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responders at all levels. It questions the assumption, given Indian Point's degraded political environment, that virtually all residents will comply with official instructions in an emergency. And it advocates various revisions to federal criteria, particularly in respect to responding to terrorism and conducting exercises. But the report is absolutely clear in recognizing that Indian Point satisfies governing NRC and FEMA requirements.
Federal law requires FEMA to make periodic findings to the NRC that emergency preparedness at every nuclear plant is adequate. Without such a finding, the NRC must shut the plant down, at least until the deficiencies are remedied. The system relies on the cooperation of the utility, and of state and local governments, to draw up coordinated emergency plans, and to demonstrate their viability in biennial exercises.
The utilities are responsible for on-site planning and communication; the governments are responsible beyond the plant boundary.
Onsite planning is seldom a problem: The utility has the highest motivation to develop an adequate plan, and Indian Point's owner, Entergy, has done so. However, if a government at any level fails, for whatever reason-lack of resources, venality, political convenience, etc.-to develop, implement, and certify an offsite plan (regardless of the merits), then a government at the next level must develop compensatory measures or the entire process is stymied.
This dependence on political cooperation-a matter beyond the direct control of any utility-distinguishes offsite emergency preparedness from any other nuclear plant management issue.
The four counties and the state have all had long-standing plans on file for Indian Point. They participated in the most recent regular exercise of the Indian Point emergency plans last September. FEMA issued its exercise report on Feb. 21, finding relatively minor problems, but no serious ones. However, the counties, beset by plant opponents, seized on the draft Witt report as an excuse to withdraw certification of their own existing plans. The state, in turn, has equivocated, and FEMA has given the state and counties until May 2 to supply missing information so that it can report to the NRC. Congressional committees and individual members also have begun getting into the act.
Before these actions lead to a shutdown order from the NRC, a few things ought to be remembered.
First, governments at all levels routinely do emergency planning for all kinds of disasters, with federal funding (utilities do it too, without the federal funding). So, radiological planning, though uniquely complex, is merely an application of existing knowledge and skills.
Second, nothing in the Witt report, or in FEMA's reports over the years, states or suggests that adequate emergency preparedness is not feasible for Indian Point. All of Witt's criticisms, many of which he concedes go beyond federal requirements, can be met; it will just take work and, in some cases, money (much of it from existing federal pass-throughs).
Third, terrorism doesn't change the radiological risk. The Witt report expresses concern over potential complications that terrorists could cause for emergency response. However, it rightly concedes that a successful terrorist attack would not change either the nature or extent of the underlying concern: a