In October, 2012 I wrote a post titled Attacking Iran Is Like Setting Off Nuclear Bombs on the Ground about a report released the previous month. Titled The Ayatollah’s Nuclear Gamble, it’s the product of an organization called Omid for Iran, along with the Hinckley Institute of Politics and the University of Utah. Omid for Iran was founded by Khosrow B. Semnani, the Iranian immigrant who became a radioactive waste disposal magnate. A controversial figure often embroiled in lawsuits, he served as president of his company Envirocare until the Department of Energy requested he step down in the wake of a bribery scandal.

Like many immigrants who make good in the United States, he draws on a reserve of rancor toward the forces in his country of origin (usually, in these cases, communist) that keep an entrepreneur like him from fulfilling his dream. You can tell by this excerpt from the executive summary of “The Ayatollah’s Nuclear Gamble” that, should they attack Iran, he’s less interested in blaming Israel and the United States than he is Tehran for inciting them.

The best long-term strategy would be a democratic, transparent, and accountable government in Iran. In such a scenario, political leaders would quickly understand that their people want jobs, dignity, opportunity, and political freedoms, not the false promise of nuclear weapons bought at a heavy, even existential, cost. A military strike would not only kill thousands of civilians and expose tens and possibly hundreds of thousands to highly toxic chemicals, it would also have a devastating effect on those who dream of democracy in Iran. Ayatollah Khamenei has proven that he cares little for the Iranian people. It is up to us in the international community, including the Iranian-American diaspora to demonstrate that we do.

As for the attack…

Based on the best information available as well as discussions with Iranian and Western nuclear experts, we have estimated the total number of people—scientists, workers, soldiers and support staff—at Iran’s four nuclear facilities to be between 7,000 and 11,000. … However, unlike traditional targets, the risks to civilians extend well beyond those killed from exposure to thermal and blast injuries at the nuclear sites. Tens, and quite possibly, hundreds of thousands of civilians could be exposed to highly toxic chemical plumes and, in the case of operational reactors, radioactive fallout. … Additionally, the environmental deg­radation due to the spread of airborne uranium compounds, and their entry into water, soil and the food chain would introduce long-term, chronic health risks such as a spike in cancer rates and birth defects.

Nor have Iran’s leaders shown any inclination to present such an assessment.

[They] have had no interest in making the risks of their reckless nuclear policies obvious to its citizens even though the resulting economic toll—inflation, unem­ployment, and the loss of international credit—has devastated the Iranian people. The Iranian military has not provided the Iranian people with any description of potential casualties resulting from attacks on these nuclear facilities. Nor has the parliament encouraged an open assessment of the grave implications of the government’s policies for Iranian scientists, soldiers and civilians working at or living within the vicinity of Iran’s nuclear facilities. This study seeks to address this deficit.

Or, in my words …

… the attack and radiation will work its synergistic black magic in conjunction with Iran’s meager disaster management and emergency preparation capabilities. … bombing Iranian nuclear facilities is like setting off nuclear weapons on the ground.

While reading “The Ayatollah’s Nuclear Gamble” I couldn’t help but wonder how Iran was allowed to sign the nuclear Non-proliferation Treaty and to become a member state of the International Atomic Energy Agency (IAEA) without instituting an effective emergency preparedness program. (Or one that at least upheld the pretense that it’s possible to deal with a meltdown or attack on a nuclear-energy facility effectively.) It seems wildly irresponsible, kind of like starting a war without medical staff and hospitals.

A passage from the IAEA’s website sheds some light on this.

Many Member States are currently not adequately prepared to respond to such emergency situations. Moreover, without standard procedures or common approaches, protective actions can differ between countries resulting in confusion and mistrust among the public, interfering with recovery operations and possibly leading to severe socioeconomic and political consequences.…

The Agency has a statutory function to develop standards for the protection of health and the environment and to provide on request for their application, through encouraging research and development; fostering information exchange; promoting education and training; and rendering services. Moreover, the Convention on Early Notification of a Nuclear Accident (Early Notification Convention) and the Convention on Assistance in the Case of a Nuclear Accident or Radiological Emergency (Assistance Convention) place specific functions on the Agency with regard to developing appropriate radiation monitoring standards and to assisting States in developing their own preparedness arrangements for nuclear and radiological emergencies.

The IAEA’s programs, as was pointed out to us by Institute for Policy Studies author Robert Alvarez, can be found on its Emergency response & preparedness page. For example: “Preparedness and Response for a Nuclear or Radiological Emergency Safety Requirements” (2002), “Preparedness and Response for a Nuclear or Radiological Emergency Safety Requirements” (2007), “Criteria for Use in Preparedness and Response for a Nuclear or Radiological Emergency General Safety Guide” (20110).

In the second paragraph from the IAEA website quoted above, note that conventions (as in agreements) “place specific functions on the Agency with regard to developing appropriate radiation monitoring standards and to assisting States in developing their own preparedness arrangements for nuclear and radiological emergencies.” (Emphasis added.) Developing and assisting — but not requiring. From the 2007 report referred to above…

The IAEA’s safety standards are not legally binding on Member States but may be adopted by them, at their own discretion, for use in national regulations in respect of their own activities. The standards are binding on the IAEA in relation to its own operations and on States in relation to operations assisted by the IAEA.

By all appearances, allowing member states to develop nuclear-energy programs without requiring them to meet certain standards of emergency preparedness looks as if it’s a loophole designed to either allow states to develop nuclear-energy programs without delay or to aid the nuclear-energy industry (or both). It’s incumbent on the United States and Israel to refrain from attacking Iran and turning that loophole into a gaping abyss of human torment.

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