Indian Point Emergency Preparedness Independent Expert Task Force Comments on the Draft Report: Review of Emergency Preparedness James Lee Witt and Associates, LLC Prepared for Entergy Nuclear Operations, Inc. February 7, 2003 3.2 3.3 SPECIFIC SHORTCOMINGS IN CURRENT EMERGENCY MANAGEMENT PROCESSES. .5 6 7 .11 .11 12 .15 APPENDIX B: EM TREATMENT OF PUBLIC PROTECTION CHALLENGES. .24 APPENDIX C: RELEASE THREATS DUE TO TERRORISM. .25 APPENDIX D: BEHAVIORAL ISSUES EVALUATION. 32 Indian Point Emergency Preparedness 1 Introduction and Background The firm of James Lee Witt and Associates, LLC (JLWA) recently conducted, for the New York Power Authority, an independent assessment of emergency preparedness of the New York communities around the Indian Point Energy Center (“Indian Point") and the Millstone Nuclear Power Station ("Millstone")'. The report of this work, entitled Review of Emergency Preparedness at Indian Point and Millstone (and referred to herein as the "draft Witt Report") was issued in draft form on January 10, 2003. As described in the draft Witt Report, the purpose of the effort was "to assess the ability of emergency management systems to protect the health and safety of the New York citizens living around Indian Point and Millstone in the event of a radioactive release". The draft Witt Report also includes "recommendations for improvement in the emergency management systems for each site". In light of the importance of this subject, Entergy Nuclear Operations, Inc. has assembled an Emergency Preparedness Independent Expert Task Force to review thoroughly and provide comments on the draft report, particularly in those aspects relating to Indian Point. Appendix A lists the members of the Task Force (or "IETF") and summarizes their credentials. As evidenced in Appendix A, the IETF embodies extensive, in-depth experience and expertise in virtually every aspect of emergency management. This report presents, in summary fashion, our assessment of the draft Witt Report, including its structure and logic, findings, conclusions and recommendations. In our review, we interacted with Entergy personnel, but this report reflects solely the views and conclusions of our IETF members. Our intent in this initial report is to provide clear and concise feedback on the key points covered in the draft Witt Report, in time for them to be taken into account by the JLWA team in finalizing their report. Entergy has also requested that the IETF prepare a more detailed follow-up report, addressing a full range of topics germane to emergency management effectiveness at Indian Point. That effort is in progress and will be reported in several months. Based on our review, the IETF stands in fundamental disagreement with the primary findings of the draft Witt Report. At the same time, we acknowledge its value in presenting many specific observations regarding emergency management processes, and we agree with a number of its recommended actions. We recognize the importance, sensitivity, and broad interest in this issue to all stakeholders, and we submit this report in the spirit of constructive contribution to those with responsibility for policy making in the emergency management arena. Millstone is located in Connecticut, but some portions of Long Island NY are within Millstone's 10-mile emergency planning zone (EPZ). Indian Point Emergency Preparedness 2 IETF Comments, in Overview The draft Witt Report is a 500+ page treatise on virtually all elements of emergency management at the state, county, municipality and operating company level. Not surprisingly for an assessment of such sweeping scope, it has sparked controversy and disagreement on numerous specific points. Beyond that, however, our IETF found the draft Witt Report to be fundamentally flawed in several important respects, and therefore we do not consider it to be a valid basis, in its current form, for decision-making. The draft Witt Report's most serious flaw is that it draws conclusions, on matters of great importance, with little apparent basis other than the opinions of its (unnamed) authors. As an example, it asserts that a terrorist-caused radiation release at Indian Point would likely be worse in magnitude and timing than that caused by accidents previously considered in safety and risk assessments of the plant. And it compounds that error by asserting that the emergency management process does not accommodate the consequences of such terrorist-caused events. Both assertions are presented without reference, basis or explanation - and, in fact, both are incorrect (as explained more fully in Section 3.4 of this report). Similarly, the draft Witt Report's main conclusion - that “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 attributed to the "combined weight” [page viii and page 240] of the various individual challenges and emergency management shortcomings identified throughout the report. There is no supporting analysis or explanation of the supposedly debilitating synergistic effect of these individual - and in many cases separable - factors. Further, this conclusion ignores the large body of contrary information and experience in real emergencies of all kinds, and it contradicts consistent findings of emergency preparedness experts and responsible public officials. (This point is discussed more fully in Section 3.5 of this report.) The report in its current draft form is simply not - in our view - a sound and professional product. It is wrong on the facts in some important areas. Many references are incomplete or incorrect. It is redundant on some points and on others internally inconsistent. It presents recommendations that in some cases are vague, unsupported or premature, and that in some important respects contradict widely-held practices and principles of emergency management. Examples of all of these are presented throughout this document. Finally, we consider the draft Witt Report to be misleading in that it provides no perspective on the relative significance (or insignificance) of the various points raised, or on the very low risk to public health and safety posed by Indian Point, even with full consideration of the issues raised therein. 2 As a convention throughout this report, verbatim statements from the Witt Report are italicized and indicated by quotation marks, followed by specific reference in brackets. Indian Point Emergency Preparedness 3 IETF Comments on Witt Report Key Points The following are IETF comments, with summary conclusions in each case, on the main topics of the draft Witt Report: 3.1 The Challenges of Public Protection The draft Witt Report identifies and discusses the many challenges related to protecting the public, implying that these are extraordinary and perhaps intractable. Specific examples include: Likelihood that some members of the public won't follow direction during an emergency (e.g., parental interference with the school evacuation process) [pages vi and viii] Difficulties in communications, particularly with non-English speaking persons (pages viii and 230] Lack of first responder confidence in the emergency plans [page viii] Problems caused by spontaneous and/or shadow evacuations [pages vi and viii] Road system limitations (potentially compounded by weather, construction, etc. [page viii] Poor public understanding of emergency management processes and their roles and responsibilities [page iv] We agree that these are tough, real-world challenges. But they are not unique to Appendix B is a tabular summary of specific, documented treatments of the IETF Conclusion: There is nothing new here and nothing to suggest that sound, established emergency management processes cannot provide the requisite level of protection required for people in New York, in the Indian Point area. |