducted last fall, the facility gave out unclear information about 

the release of radioactive materials, which also happened during the 

February 2000 event. In addition, NRC reported that several actions to 

correct previously identified weaknesses had not been completed. For 

example, NRC noted that the timely and accurate dissemination of 

information was identified as a weakness in the fall 2002 exercise and 

had been documented previously in drill critique and condition reports.



In addition, in our 2001 report, we noted that NRC’s Office of the 

Inspector General found that, during the February 2000 event, the 

Indian Point plant’s technical representatives did not arrive on time 

at the local counties’ emergency operations centers. To help address 

this problem, Consolidated Edison said that it would install a 

videoconferencing system in the centers to enhance communications 

between the plant and the off-site officials. According to county 

officials, the videoconferencing system had not been installed as of 

February 2003.



With respect to our 2001 recommendation that NRC and FEMA reassess 

their practices of primarily communicating with state officials during 

nonemergency situations, federal and local officials indicated that 

little has changed since our report. NRC officials told us that they 

did reassess their policy since our report was issued and determined 

that no changes were needed. According to FEMA officials, the agency 

will continue to work with state and local officials to carry out its 

emergency preparedness program but has not made any changes regarding 

nonemergency communication with state and local officials.



Given this history of inadequate efforts to address weaknesses in 

Indian Point 2’s emergency preparedness program, we continue to believe 

that both NRC and the plant owner could benefit from being more 

vigilant in correcting problems as they are identified. In addition to 

improving the plant’s program, a better track record in addressing 

these problems could go a long way in helping alleviate the heightened 

concerns in the surrounding communities about the plant’s safety and 

preparedness for an emergency. Similarly, more frequent, direct 

communication by NRC and FEMA with officials of the surrounding 

counties could improve local emergency preparedness programs and, in 

turn, help local officials better communicate with their constituents 

about the plant’s safety and preparedness for an emergency.



The Witt Report Raises Emergency Preparedness

Issues at Indian Point and Other Nuclear Power Plants:



On August 1, 2002, the Governor of New York announced that James Lee 

Witt Associates would conduct a comprehensive and independent review of 

emergency preparedness around the Indian Point facility and for that 

portion of New York State in proximity to the Millstone nuclear power 

plant in Waterford, Connecticut.[Footnote 4] According to Witt 

Associates, the review encompassed many related activities that were 

designed, when taken together, to shed light on whether the 

jurisdictions’ existing plans and capabilities are sufficient to ensure 

the safety of the people of the state in the event of an accident at 

one of the plants, and how the existing plans and capabilities might be 

improved. According to Witt Associates, it has considered and 

incorporated public comments on a January 2003 draft of its report and 

plans to issue the final report this month.



We have not evaluated the Witt report or verified the accuracy of its 

findings and conclusions. We did note that the draft report identifies 

various issues--such as planning inadequacies; expected parental 

behavior that would compromise school evacuation; difficulties in 

communications; the use of outdated technologies; problems caused by 

spontaneous evacuation in a post September 11, 2001, environment; and a 

limited public education effort--that may warrant consideration at 

Indian Point and nationwide. The draft Witt report concludes that NRC 

and FEMA regulations need to be revised and updated. We understand that 

FEMA agreed, to an extent, in its review of the draft report. According 

to the agency, the draft report raises a number of issues that should 

be considered for enhancing the level of preparedness in the 

communities surrounding the Indian Point facility, such as better 

public education, more training of off-site responders, and improved 

emergency communications. In addition, FEMA stated that some of these 

issues should be evaluated for their applicability nationwide. However, 

FEMA also said that a number of the issues raised in the draft report 

were not supported by its own exercise evaluations, plan reviews, and 

knowledge of the emergency preparedness program. According to NRC, the 

draft report gives “undue weight” to the impact of a terrorist attack. 

The agency said that it saw no difference between emergency plans for 

releases caused by terrorist acts and those caused by equipment 

malfunctions.



In summary, Mr. Chairman, the post September 11, 2001, environment 

clearly presents new challenges for NRC and FEMA. While the public has 

always had considerable interest in the safety of nuclear power plants, 

the terrorist attacks have brought a level of focus and anxiety that 

may rival or exceed that caused by the Three Mile Island accident in 

1979. NRC and the nuclear industry deserve credit for taking action to 

strengthen physical security as the result of a changing world, but we 

are still concerned that, as shown in this hearing today, problems in 

emergency preparedness remain after being repeatedly identified as 

needing attention. Mr. Chairman, GAO is currently conducting reviews of 

physical security at selected nuclear power plants and is looking in-

depth at safety issues at the Davis-Besse plant in Ohio. We plan to 

report the results of our work later this year.



Mr. Chairman, this concludes our prepared statement. We would be happy 

to respond to any questions that you or Members of the Subcommittee may 

have.



Contacts and Acknowledgments:



For further information about this testimony, please contact me at 

(202) 512-3841. Raymond Smith, William Fenzel, Kenneth Lightner, 

William Lanouette, Jill Edelson, Heather Barker, and Addison Ricks also 

made key contributions to this statement.



(360317):



FOOTNOTES



[1] NUCLEAR REGULATION: Progress Made in Emergency Preparedness at 

Indian Point 2, but Additional Improvements Needed, GAO-01-605 

(Washington, D.C., July 30, 2001). 



[2] James Lee Witt Associates, LLC, Review of Emergency Preparedness at 

Indian Point and Millstone [Draft] (Washington, D.C., Jan. 10, 2003). 

The Witt report was commissioned by Governor Pataki to be a 

comprehensive and independent review of emergency preparedness in the 

areas around Indian Point and for that portion of New York State in 

proximity to the Millstone nuclear power plant in Connecticut. 



[3] In February 2000, a tube ruptured in a steam generator and 

Consolidated Edison temporarily shut down the plant because of the 

possibility that radioactively contaminated water could leak into the 

environment. According to Consolidated Edison and NRC, the total amount 

of radioactivity released posed no threat. 



[4] Mr. Witt is a former FEMA Director.