Indian Point Emergency Preparedness Interestingly, the draft Witt Report seems to contradict this recommendation, at least in part, in the next paragraph, stating that having these strategies “does not mean their automatic application in a real event" and that even when the strategy assumptions "precisely match the real world conditions" they "should be reviewed by decision makers prior to application". IETF disagrees with the suggested approach. Use of tailored, complex The tried and true approach to emergency management is to invoke simple, conservative and manageable measures measures that can be tested and practiced, and relied upon even during unanticipated and potentially chaotic conditions in a real emergency. The approach recommended by the draft Witt report is counter to this established practice and there is no evidence that such a change is needed to achieve public protection objectives. This is not to say that we disagree with technically sound efforts to better IETF Conclusion, with respect to draft Witt Report Recommendations: Indian Point Emergency Preparedness 5 IETF Conclusions and Recommendations Based on all of the above, our primary conclusions regarding the draft Witt Report are as follows: 1. The fundamental conclusion drawn by Witt et al, to the effect that the "current radiological response system and capabilities are not adequate to protect the people from an unacceptable dose of radiation in the event of a release from Indian Point" is simply incorrect. It is not supported by the facts. This conclusion ignores the large body of information and experience in real emergencies of all kinds, it contradicts consistent findings of emergency preparedness experts and responsible public officials, and it is not a logical inference from the underlying information in the draft Witt Report itself. IETF Recommendation 1: Absent major new information and reassessment, that conclusion must be deleted (or restated in a substantive way) prior to issuance of a final report. 2. The recommendations in the draft Witt Report, while including some viable elements, are not central or prerequisite to a satisfactory emergency response process. Many of the recommendations are conjectural and others are conceptually attractive but vague. Some are incompatible with widely accepted practice. In all of these cases, significant further evaluation would be required prior to acceptance. And in no case do we find (nor does the draft Witt Report identify) any specific recommended action which must be taken in order to have a satisfactory emergency response process. IETF Recommendation 2: The recommendations should be characterized, in composite, as warranting consideration. The report should make it clear that these recommendations are improvements and enhancements, not prerequisites to satisfactory emergency preparedness. Indian Point Emergency Preparedness References 1. Adler, V., J. Sorensen and G. Rogers, "Chemical and Nuclear Emergencies: Interchanging Lessons Learned from Planning and Accident Experiences”, presented at the OECD Workshop on Technical Aspects of Emergency Planning, Brussels, Belgium, June 1989. 2. G. Rogers and J. Sorensen, “Adoption of Emergency Planning Practices for Chemical Hazards in the United States", Journal of Hazardous Materials, Vol. 27, No 1, pp 3-26 3: "Risk Characterization of the Potential Consequences of an Armed Terrorist Ground Attack on a U.S. Nuclear Power Plant," prepared by the Electric Power Research Institute for the Nuclear Energy Institute, draft report, December, 2002. 4. "Deterring Terrorism: Aircraft Crash Impact Analyses Demonstrate Nuclear Power Plant's Structural Strength," Nuclear Energy Institute, December, 2002. 5. "Severe Accident Risks: An Assessment for Five U.S. Nuclear Power Plants,” NUREG-1150, Volume 1, Section 7, December, 1990. 6. "Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Reactor 7. "Criteria for Preparation and Evaluation of Radiological Emergency Response 8. J. Sorensen, "Assessment of the Need for Dual Indoor / Outdoor Warning Systems and Enhanced Tone Alert Technologies in the Chemical Stockpile Emergency Preparedness Program", Oak Ridge National Laboratory, ORNL/TM— 12095, 1992. 9. Umatilla County Emergency Management. "School preparedness emphasized in October CSEPP advertising campaign," Press Release, 10/17/2002. 10. Quarantelli, E. "Problematical Aspects of the Information/Communication Revolution for Disaster Planning and Research: Ten Non-Technical Issues and Questions," Disaster Prevention and Management 6 (1997): pp. 94-106. 11. Sorensen, J. and D. Mileti. "Decision Making Uncertainties in Emergency Warning System Organizations," International Journal of Mass Emergencies and Disasters, Vol. 5, No. 1, 1987, pp 33-61. 12. Jackson, D. et al. "Protecting Emergency Responders: Lessons Learned From Terrorist Attacks." Santa Monica, CA: RAND, 2002. 13. Lindell, M. and R. Perry. Behavioral Foundations of Community Emergency Planning. Washington, DC: Hemisphere Publishing, 1992. 14. Perkins, Judy, Ibibia K. Dabipi, and Lee D. Han. "Modeling Transit Issues Unique to Hurricane Evacuations: North Carolina's Small Urban and Rural Areas." North Carolina A&T State University Transportation Institute, December 31, 2001 15. Sorensen, J. and D. Mileti. "An Assessment of Pre-emergency Information Programs For Nuclear Power Plant Accidents," pp. 311-336 in Preparing for Indian Point Emergency Preparedness Nuclear Power Plant Accidents. D. Golding, J. Kasperson, and R. Kasperson 16. Urbanik, T. "Evacuation Time Estimates for Nuclear Power Plants," J. of 17. Mitchell, K. (ed) Crucibles of Hazard: Mega-Cities and Disaster in Transition. 18. State Capability Assessment for Readiness: A Report to the United States Senate 20. Quarantelli, E. L., B. Phillips, and D. Hutchinson. (1983), Evacuation Behavior: 21. P. Duclos, S. Binder, and R. Riester (1989) "Community evacuation following the Spencer metal processing plant fire, Nanticoke, Pennsylvania," Journal of Hazardous Materials 22: 1-11. Indian Point Emergency Preparedness Appendices Appendix A: IETF Curricula Vitae Robert T. Bradshaw is a senior consultant with over 20 years experience in government and private sector crisis management response, planning, training, drills and exercises. His management experience including service as senior vice president and a member of the board of directors of a worldwide crisis management consulting firm and operating his own consulting firm, Bradshaw Emergency Management, Inc. Mr. Bradshaw has responded to a number of crises on the national and international levels. In particular, Bradshaw established and operated an emergency center for an U.S. airline to respond to the Pentagon disaster in response to the events of September 11, 2001. He has directed a major project for the U.S. Department of Transportation (DOT), Office of Pipeline Safety to support facility oil spill response plan review process. Bradshaw responded as a DOT representative to the San Jacinto River Pipeline incident in and was a principle author of the San Jacinto Post-Incident Assessment. For FEMA and the U.S. Department of Justice, Bradshaw also developed and presented programs on weapons of mass destruction and terrorism designed for local responders. As an independent consultant, Bradshaw served as offsite emergency planning coordinator for Boston Edison's Pilgrim Nuclear Power Station, where he supervised development of offsite plans and procedures for seven communities and the State of Massachusetts. Other projects included review and comment on the City of Chester, Pennsylvania Disaster Operations Plan and data support to the TMI Evacuation Time Estimate Study. As a project manager for a major engineering firm, Bradshaw coordinated emergency management planning and training, exercising and drill support for clients such as the offsite radiological emergency preparedness program for Philadelphia Electric's Limerick Generating Station, where he developed county and municipal plans and several school and health-care facility plans. He also prepared and conducted two full-scale exercises for Limerick. He is a former emergency planner for the Pennsylvania Emergency Management Agency, where he developed and reviewed state and municipal emergency plans, revised the state's vulnerability analysis and served as controller/evaluator for six full-scale federally evaluated exercises. Mr. Bradshaw has a B.S. in Environmental Science from Wilkes College, Wilkes-Barre, Pa., and did graduate work in Urban and Regional Planning at Pennsylvania State University. John C. DeVine, Jr. is co-founder and principal of Polestar Applied Technology, Inc., a company that provides management and engineering services to U.S. and international electric utilities, the U.S. Department of Energy (DOE), and others. His activities at Polestar have included ongoing engineering and management support of commercial U.S. |