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WPCNR Westchester County Clarion-Ledger. By John F. Bailey. © 2003, The White Plains CitizenNetReporter. All Rights Reserved. May not be Reproduced or Retransmitted In Whole or In Part Without Permission of WPCNR. February 26, 2003 UPDATED March 1, 2003: Witt Associates did not respond to a WPCNR inquiry Friday to see if their Final Version of their error-riddled Witt Report was released Friday. The Federal Emergency Management Agency press officer did not answer our inquiry to comment on whether FEMA demanded The Journal News take down their specific detailing of errors in the report from the Journal News website earlier this week.
The Witt Report, sharply critical of the Indian Point Westchester County emergency plan and the Indian Point ability to report nuclear accidents accurately, has based its conclusions on major misconceptions about Indian Point operations.
It appears to have happened because none of their experts toured or asked Indian Point or Westchester County for information on up-to-the-present operations or confidential security arrangements.
The Federal Emergency Management Agency in its own review released last Friday, and obtained by WPCNR, specifically documents over 146 outright errors, misconceptions, and inaccuracies on which the Witt experts based their conclusions in their 246-page written report (including appendices, the Witt Report runs approximately 500 pages).
Media Do Not Report How FEMA Really Feels About the Witt Report.
You would never know this from other news reports. FEMA’s report has been reported as far as its reaction to the New York State Report (The Witt Report), which reads, FEMA believes that the draft State report raises a number of issues that should be considered for enhancing the level of preparedness in the communities surrounding the Indian Point Energy Center. These include better education of the public, more training of offsite responders and improved emergency communications. Some of these issues should be evaluated for their applicability program-wide.
Now You See It. Now You Don’t
That is perhaps the only nice thing FEMA has to say in their critique. However, that full text from which WPCNR compiled this partial account was taken off The Journal News website within 24 hours of when WPCNR noted it there, so the full text is no longer available as of Thursday, February 27, and could have been taken off the site within hours after its appearance..
FEMA’s press office was contacted Friday afternoon and asked, on tape, if FEMA requested The Journal News to take down the full report from its website. The press officer has not returned the call with an answer as of Saturday morning.
Previously, WPCNR learned Thursday the full report of FEMA’s devastating undressing of Witt expertise, was never supposed to be released to the public. The critique, which was obtained by WPCNR, was prepared by FEMA officials who had no affiliation with Entergy, owners of Indian Point, and it is an embarrassment to the Witt organization.
The FEMA report was supposed to be only for viewing by state and county officials.
Repression of Full Text of the FEMA Report Deludes Public.
By keeping the full text of the report from the public view, and apparently no public officials having read the full text, the public has the mistaken impression that The Witt Report is correct.
What has not been reported or written about even by media with the full report in their possession, is the full scope of the FEMA report.
It is devastatingly uncomplimentary to Witt Associates’ scholarship, science and professionalism.
Nuclear “Experts” Not Named.
Indian Point executives, Mike Slobodien, Emergency Planning Director, and Jim Steets , Manager, Communications, confirmed to WPCNR one week ago that Witt Associates would not tell them who the persons were with a nuclear power plant background who had worked on the report.
FEMA Questions Comparing Chemicals to Radiation.
FEMA’s suppressed analysis of the Witt Report indicates that whether the persons had a nuclear power plant background or not, they did not do their homework., made assumptions based on chemical plant disasters and chemical plume behavior, not nuclear disasters or radioactive plumes which FEMA said is scientific nonsense.
Mr. Slobodien said the errors in the report would not have occurred had Mr. Witt or any of his associates or those acting on his behalf at Innovative Emergency Management (of Baton Rouge, Louisiana) his subcontractor, took the time to visit Indian Point on a fact-finding mission, or had consulted with Entergy officials about how Indian Point runs, monitors, secures and reports accidents today, before preparing their report.
Witt: Plant Should Use Computer Calculation of Plume Direction. Fact: They Do.
One Witt Team misconception that is one of the lynchpins of the Report’s conclusions critical of the plant, .involves the methodology Indian Point uses to track a release of radioactivity into the atmosphere.
The Witt Report states in many different places that Indian Point does not use up-to-date computer technology. The report says state-of-the-art computer technology should be used to calculate how changes in wind direction affect the direction a plume release would travel. The Witt Report alleges they cannot predict wind direction in real time, creating unnecessary time lags putting areas at risk.
This is not true reports Indian Point’s Slobodien and FEMA backs him up.
The obvious misconception on The Witt team’s part came about apparently when a Witt Team representative watched plastic overlays being used in the Emergency Operation Center they observed at Indian Point on September 24 the date of the county’s Indian Point incident exercise.
The Witt Report itself indicates their Team assumed the wind direction changes were estimated by referring to a plastic glassene chart that matched a new wind direction. According to Steets, who was present in the Indian Point Emergency Operations Center, the observer from Witt did not ask for an explanation of the charts.
Steets’ explanation for the mistake is he believes that the Witt observer or observer(s) apparently assumed the charts were the “technology” used to plot changes in direction any plume release would take.
Here is what the Witt Report says, on page 244,
We recommend that the Indian Point facility…State of New York, counties and cities install a more sophisticated nuclear atmospheric dispersion model. This model should be calibrated to incorporate meteorological information from the local area as well as the results of radiation detection and measurement devices, fix-mounted to provide real-time measurements of radiation status. This model should also be validated against the tracer experiments conducted in the Hudson River Valley. The model must provide information on the time of exposure of the population.
More Misconception.
In an earlier section of The Witt Report on page 237 it becomes clear that the Witt observers of the September 24 operation did not understand what they were seeing when the charts were laid down:
The Indian Point region is using old, out-dated technologies in a number of areas. The hazard assessment process uses plastic map overlays for determining the area at risk. The hazard information is communicated via slow transcription of hazard information onto paper and then faxed to the State and counties. Plume information is currently not available through operable automation systems that can show the State and counties the precise areas that are at risk. Hazard assessments do not integrate with population data and do not show the time that various zones would be at risk.
Big Mistake.
Slobodien reports, to the contrary, Indian Point does use “operable automation systems” that print digitized maps of the plumes, that are in no way “transcribed,” they are printed out like weather maps based on wind direction and the radiation monitors, and instruments about the plant. The system previously did not show the time various zones would be at risk, but he says “we do now.”
Mr. Slobodien told WPCNR the Indian Point system does exactly what Witt’s Report says they do not do. The plant uses “state of the art” computer technology to coordinate wind direction, plume density and create a plume chart digitally every 15 minutes like a cardiogram.
Time Interval Criticism Does Not Make Sense.
The 15-minute updating time frame that The Witt Report criticizes as being too long an interval between plume travel direction updates, reflects a basic lack of understanding of radioactive plumes, according to Slobodien.
“Charts printed out any faster,” Slobodien said, “are meaningless, because you can not ascertain the change visually.”
Witt Observer (s) Mistake Plastic Manual Backups for Real Thing.
“This is so egregious,” Slobodien told WPCNR last week, “to think that they (The Witt experts), would assume we were not using the most up-to-date computer technology available. The fact of the matter is we only use them the plastic charts as manual backup if our computers fail. Our computer plots the change in wind direction every 15 minutes and prints out the isopleths showing the changes in air density which show clearly the zone affected by the wind shift.”
It is a recurring theme throughout the Witt Report that the sketchiness of plume direction is one of the key reasons why the evacuation plans need massive improvement.
The FEMA analysis issued Friday February 21, (and not reported in any depth by any of the major media), does not agree with the Witt position on plume intelligence and notes this error in judgment made by The Witt Report:
…while a hard copy is transmitted by facsimile to the State and counties, the information is previously transmitted by a dedicated phone system that is not subject to overload during an emergency. The MRP-DAS system, a computer link with the utility, gives almost real time (the data is a 15-min average of the instrument readings and is therefore delayed slightly) data of plant systems readings and includes the readings of the 16 radiation detectors that are placed around the site….In Westchester, for example, the assessment included populations impacted and projected arrival time of the plume. It should be noted that the initial PAR and PAD were well before any release and therefore at the time of the first decision there was no dose, only potential dose.
No Quantification of Radiation Intensity.
WPCNR did not find in the Witt Report any number given for the REM’s the Witt Report Team expects to be released in any plume from Indian Point. An R.E.M. is short for “roentgen equivalent man,” a measurement that quantifies radiation doses as they affect a man or woman.
The Witt Report compares releases at Indian Point directly to the Chernobyl disaster in Russia in 1986, and the Bhopal chemical disaster in India, as examples of the kind of damage radiation leaks from Indian Point can do to the population.
It is Mr. Slobodien’s contention that those comparisons are not scientifically comparable. The Chernobyl fire and leak is not applicable, in his opinion, because the reactor that melted down contained graphite as a radiation absorber, and graphite caught fire creating a much longer event and release. Slobodien said he was confident any Indian Point plume could be contained within a few hours, not days as was the case in the Chernobyl incident. He said for any plume release, the Indian Point reactor would have to be penetrated.
Compares Apples to Oranges, Due to Witt Associates’ Subcontractor’s “Chemical Expertise” Background
The FEMA analysis throws out the chemical disasters as a means of comparison of plume drift damage cited by the Witt Report. FEMA notes Bhopal was a chemical release of deadly chemicals (caused by an explosion), and had nothing to do with radioactivity, citing it had only relevance to how a release of some sort can kill a lot of people. This comparing apples to oranges, without mentioning the Bhopal release was chemica, misleads the lay reader of the document.
The Witt Report expertise on nuclear matters is attributed to Innovative Emergency Management of Baton Rouge, Louisiana, (with offices in Anniston, AL, Abingdon,MD, Salt Lake City, and Washington, D.C.). IEM is primarily in the business of analyzing chemical release scenarios, not nuclear incidents, which perhaps explains their inclusion of a chemical plume in a report dealing with radioactive plumes.
They list Pacific Northwest National Laboratory (Richland, Washington) and Battelle Memorial Institute, (Columbus, Ohio) both national institutions dealing in nuclear analysis and research as clients. However, Pacific Labs, located in Oregon has no contract records of doing any work with Innovative Emergency Management, and Battelle has only used them for input at their Chemical Biological Information Analysis Center in Canada, nothing of a nuclear nature. The outfit lists a number of government agencies and private power companies as clients. IEM principals have overwhelmingly chemical substance emergency based experience, and may have a “nuclear background” but neither their offices nor the Witt press office would reveal who the nuclear experts were, or their credentials.
Weird Science: FEMA Calls Chemical Plumes Very Different from Radioactive Plumes.
FEMA writes: Throughout the (Witt) report there seems to be an effort being made by the report authors to fuse the Radiological Emergency Response program with the CSEPP (Chemical Stockpile Emergency Preparedness Program) program; CSEPP program terminology is used with the caveat that the term is interchangeable with REP (radioactivity) terminology. For example, on page 30 the authors chose to use a chemical plume rather than a radioactive plume to explain their point. This is misleading; the two types of plumes and their effects are quite different. If this document (The Witt Report) is for REP (radioactivity) planners, programmers, and practitioners, all CSEPP references should be deleted.
FEMA is troubled that The Witt Report compares a possible nuclear plant event evacuation with their experts’ past experiences of a chemical plant explosion in Bhopal, India in 1984 and a train wreck derailment in Mississauga, Canada in 1979 that produced a chemical fire:
….Chapter 4…references the CSEPP (chemical) method to develop protective action strategies. This “two-part” process is what the (Indian Point) dose assessment and the local decision-makers already do. The authors (of The Witt Report) appear to advocate “sheltering” even though (regulation) requires a default evacuation of the 2 mile ring and 5 miles downwind. The authors and particularly those with CSEPP (chemical) experience should be aware that a chemical stockpile has a greater probability of exploding than a nuclear facility and thus the amount of time to discuss and decide… differs ( WPCNR note: substantially more time in a nuclear plume release according to the nature of the plume.).
Maximum Indian Point Radiation in a Plume Release is 3-1/2 times that of a typical Hospital Gastro-Intestinal Series.
Slobodien told WPCNR that the most “absolute worse case,” that an Indian Point plume release could be is 4 to 5 R.E.M.’s, for one hour at a distance of 2 miles from the plant, 5 miles downwind, after which the plume dissipates.
What does this mean?
In comparison, he said, a routine hospital procedure, done daily at most hospitals, the G.I Series , (sometimes repeated on a patient within a few days time to check treatments), exposes a patient routinely to 1.4 REMs.
Using the Witt Report’s own Chart of R.E.M. comparisons, the Gastrointestinal Series, upper and lower, exposes a patient to 1.4 R.E.M.s. So the maximum exposure a person standing under an Indian Point plume for one hour on the ground would be receiving the equivalent of about three G.I. Series. G.I. series which can be experienced by persons in hospitals in an ongoing treatment situation for internal bleeding for example.
Handicapping the Plume.
Slobodien said exposure is judged on the amount of time one spends in the plume release area, and the calculated maximum radioactivity dose in an Indian Point plume release of 4 to 5 REMs, assumes exposure for one hour. Slobodien says he is confident they can contain and stop any plume release in an hour’s time, and natural dissipation of the cloud would take place by wind dispersal after an hour.
Likelihood of a 4 –5 R.E.M. release? The 1979 Three Mile Island Incident Released 0.001 REM.
WPCNR contacted a private environmental research firm, Integrated Environmental Management, Inc., of Knoxville, Tennessee (selected at random by WPCNR) for an independent nuclear expert verification. The organization describes itself as delivering “strategic health physics (radiation safety), industrial hygiene, and environmental consulting and services to both government and commercial clients.” It maintains a staff of Certified Health Physicists, Certified Industrial Hygienists and Registered Radiation Protection Technologists.
A Certified Health Physicist, Carol Berger, answered WPCNR’s question of whether a 4 REM dose was likely from an nuclear plant release, whether it was dose per particle or static at 4 REMS.
Berger wrote WPCNR: “The only way to turn any of these numbers into dose (i.e., REMS) is to first determine the location where the dose is to be measured, determine the amount of time a person remains at that location, assess that person’s actions while at that location (i.e., standing still, working hard, eating the local flora, etc.), evaluate the radionuclide content of the particles in the plume, and a variety of other input parameters.
“Therefore, your question about the radiation dose in a cloud being four (4) REMS seems to imply either a very dramatic release of radioactivity, a measurement point that is immediately proximal to the release point, and /or an exposure duration that is pretty long.”
The Three Mile Island Standard. Not Even Close to a G.I. Series Dose.
“Keep in mind ,” Berger wrote, “that during the incident at the Three Mile Island nuclear power station in 1979, when about three million curies of noble gases and about 10 curies of radioactive iodine were released, the maximally-exposed individual who was assumed to be in fairly close proximity to the plant, was only one (1) millirem, or 0.001 REM.”
Berger wrote that assessing radiological impacts of releases of radioactivity has been “well-developed over the years.”
She noted that, “they are able to assess doses at almost any location away from the release point from all exposure pathways, including direct radiation exposure, exposure from inhalation of the contents of the plume, exposure from ingesting food or water that have been contaminated by the plume and others.”
Who Are These Guys?
The draft Witt Report does not identify the persons working for Innovative Emergency Management, the subcontractor who worked for them in preparing the report. The Witt Report lists I.E.M. as having provided the judgments on Indian Point operations, but so far has refused to name names.
An IEM executive, Ted G. Lemcke, speaking to WPCNR last week said the individuals who handled the Innovative Emergency Management assignment from Witt Associates had a nuclear power plant background, and that he thought they would be identified in the Final Report now being developed from the rough draft. It was due yesterday, Friday, February 28. Mr. Lemcke said the Draft report was now being “clarified and verified” and Witt Associates is “resolving some issues with various parties,” but he would not say who those “various parties” were.
No one with Witt Came Knocking with Questions.
Mike Slobidien of Indian Point, in frequent touch with Witt Associates last week said no experts with nuclear power plant backgrounds participated in preparing the Witt Report, to his knowledge, because in his conversations, they would not identify those individuals to him, either. Slobidien said, it was his understanding that Witt Associates was going to schedule a tour of Indian Point as of last week, but no date has been set, and the media would not be invited.
Thursday, February 27, Mr. Slobodien said that Witt officials had been in touch with Indian Point within the last week to discuss their mistakes.
WPCNR Reports: A Tour of the Plant Is Instructive.
Touring and interfacing with Indian Point managers onsite prior to writing the report would have given The Witt Report team some valuable insights. It did for WPCNR. From what this reporter saw on site, driving a truck of explosives next to the reactor dome at Indian Point, might not be possible due to the extensive physical protection surrounding the reactors.
But, because Witt representatives did not tour Indian Point, according to Entergy officials, (as WPCNR did in June of 2002), they assume a terrorist could drive a truck up and set off a bomb causing “an immediate crisis.”
. The Witt Report spends part of page 185 raising the possibility that “Terrorist events could take other forms, such as trucks armed with conventional explosives.”
If you see the area around Indian Point reactors for yourself, a rational person would conclude it would be tough to reach the reactors from the entrance of Indian Point to the site of the reactors. For security reasons, WPCNR will not reveal the protection mechanisms, but Entergy said they would have cleared Witt’s team to go into great detail about the plant’s defenses that they would not reveal to WPCNR. But the Witt Team never asked.
The Witt Report writes that it was not commissioned to review Indian Point security processes, however, their conclusions are based on assumptions of security arrangements.
Did not Go Into Detail on County Improvements to Evacuation Plan.
Witt Report preparers also did not do intelligence gathering with Westchester County either. Tony Sutton, Deputy Commissioner of Emergency Planning for Westchester County, said he supplied Witt representatives with phone numbers and addresses of organizations, contacts, and agencies involved in the county’s emergency plan. However, when WPCNR asked if Witt had asked Sutton to go over all the most recent changes in Westchester’s plans since September 11, Sutton said, “No, they did not.”
County Executive Andy Spano in a news conference was quoted saying the same thing.
Who is Innovative Emergency Management?
Innovative Emergency Management employs at least one person with nuclear background among their principal officers. He is Ted G. Lemcke, an expert in using computer models to simulate and assess threats from weapons of mass destruction. However, he did not contribute to the Witt report, or sign off on I.E.M.’s contribution to it, he said. He referred WPCNR to Roy Williams of Witt Associates for more information. Mr. Williams did not return two WPCNR calls last Thursday..
WPCNR interviewed Barry Scanlon, Vice President of Witt Associates on the issue of who prepared the Indian Point assessments. He would not say who Witt’s nuclear experts were. “We’re confident with the expertise of our team,” Scanlon said. Scanlon said they were “internally reviewing comments” received on the draft report when interviewed by WPCNR last Thursday. He said last week he did not know if the names of the Witt nuclear experts were going to be released.
FEMA Takes Report to Task.
The Witt Report sources for Indian Point information appear to be their analysis of operating and licensing documents filed by Indian Point recently. Entergy purchased the plant in 2001. Neither IEM nor Witt representatives visited Indian Point on fact-finding missions, according to Jim Steets, Entergy spokesman, except to visit the Emergency Operations Center at Indian Point on September 24 when the County Wide Exercise mentioned prominently in the report was staged.
The reviewers of those documents cited in the Witt Report appendix which Indian Point had filed with the commissions and FEMA appear not to have interacted with Entergy officials to see whether or not Indian Point had complied with 73 of the “Not Met” judgments contained in those reports, which The Witt Report lists as having been “not met.”
FEMA says Witt Report Does Public a Disservice with False Impression of Number of “Not Mets.”.
According to FEMA, “Plan Reviews, efforts should have been made by the authors of the NY State Report (Witt Report) to verify their concerns with the plans before characterizing each as not meeting requirements. The authors of the NY State Report did not include a review of the procedures that are an integral part of the plan and where many of the details of what is to be done are included. By this approach, the report does the public a disservice when referring to requirements not being met in Appendix C.”
Entergy is Diplomatic.
Entergy made reference to this condition in their news release of February 7, when they wrote, “The draft also contains significant factual errors.” According to Entergy, in the Witt Report appendixes, of 198 elements listed by the Witt Report, where 73 where reported “not met,” actual not met totals were only 11, according to Entergy. Four of those 11 “Not Mets” were not required by a nuclear plant licensee, and the remaining 7, 2 were not required in the plan, 2 were not met, and 3 have been partially met.
Nuclear Experts Shocked.
Experts from around the country, not employed by Entergy, are reported “shocked” about the technical inaccuracies that are contained in The Witt Report as being the present condition of Indian Point ability to report accidents, plume-releases, and where the plumes might drift.
A Most Glaring Misunderstanding.
The Witt Report assumes is that Entergy does not use up-to-date computer technology which the Witt “experts” say have lead to its conclusions. Entergy official, Jim Steets, said this could have been avoided had Witt Associates sought a detailed tour of the Indian Point facility, conducted briefings with Indian Point managers, workers and personnel. No Witt representatives , Steets and Slobodien say, consulted with Indian Point officials on what security procedures were in place, nor consulted them on the details of the internal operational procedures of the plant. Steets said the Indian Point facility would have cleared them to discuss confidential security procedures in place, for The Witt Team to make a more meaningful assessment.
FEMA Strikes Back: Terrorist Events Analyzed with Same Procedure.
FEMA’s report goes much farther than Entergy’s polite comments released to the media February 7, FEMA systematically, chapter-by-chapter cite the report for inaccuracies in sweeping, uncompromising fashion, error by error.
From their “Executive Summary,” FEMA tells you where they are coming from:FEMA also believes that a number of the issues raised by the state report are not supported by FEMA’s own exercise evaluations, plan reviews and knowledge of the Radiological Emergency Response Program.
The Big Ten
In FEMA’s Executive Summary they list 10 major issues with Witt conclusions, in assessing the plans, saying flat out, “the emergency plans…are adequate to protect the public health and safety if updated and exercised consistent with current guidelines.”
FEMA disputes Witt Report worries about a terrorist attack:
Emergency response plans are periodically updated and are designed to be flexible enough to respond to a wide variety of adverse conditions, including a terrorist attack. The planning process has demonstrated its robustness and ability to evolve and improve during the years since the Three Mile Island accident.
The coordinated response to contain or mitigate a threatened or actual release of radioactive material would be essentially the same whether it resulted from an accidental or terrorist act. Further, it should be stated that every biennial exercise has used releases or potential releases that require an evacuation of at least a portion of the planning zone.
Witt Report Misses What’s Changed.
FEMA, just warming up notes the Witt Report does not account for the significant security measures that have been put in place since the terrorist acts of September 11, 2001.FEMA reports, “Immediately after the attacks, the Nuclear Regulatory Commission staff undertook a comprehensive evaluation of NRC’s security and safeguards program. On February 25, 2002, the NRC issued orders… that include increased patrols, augmented security forces and capabilities, additional security posts, installation of physical barriers, vehicle checks at greater standoff distances, enhanced coordination with law enforcement and military authorities, and more restrictive site access controls for all personnel….Entergy and Dominion (Millstone plant) are both in full compliance with the order and enhanced security measures are in place at Indian Point and Millstone.
Sheltering a Red Herring.
FEMA Dismisses The Witt Report Concern for “Sheltering:”:
…extensive studies of severe reactor accidents have been performed. These studies clearly indicate that for all but a very limited set of conditions, prompt evacuation of an area near the plant is much more effective in reducing the risk of early health effects than sheltering the population in the event of severe accidents. even in the event of a plume condition. FEMA reports that the population to be evacuated only applies to populations “immediately at risk, nominally those within 2 miles of the plant and about 5 miles downwind.”
FEMA Asserts They Have Planned
FEMA takes strong exception to The Witt Report comment that “Calculations of the optimal strategies for protecting the public safety and health are best done during the planning phase and incorporated into the emergency plans. There are no such comprehensive analyses incorporated as part of the plans for the Indian Point facility, counties or the State of New York.”
FEMA says this is 100% wrong, citing “extensive” guidance that has been used to set “event severity levels,” they call Emergency Action Levels, which FEMA writes, specify abnormal plant conditions and classify them according to the security level…The severity level classification of the event dictates onsite actions, including notification of responders and offsite authorities, recommending onsite and offsite protective actions.
Challenges that Evacuation Times Are Reasonable.
FEMA takes on The Witt Report criticism of evacuation times, by noting that there is time to make evacuation pre-calls because of the limited area involved:
Only a fraction of the EPZ (Evacuation Protection Zone) will be in the potential pathway of the plume at any point in time due to such factors as wind direction and speed. This is the population for which protective actions, such as evacuation, are needed. It is possible to move out of the plume by traveling only a short distance perpendicular to the downwind direction of the plume.
About 85 Specific Errors, Discrepancies and Alleged Misjudgments. And Bad Math.
The agency takes The Witt Report apart, chapter by chapter, reciting specific Witt Report errors, inaccuracies, and assumptions and opinions that are hard to understand:
Some examples: Witt claims the exercise process was not based on Performance. FEMA says the 2002 exercise for Indian Point was.
Witt Report Offers to Fix the Exercise Plan
In fact, WPCNR, in reading The Witt Report, noted a description of their partner’s process for Perfomance-Based Outcomes in determining emergency plans. This passage might be construed to be an offer to help New York and Westchester revise the emergency plan, writing, on page 193 of the draft Witt Report, in promoting its partner, Innovative Emergency Management:
…a REP (Radiological Emergency Plan) exercise has to be able to clearly demonstrate, using consistent, objective data, that the public safety goal has been served. Saying it has been served without the data to objectively defend the judgment will affect the acceptability of the judgment. This is the main shortcoming we observe in the implementation of the current REP exercise methodology.
To further enhance the “outcome-based” evaluation methodology for REP, a product-based emergency management structure is necessary. In our work in emergency management in the last 18 years, we have repeatedly witnessed the problems caused by the functional approach to emergency management. To solve these problems, IEM (Innovative Emergency Management, Witt Associates’ partners in writing the report), developed a product-based emergency management architecture about seven years ago. The Public Protection Performance Architecture defines the “products” or performance outcomes to be achieved in managing a response to an emergency. The product-based approach looks at the end points sought by customers…In reviews of many disaster case studies and in the course of many consulting assignments across the United States and some overseas, we understand that there are basic services or products that citizens demand.
FEMA Accuses Witt Report of Ignoring Pre-Evacuation Strategies
The Witt “Major Conclusion” ignores the fact that evacuations can and will occur before there is a release. FEMA remarks: “a release in most cases will be of limited speed and it will take time for it to move from the reactor building to the site boundary to the 10-mile boundary of the EPZ.”
The Witt Report says tone alert radios have not been widely implemented. FEMA reports, “this statement is without substance and is inaccurate. Each of the four counties has tone-alert radios distributed throughout their respective emergency planning zones and this information is provided in each of the county plans.”
Wanted: A Calculator.
FEMA identifies a major table of radiation effects discrepancy where the Witt Report says one thing but their table disagrees. Witt Report copy reads that “high, short-term doses can cause early side effects…receiving such high doses can be compared to receiving four lifetimes of normal background radiation in an extremely short time span.
FEMA calls them on this: “The report identifies an average radiation dose received yearly to be approximately 360 millirem. Acute exposures to four lifetimes of natural background radiation would be approximately 100 REM, well below the lowest entry in the table of effects located on page 26 of the Draft report. (200 REM—where 1 percent die within 30 days if untreated. 5% suffer nausea.)
FEMA notes this as a major error.
There are many more FEMA documentations of factual errors and misunderstandings that are equally damaging to the Witt Report conclusions.
FEMA Concerns Itself with Witt Advocacy Group Data
The FEMA critique wraps up with citing some of what it says are about 35 Witt misinterpretations of the Practice and Full-Scale Exercises last September, and spends several pages, debunking the concerns of “Advocacy Groups,” as expressed and supported by The Witt Team.
The lead sentence of the second paragraph under “FEMA comments on Appendix J: Advocacy Issues,” says it all: The authors of this report provide the concerns as basic well-grounded facts rather than clarifying where there is misinformation and half-truths.”
FEMA returns to the central Witt hypothesis of “a faster-moving event,” they note: …fourth bullet indicates that the emergency plans fails to consider radiation release from spent fuel pools. First, just as with a terrorism incident or a leaky valve, the off-site response will be the same. Second, unlike the reactor core, there is nothing “pushing” radiation up and out beyond the site boundary to off-site areas. Third, cooling pools are 40 feet of water encased in concrete within a concrete and steel structure. Any time of radiation release is highly speculative.
On page J-2 of the Witt Report, FEMA questions Witt Associates “misguided concerns based on partial information.” The FEMA team notes “these concerns include not planning for a “fast breaker” by the utility, the capacity of area hospitals to treat workers and citizens, refusal to medical personnel to report, and the location of reception centers. The hospitals are not used to do initial monitoring of individuals; that is to occur at the reception centers. The hospitals will be used in the event someone requires medical attention, broken leg, heart problems, etc., and capacity should not be exceeded.”
In conclusion, FEMA comments on the Petition for Withdrawal of FEMA approval, and goes into extensive detail on why the petition has no merit.
Witt Associates is being paid approximately $850,000 by New York State for the Witt Report.
