Plan to Strengthen Department of
Homeland Security (DHS)/Federal Emergency Management Agency (FEMA) Biennial
Emergency Simulation Exercises
Biennial Emergency Response Exercises are conducted by the Department of Homeland Security/Federal Emergency Management Agency to assess the level of State and local preparedness in responding to a radiological emergency in the 10-mile Emergency Planning Zone (EPZ).
Nuclear Emergency Exercises must be based on realistic post 911 scenarios; be comprehensive; measure the effectiveness of the emergency response system; allow participation by independent experts; and allow interested stakeholders to observe these exercises.
Pilgrim EPZ’s Biennial Exercise was held April 14, 2004. The public meeting to discuss the exercise was held April 20, 2004.
The public was not allowed to observe the exercise; nor was the public notified about the Public Meeting via the media. Therefore the public does not have reasonable assurance that the exercise provided an effective, realistic and comprehensive test of emergency plans and that responses to the exercise were appropriate.
The following comments are based on lessons learned from Pilgrim’s former exercises and comments by the Indian Point Safe Energy Council in regard to their upcoming June 2004 Exercise – see www.riverkeeper.org
Plan to Strengthen Biennial Emergency Simulation Exercise
1) Ensure that exercises
are based upon a scenario involving a fast breaking release of radiation
that results in the contamination of a significant portion of the 10-mile
emergency planning zone and the 50-mile ingestion pathway zone. (Federal
government reports note that a radioactive release can begin is less than an
Exercises can be no-notice causing emergency personnel to mobilize suddenly as they would in a real emergency. (NUREG-0654, the federal regulation that defines emergency planning for nuclear sites, recommends that some exercised be unannounced.)
Exercises can occur during non-duty hours. (NUREG-0654 states that “each organization should make provisions to start an exercise between 6:00 pm and 6:00 am.)
Exercises can involve real drills involving the practice of the current plan – not simply “table-top” exercises, paper shuffling, and phone calls.
School Preparedness, bussing school children out of the EPZ: Did the drill involve just contacting one or all transportation providers and all drivers; were busses actually dispatched from the company to the schools and sent back to the Reception Center; were school children mobilized as if there were an accident, boarded onto the busses, children returned to the classroom, and busses sent to the Reception Center? The later scenario would provide a realistic test and learning experience.
Reception Centers: Were volunteer “evacuees” sent to the Reception Centers, monitored, decontaminated, and sent on to the Mass Care Facility? Were the centers tested for the maximum number of evacuees likely to arrive – 100% of the institutionalized population, including school children, and 75% of the general public?
4) Ensure that exercises
are comprehensive and cover a variety of conditions: inclement weather;
different seasons; holidays; grid lock on primary transportation routes;
terrorism scenarios; and scenarios that assess stress on limited emergency
resources and personnel. (For example, test a scenario involving multiple
attacks in the region i.e. attacks on local bridges, roads, and electrical
transmission lines – or a regional electrical blackout.)
7) Ensure that the exercise
takes into consideration a large number of people, who have been injured and
contaminated, requiring treatment and decontamination. (Medical personnel
have expressed concerns about hospitals being overrun by citizens worried
that they have been exposed to radiation and the ability to treat a large
number of contaminated people.)
9) Involve and cooperate with independent experts, like James Lee Witt Associates, to monitor and evaluate the exercise and publish their own findings.
10) Involve elected
officials at the local, state, and federal level; representatives from
public interest groups; and members of the public as evaluators, observers
and players. FEMA should provide training exercise evaluations to those
selected to be evaluators. (The Governor Pataki-commissioned Witt report
called for greater public involvement in emergency planning: “Cities,
special facilities, private employers, and selected citizen groups or
neighborhoods should be encouraged to participate in exercises. Elected
officials should participate in exercises to make sure that the
decision-making element is well represented and that they receive needed
training. We further recommend that interested stakeholders be allowed to
observe these exercises.”)
12) DHS/FEMA should devise
and publish a set of specific standards by which they evaluate the adequacy
of the exercise and the plan as a whole. FEMA’s current standards are
deliberately vague and allow the agency to sign off on an exercise that may
be riddled with deficiencies.
14) Ensure that the public meeting scheduled to discuss the exercise is widely announced in the media, held at a time and location to maximize public attendance, and allows the public to ask questions and make comment.
15) Practice makes perfect; therefore exercises should not simply be biennial but instead have quarterly drills and annual exercises.