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WPCNR County Clarion-Ledger. Excerpted from Final Witt Report. March 8, 2003: James Lee Witt Associates has included a special Appendix to its Final Witt Report released Friday that scolds the conclusions being reached by the public and the media and their focus on the terrorist aspects of their report.
In brief, the appendix admits that faster and larger releases based on terrorism was something they did not mean to imply, but did. The statement speculates new scenarios that could hamper the evacuation plans. It says the present evacuation plans should be used, but improved. It clarifies and corrects the impression given by their Draft Report and admits Indian Point is in full compliance with NRC and FEMA requirements.
Witt’s men question nuclear experts wanting to hold Witt Associates to a scientific standard of proof and imply nuclear people criticising the report, do not have their (Witt) expertise in emergency management. They say closing the plant would not remove the need to protect the plant. The statement adds that they were not supposed to evaluate the possibility of a radioactive release to the public as part of their job. Here is that appendix, as it was released to the media Friday afternoon:
Issues with which we agree, but did not emphasize or clarify sufficiently in the draft.
JLWA is aware of the public and political reactions that have resulted from the issuance of the draft report. The issuance of the draft for public comment is evidence of our concern that our report not be used in a way that would mislead or misinform the public. We are also concerned about possible misrepresentation of the report. As a consequence we feel it both necessary and appropriate to emphasize some issues we may not have accentuated or clarified sufficiently in the draft.
1. Closing Indian Point would not remove the need for improvements in emergency preparedness. We believe most people recognize that closing the plant would not remove the source of radiation and that special provisions for the protection of people, common to all nuclear plants, would need to remain in place. We are concerned that decision makers and the general public not lose sight of the need to make improvements. This will require federal, state, local, business and citizen support, including financial support, as those responsible struggle with some very difficult issues.
It is possible that visible improvements would be of value in raising public confidence about the degree of protection available, and that that enhanced public confidence may result in behaviors that improve the effectiveness of a response.
2. The existing plans should be followed during an emergency. Our intent was not to discredit the plans, but to improve them. Our experience leads us to believe public safety is enhanced by adherence to the recommendations of public authorities charged with the protection of public safety. Those authorities should use the plans they have, adjusting them according to circumstances and their best judgment. A plan should be viewed as a living document that is constantly evolving and being improved.
3. The media and others are focusing on the terrorist threat to the plant itself. We have not focused on any possible threats to the plant. The draft report identified a variety of significant issues that need to be addressed, regardless of a terrorist threat. We are concerned that the issues that exist independent of a possible terrorist threat are not getting the attention they deserve.
4. Both Millstone and Indian Point meet current NRC and FEMA standards. The NRC has stated as recently as November 18, 2002, that FEMA’s preliminary assessment of the capabilities of, and compliance by, the State and its jurisdictions, based on the September 24, 2002 exercise, indicates the off-site emergency plans are adequate to protect public health and safety. Although we may come to different conclusions regarding adequacy apart from the standards, and believe NRC and FEMA requirements need revision, we recognize that those requirements are the product of many years of serious thought and strenuous effort dedicated to the public well-being.
Related to this issue is the high standard to which we hold ourselves. In other words, is there anything short of perfection that will satisfy us? We neither expect nor require perfection in a plan. We note in the draft that disaster experience shows how people can rise to an occasion, how responses can be effective in spite of defective plans, and how plans for one event can be used for other events.
Nevertheless, we have not seen a plan that had no room for improvement, and our task was, in part, to recommend improvements whether or not the plans met current requirements. In so doing we needed some standard to measure the effectiveness of protective measures. We used the EPA Protective Action Guideline as the one most applicable, recognized and defensible. The result of these considerations and our review was a set of recommendations that do involve a high standard of protection. We do not consider that standard impossible or unreasonable, but readily recognize that some in our profession may disagree.
5. There are some unique aspects of terrorism that off-site planning and exercising should address. There may be some planning and response considerations that are not addressed in “tried and true” planning and exercising. For example, there may be impacts on the thinking, emotions and reactions of the population and responders when the report of an accident says “radiological release” and “terrorism” in the same sentence. Although we do not know for certain what those impacts are, they should not be ignored using the argument that the off-site response to a terrorist-induced event would be the same as the response to any other event.
Another example is an incident that involves multiple, nearly simultaneous obstruction of evacuation routes in addition to those that would occur in a “normal” evacuation. Because these obstructions can be assumed to be deliberately designed to cause disruption, they may also be more difficult to address than normal traffic problems.
Another example would be actions that target responders.
An additional question that needs to be explored is whether there would be higher levels of convergence (arrival of people into the area) in a terrorist event than has already been documented for radiological events such as Three Mile Island. We expect, too, that spontaneous evacuation may be more of a problem than it would be in a non-terrorist event.
The bombing of the Murrah Federal Building in Oklahoma City in 1995 demonstrated how the presence of a crime scene significantly changes the communications and coordination aspects of a disaster response. Those who are responding to a terrorist assault are no longer available for normal event law enforcement activities, such as the safe evacuation of the affected populace.
In the response to a terrorist event at Indian Point or Millstone, it may well be that news media, law enforcement and/or others reduce the degree of control over the content and timing of information that the plant authorities would otherwise have. Agencies, such as the FBI, will likely insist on involvement in both on-site and off-site activities in ways not contemplated in existing plans and exercises.
6. We attempted to take no position on whether a terrorist act could cause a faster or larger release. On page 240 we stated, “When considered together, however, it is our conclusion that the current radiological response system and capabilities are not adequate to overcome their combined weight and protect the people from an unacceptable dose of radiation in the event of a release from Indian Point, especially if the release is faster or larger than the typical REP exercise scenario (often called “design-basis release”) (emphasis added). On page viii of the Executive Summary, we shortened the highlighted phrase to “… especially if the release is faster or larger than the design-basis release.” We considered these to be equivalent statements. Nevertheless the phrase in the Executive Summary caused confusion, and charges that we assert a terrorist attack can result in a faster and/or larger release, an issue upon which we intended to take no position. Consequently, we have changed the wording in the Executive Summary.
7. We were asked to provide our observations and recommendations as experts in the field of Emergency Management. We did not attempt to adjudicate disputes among scientists, such as the probabilities of a release. We disclaimed such intentions on page 19 of the draft. Nevertheless, some have attempted to discredit us and the draft on the basis that it is not scientific.
We are confident that our emergency management credentials qualify us to present our findings, conclusions and recommendations. We would suggest that nuclear engineers and others who take us to task for inadequate scientific rigor in what we say about emergency management might first consider their own qualifications in our field. They are entitled to disagree, as might some of our colleagues in emergency management, but they should not scorn our findings, conclusions and recommendations on the grounds that they lack scientific demonstrability.
8. Emergency management is not the only issue involved in the debate about nuclear power plants. We made it clear in the draft that alternate sources of energy and economic considerations are important, even though we were not asked to address them. Most public enterprises involve some degree of risk. Although we have questioned the degree to which the public is protected in the event of a release, we have not addressed the degree of risk people are willing to accept in exchange for benefits they receive, which is another legitimate aspect of the debate.
