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] Indian Point Emergency Preparedness Independent Expert Task Force Emergency planning for nuclear plants is in the vanguard practice in the US, for protection from all threats, as demonstrated by the CAR (Capability Assessment for Readiness) conducted by FEMA, which concluded that "Overall, States participating in the REP Program score higher above the national average in all functional areas." [18, p. 122] IETF Conclusion: There is simply no basis for the draft Witt Report conclusion that the emergency management processes currently in place are inadequate to protect public health and safety. Indian Point Emergency Preparedness 4 IETF Comments on Witt Report Recommendations There are recommendations throughout the draft Witt Report. Many, not all, are restated in Section 11. The recommendations are not prioritized, and none is described as (nor do we consider any to be) central to emergency management success. Some of the report's recommendations are based on incorrect or unconfirmed assumptions. Many are vague or conceptual and some counter established practice and experience. In such cases, substantial further evaluation and development is warranted before they could be adopted. In other areas, we agree that the recommended actions have merit and should be considered, and acted upon as appropriate. 4.1 Points of Agreement Included in the draft Witt Report are recommendations regarding areas in which the emergency management planning and processes are frequently updated. In some of these cases, we understand that the actions recommended by the draft Witt Report had previously been identified and are already being implemented; others are attractive in concept and are expected to be evaluated. Examples are: Incorporation of new technologies, such as reverse 911 and GPS, to Adjustment of siren noise levels consistent with terrain and background Improvement in public education and outreach activities Upgrading Emergency Operations Centers and technology supports for protective actions Involvement of cities and counties, in response planning, training, and exercises Improvements in methods and equipment for communications with state and counties. Development of methods to accommodate communication failures such as destruction of hardware, network jamming, computer system hijacking, and weak signals Inclusion of large employers in emergency planning Development of sound processes for use of stable iodine as a prophylactic for radioiodine uptake Use of traffic simulation models, with inclusion of population variations including transients Inclusion of shadow evacuations in the exercise system Improvement in a comprehensive training program including certification of some key positions involved in response Regular feedback from the IP emergency response community to Indian Point Emergency Preparedness Use of improved plume modeling and related hazard assessment, taking 4.2 Comments on Key Witt Report Recommendations The following are IETF comments on draft recommendations that we consider to be of particular significance: 1. Draft Witt Report recommendations that exercises should be “performance outcome-based": As stated, "The State should work with FEMA and others to develop a performance outcome-based exercise program distinctly different from the functional exercise approach. A functional approach examines each activity against regulations, guidance, or plans and looks for compliance. An outcomebased approach looks for the effects of the actions on the community". [page ix, and subsequent] We concur that that emergency preparedness exercises should include performance outcome assessment along with appropriate compliance measures. The exercise outcome of primary importance is the protection of public health and safety, and exercises should be conducted and assessed in a way demonstrates achievement of that objective. This performance outcome philosophy is already being implemented. Over a year ago, FEMA incorporated this approach in its new process for grading nuclear plant exercises. FEMA now uses six evaluation areas instead the 33 objectives utilized previously. In accordance with the REP Program Manual, the new evaluation areas, "...reflect FEMA's shift towards a more 'results oriented' approach to the evaluation process. In other words, the accomplishment of the mission (result) is more important than the means used to achieve the result." [18, page iii-59]. IPEC and off-site authorities were evaluated against these new performance-based criteria during the September 24, 2002 FEMA Exercise. This process is likely to see ongoing refinement and improvement. Full implementation of a fundamentally different exercise process will take time and will require development, testing and training. Emergency exercises for all nuclear plants currently follow federal regulations and guidelines and should be continued until a new process is ready for implementation. 2. Draft Witt Report recommendation that Emergency Plans should take into As stated: "The current planning assumption, that the public will not act in ways that will compromise the effectiveness of the response, can lead to serious Indian Point Emergency Preparedness miscalculations. Planning, response, and public education all need to take into account the general findings of disaster researchers on how people behave during emergencies as well as specific findings from the region on the expected actions and intentions of the people living and working around both nuclear facilities, both within and outside of the 10 mile EPZ".[page 225] We agree that plans should be based on realistic behavioral assumptions and should take into account findings from disaster research. However, we note that behavioral intent studies have proven to be of limited use, because individuals' perceptions of what they would do in an emergency situation may differ considerably from their actual behavior in that situation, for a variety of reasons. Appendix D is a tabular summary of behavioral issues raised by the draft Witt Report, and the IETF comments on each. Note also that rigid public conformance with protective action directions is not essential for an effective nuclear plant emergency response. These directions are conservative in nature, and in most cases variations in individual response would have little health consequence. 3. Draft Witt Report recommendation to improve public outreach The report finds that “A comprehensive public outreach strategy should be put in place to better educate all sectors of the public on their role in emergency response plans."[page 222] We concur that public education is a foundation for facilitating effective public response. This is, and will continue to be, an area of sharp focus and continuing improvement at Indian Point. A number of specific recommendations are offered in the draft Witt Report regarding public outreach. We recommend that these be evaluated for inclusion in the ongoing efforts to improve public outreach in the Indian Point EPZ. 4. Draft Witt Report suggestion regarding event-specific protective action While not presented as an explicit recommendation, the draft Witt Report argues that many case-specific protective action strategies be developed and incorporated into the Indian Point emergency management processes. Excerpts from the report in this area include: "Safety requires the right actions at the right time. Each radiological emergency can have unique aspects – the accident can be different, weather can be different, time of day and hence patterns of population distribution. ...Humans cannot process the hundreds of variations and arrive at the best strategy. However computers can ... Indian Point and Millstone need to develop a series of protective action strategies for varying contingencies. In our experience...several million simulations had to be run..." [pages 212 and 213] |