ML063460306
| ML063460306 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Indian Point  |
| Issue date: | 02/07/2003 |
| From: | Arlette Howard Nuclear Energy Institute |
| To: | Witt J James Lee Witt Associates, NRC/FSME |
| References | |
| FOIA/PA-2006-0299 | |
| Download: ML063460306 (5) | |
Text
- elI NUCLEAR ENERGY INSTITUTE Angelina S. Howard Executive Vice President February 7, 2003 James Lee Witt Associates, LLC Ben Franklin Station P. 0. Box 7998 Washington, DC 20004-7998
Subject:
Industry response to "Review of Emergency Preparedness at Indian Point and Millstone, DRAFT" Dated January 10, 2003 The Nuclear Energy Institute (NEI)' submits the following comments on behalf of the nuclear industry. Although the draft report on Indian Point and Millstone emergency planning makes some recommendations that merit industry consideration, faulty methodology used to evaluate the programs results in deeply flawed findings and recommendations. There is no analytical basis for the draft report's conclusion that the emergency plans are ineffective.
The draft report ignores the fact that emergency preparedness programs are based on a fundamental commitment to safe plant operations and to the defense-in-depth concept of nuclear plant physical design and construction. The nuclear industry's emergency preparedness programs are the gold standard worldwide, tested and proven over more than 20 years. Although emergency plans developed by the industry have been implemented by state and local government after scores of industrial and natural disasters, they have never been needed because of a nuclear plant incident.
Emergency response plans are regularly tested and reviewed to ensure that public health and safety is protected. Decades of experience reviewing and exercising these plans and their procedures attest to their effectiveness in protecting the public. Federal law requires every nuclear power plant to develop and regularly test a comprehensive emergency response plan. The plan must provide protective measures for communities in 10-mile and 50-mile emergency zones. These public safety zones were determined by the Environmental Protection Agency (EPA) and the Nuclear Regulatory Commission (NRC), with input from federal agencies, and there are specific emergency response measures for each of the two zones. The Federal Emergency Management Agency (FEMA) has the lead role in emergency NEI represents nearly 275 companies, including every U.S. company licensed to operate a commercial nuclear reactor, industry suppliers, fuel fabrication facilities, architectural and engineering finms, organized labor, law firms, radiopharmaceutical companies, research laboratories, universities and international nuclear organizations.
James Lee Witt Associates, LLC February 7, 2003 Page 2 planning for non-industry participants in the off-site emergency plan, including local and state government.
The multi-agency effort determined that a 10-mile radius encompassing a reactor facility is an appropriate emergency planning zone in the event of a release of radioactive material from the reactor. This is an appropriate public protection zone regardless of whether a release of radioactive material is caused by a plant accident or sabotage. The impact on the reactor from either scenario would evolve over a period of several hours, thus providing time for orderly sheltering or evacuation of the public. Sheltering of the public and selective evacuation are the most effective means for protecting public health and safety. Moreover, if some evacuation is necessary, only a portion of the zone would be affected, not the entire 10-mile radius. Projected radiation dose as a result of most major reactor accidents is not a threat to public health and safety beyond the 10-mile zone, and evacuation of citizens beyond this area is not necessary.
The agencies also concluded that a 50-mile planning zone would be sufficient to protect the public from limited exposure as a result of consumption of contaminated water, milk or food. Similar to the 10-mile zone, only a portion of the 50-mile zone would be affected.
Finally, the scientific basis used by the NRC to develop the guidelines pertaining to emergency preparedness is over 20 years old. The scientific analyses used by the NRC and others are overly conservative in light of current scientific knowledge.
Emergency preparedness is integrated with the industry's comprehensive security program. Although America's nuclear plants were the best-defended industrial facilities prior to Sept. 11, 2001, additional security measures since the terrorist attacks include extending plant site security zones and increasing security patrols within these zones. Security forces were increased by 33 percent to approximately 7,000 well-armed, highly trained officers at 67 sites.
Industry Response to Principal Findings of the Draft Report The report authors reviewed the overall emergency plans for Indian Point and Millstone, but did not review all of the detailed procedures that Entergy uses to implement its broad-based emergency plans. As a result, many concerns raised in the draft report are based on incomplete or inaccurate information.
The draft report raises issues in a variety of areas that the industry will consider as part of an ongoing comprehensive review of its emergency planning programs.
These issues include:
" notification of the public in the event of a plant emergency a industry/government coordination
- terrorism response
" public education of emergency response plans, and
" response management.
James Lee Witt Associates, LLC February 7, 2003 Page 3 The following are responses to the major findings in the draft:
- 1. The report charges that plant emergency plans are built on regulatory compliance and not on a strategy that protects from radiation.
The industry's fundamental approach to emergency preparedness incorporates multiple protective measures to prevent the release of radiation in the first place.ý,
Nuclear plants are designed, built and operated to prevent a radioactive release, even in extreme cases, including natural disasters or acts of terrorism.
The industry's emergency response plans use a combination of evacuation and sheltering to safeguard the public should there be a release of radioactive material at a nuclear power plant. As noted earlier, sheltering is often more effective to protect the public rather than evacuation. If needed, evacuation is well planned and would be performed so citizens closest to the plant are evacuated first. The Witt report recognizes this point, using as an example the 1979 evacuation of 217,000 people in Mississauga, Ontario, due to the derailment of a train carrying chemicals. Evacuation was first initiated for residents and special facilities closest to the derailment. Evacuations then preceded centrically moving away from the hazard. Evacuations in areas near nuclear power plants are based on the same systematic and orderly plan.
- 2. The draft report concludes that people will not comply with official directions and plans will not consider the reality and impacts of a spontaneous evacuation.
Industry reviews have found otherwise. Well-coordinated evacuation planning by, industry and local/state government officials is tested regularly in: drills and exercises. Moreover, a i989 industry report 2 provides insights and lessons learned from the analysis of more than 50 large-scale emergencies-both from natural events and industrial accidents-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.
The industry frequently drills, reviews and improves its emergency plans to ensure that public health and safety is protected. Nuclear plant emergency plans are so effective that communities have used them in response to various emergencies, such as chemical spills, fires and natural disasters. The draft report acknowledges that communities that have "undergone nuclear [emergency] planning are more rigorously prepared and capable than most communities that do not have nuclear power plants in their midst." However, this capability is not factored into the draft report's overall findings.
2 NUMARC/NESP-004, Feb. 1989, "Identification and Analysis of Factors Affecting Emergency Evacuations,"
prepared by Roy F. Weston, Inc.
James Lee Witt Associates, LLC February 7, 2003 Page 4
- 3. The draft report concludes that the emergency plans do not consider additional ramifications of a release caused by a terrorist. It also charges that the plans do not account for the impact of spontaneous evacuation.
A nuclear facility's emergency response plan, including possible evacuation, would be implemented in the same manner regardless of the scenario of events that leads to an accident. If a terrorist attack resulted in a release of radiation at a nuclear power plant, the timing and quantity.of a radiation release would be no different than plant accident scenarios to which emergency response teams plan and drill.
A study recently completed by EPRI, on behalf of the industry and at the request of the NRC, determines that the offsite consequences resulting from a successful terrorist attack at a nuclear power plant are well within the NRC safety goals for severe reactor accidents. Further, state and federal officials involved in emergency response drills told The New York Times in January that the consequences of a reactor accident and terrorist attack would be about the same.
Even in the extremely. unlikely event of a successful terrorist attack, operators are prepared to take actions necessary to maintain reactor safety. The draft report asserts that the timeframe used in a scenario leading to a rapid release of.
radiation is too quick for a response, but does not provide justification for this assertion.
In reality, state-of-the-art intruder detection and advance warning systems, robust physical barriers and a coordinated paramilitary response by on-site security forces would significantly extend the timeframe of the attack and allow significant reinforcements to reach the site. Moreover, plant operators are well trained on emergency procedures-including training on reactor simulators and frequent drills and exercises-to respond to emergencies with little or no warning. Industry procedures to protect the plant in the event of an accident or sabotage are approved by the NRC. The record of safe plant operations over decades of experience - together with proven, effective responses to actual plant events -
demonstrates that these procedures are effective.
Apart from plant-specific issues, the draft report fails to take into account the fact that off-site emergency response to terrorist activity is a broad concern shared by the federal, state and local governments and industry. In the aftermath of Sept.
11, 2001, the NRC initiated a comprehensive review of requirements for plant security safeguards and policies. New NRC requirements, focused in part on emergency preparedness, have been implemented by the industry in response to broad, heightened terrorist alerts.
Industry, in coordination with the NRC and FEMA, developed guidelines for responding to NRC orders regarding such issues as plant evacuation and; communications with communities near nuclear plants. These enhancements are incorporated into the plant's emergency implementing procedures, which were not reviewed by Witt Associates.
James Lee Witt Associates, LLC February 7, 2003 Page 5
- 4. The draft report concludes exercises are of limited use in identifying inadequacies and improving subsequent responses.
The industry's expertise in off-site emergency preparedness programs for over 20 years has been measured by exercises that have been critiqued, and subsequently approved, by both the NRC and FEMA. Nuclear plant emergency plans have been effective in frequent exercises with local and state officials and emergency responders as well as in actual implementation after events such as hurricanes, chemical spills and other events. The draft report acknowledges that nuclear plant emergency response programs are effective for use in emergencies outside of the nuclear industry, yet does not recognize the role drills and exercises have played in making them so successful.
Theý nuclear industry has a long-standing philosophy of continuous improvement in all phases of plant operation. In that regard, the industry is conducting a comprehensive review of all U.S. nuclear plant emergency preparedness programs.
The industry is reassessing emergency preparedness programs, focusing on management oversight of plant programs, a review of communications approaches, and application of lessons learned to each plant's emergency preparedness program.
Conclusion It is-unfortunate that a report of this magnitude, developed during a time of heightened public concern about security and emergency preparedness, is so deeply flawed. Rather than informing the debate, the draft report is being used by opponents of Indian Point to deliberately raise fear among the public.
As a result, the draft report undermines public confidence in a state-of-the-art emergency preparedness program that is the proven standard for orderly, successful evacuations of the public. The industry is committed to continue to evaluate and improve its security and emergency planning programs, and will continue to work with local, state and federal government to implement the best possible programs to protect public health and safety. We urge Witt and Associates to recognize these points in its final report.
NEI would like the opportunity to discuss these comments with you in more detail.
If you have questions about the industry's comments on the draft report, please contact me at 202.739.8000.
Sincerely, Angelina S. Howard