June 25, 2007 

MEMORANDUM TO: Luis A. Reyes 

Executive Director for Operations 

FROM: Stephen D. Dingbaum /RA/ 

Assistant Inspector General for Audits 

SUBJECT: AUDIT OF NRC’S EMERGENCY PREPAREDNESS 

PROGRAM (OIG-07-A-13) 

Attached is the Office of the Inspector General’s (OIG) report titled, Audit of NRC’s 

Emergency Preparedness Program.

This report presents the results of the subject audit. Agency comments provided at the 

exit conference on June 6, 2007, have been incorporated, as appropriate, into this 

report. The agency did not provide formal comments. 

Please provide information on actions taken or planned on each of the 

recommendations within 30 days of the date of this memorandum. Actions taken or 

planned are subject to OIG follow up as stated in Management Directive 6.1. 

We appreciate the cooperation extended to us by members of your staff during the 

audit. If you have any questions or comments about our report, please contact me at 

415-5915, or Beth Serepca at 415-5911. 

Attachment: As stated 
Electronic Distribution

Frank P. Gillespie, Executive Director, Advisory Committee on Reactor 

 Safeguards/Advisory Committee on Nuclear Waste 

E. Roy Hawkens, Chief Administrative Judge, Atomic Safety and 

 Licensing Board Panel 

Karen D. Cyr, General Counsel 

John F. Cordes, Jr., Director, Office of Commission Appellate Adjudication 

Peter J. Rabideau, Acting Chief Financial Officer 

Janice Dunn Lee, Director, Office of International Programs 

Rebecca L. Schmidt, Director, Office of Congressional Affairs 

Eliot B. Brenner, Director, Office of Public Affairs 

Annette Vietti-Cook, Secretary of the Commission 

William F. Kane, Deputy Executive Director for Reactor 

 and Preparedness Programs, OEDO 

Martin J. Virgilio, Deputy Executive Director for Materials, Waste, Research, 

 State, Tribal, and Compliance Programs, OEDO 

Jacqueline E. Silber, Deputy Executive Director for Information Services 

 and Administration and Chief Information Officer, OEDO 

Vonna L. Ordaz, Assistant for Operations, OEDO 

Timothy F. Hagan, Director, Office of Administration 

Cynthia A. Carpenter, Director, Office of Enforcement 

Charles L. Miller, Director, Office of Federal and State Materials 

 and Environmental Management Programs 

Guy P. Caputo, Director, Office of Investigations 

Edward T. Baker, Director, Office of Information Services 

James F. McDermott, Director, Office of Human Resources 

R. William Borchardt, Director, Office of New Reactors 

Michael F. Weber, Director, Office of Nuclear Material Safety and Safeguards 

James E. Dyer, Director, Office of Nuclear Reactor Regulation 

Brian W. Sheron, Director, Office of Nuclear Regulatory Research 

Corenthis B. Kelley, Director, Office of Small Business and Civil Rights 

Roy P. Zimmerman, Director, Office of Nuclear Security and Incident Response 

Samuel J. Collins, Regional Administrator, Region I 

William D. Travers, Regional Administrator, Region II 

James L. Caldwell, Regional Administrator, Region III I 

Bruce S. Mallett, Regional Administrator, Region IV 
AUDIT REPORT 

Audit of NRC’s Emergency Preparedness Program 

OIG-07-A-13 June 25, 2007 

All publicly available OIG reports (including this report) are accessible through 

NRC’s Web site at: 

http:/www.nrc.gov/reading-rm/doc-collections/insp-gen/ 
Audit of NRC’s Emergency Preparedness Program 

i

I. EXECUTIVE SUMMARY 

BACKGROUND

Emergency Preparedness (EP) is one of the seven cornerstones of 

the Reactor Oversight Process, which is the Nuclear Regulatory 

Commission’s (NRC) primary mechanism for nuclear power plant 

oversight. The objective of the EP cornerstone is to ensure that 

licensees operating nuclear power plants are capable of taking 

adequate measures to protect public health and safety during a 

radiological emergency. 

NRC regulations require licensees to have comprehensive EP 

programs, which include dedicated emergency response facilities, 

systems, equipment, and staffing. Licensees must describe their 

programs in facility-specific plans that provide licensee staff with 

guidance for responding to a range of emergency situations. NRC 

inspectors assess the ability of licensees to execute specific 

elements of their EP plans such as coordination with offsite 

emergency response organizations during EP drills and exercises. 

Licensees conduct quarterly onsite EP drills, as well as biennial EP 

exercises that simulate emergencies and involve NRC as well as 

State and local authorities. During these exercises, the Federal 

Emergency Management Agency (FEMA) assesses State and local 

response organizations’ implementation of their emergency plans. 

PURPOSE

The objectives of this audit were to evaluate: 

1) NRC’s efforts to ensure that nuclear power plant licensees have 

adequate EP plans and programs for security-based 

emergencies, and; 

2) NRC’s coordination with Federal, State, and local authorities to 

plan and prepare for security-based emergencies. 

RESULTS IN BRIEF

With respect to the first objective, NRC is making a sufficient effort 

to ensure that nuclear power plant licensees have adequate EP 

plans and programs. However, in regard to the second objective, 

this audit found a weakness within the EP program. Specifically, 

NRC has not followed a consistent process for communicating its 

coordination role with State and local government authorities. 
Audit of NRC’s Emergency Preparedness Program 

ii

Weakness in NRC’s Coordination with State and Local 

Government Authorities

In the event of radiological emergencies that occur at nuclear 

power plants, NRC is responsible for supporting State and local 

emergency management organizations and coordinating the 

Federal Government’s response under the National Response 

Plan. However, NRC has repeatedly demonstrated problems 

coordinating and communicating with State authorities during EP 

exercises. This weakness recurs because (1) NRC has not clearly 

defined and communicated its coordination role to State and local 

authorities, and (2) has not followed a consistent approach for 

working with the States during these exercises. Inadequate 

coordination and communication adversely affects NRC’s 

emergency operations with State agencies and could diminish the 

public’s confidence in NRC. 

RECOMMENDATIONS

This report makes two recommendations to help NRC improve its 

emergency preparedness coordination with State agencies. These 

recommendations appear on page 10 of this report. 

. 

AGENCY COMMENTS

At an exit conference held on June 6, 2007, agency managers 

generally agreed with the audit findings and recommendations and 

provided comments concerning the draft audit report. We modified 

the report in response to these comments as we determined 

appropriate. NRC reviewed these modifications and opted not to 

submit formal written comments for the final version of this report. 
Audit of NRC’s Emergency Preparedness Program 

iii

ABBREVIATIONS AND ACRONYMS 

DHS Department of Homeland Security 

EP Emergency Preparedness 

FEMA Federal Emergency Management Agency 

FTE full-time equivalent 

MD Management Directive 

NSIR Office of Nuclear Security and Incident Response 

NRC U.S. Nuclear Regulatory Commission 

OIG Office of the Inspector General 

RSLO Regional State Liaison Officer 
Audit of NRC’s Emergency Preparedness Program 

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Audit of NRC’s Emergency Preparedness Program 

v

TABLE OF CONTENTS 

EXECUTIVE SUMMARY..............................................................................i 

ABBREVIATIONS AND ACRONYMS ..........................................................iii 

I. BACKGROUND ...................................................................................1 

II. PURPOSE............................................................................................4 

III. FINDING 

WEAKNESS IN NRC’S COORDINATION WITH STATE AND LOCAL 

GOVERNMENT AUTHORITIES ...................................................................5 

 

IV. AGENCY COMMENTS ........................................................................11 

 

APPENDICIES 

A. SCOPE AND METHODOLOGY .....................................................13 

B. SELECTED REGIONAL STATE LIAISON OFFICER (RSLO) 

FUNCTIONS...................................................................................15 
Audit of NRC’s Emergency Preparedness Program 

vi

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Audit of NRC’s Emergency Preparedness Program 

1

I. BACKGROUND 

Emergency Preparedness is one of the seven cornerstones of the 

Reactor Oversight Process, which is NRC’s primary mechanism for 

nuclear power plant oversight. The objective of the EP cornerstone 

is to ensure that licensees operating nuclear power plants are 

capable of taking adequate measures to protect public health and 

safety during a radiological emergency. 

Figure 1: NRC’s Regulatory Framework 

NRC’s Office of Nuclear Security and Incident Response (NSIR) 

manages this cornerstone by developing emergency preparedness 

policies, regulations, programs, and guidelines for currently 

licensed nuclear reactors and potential new nuclear reactors. NSIR 

EP staff issue internal and external communications and conduct 

inspections, licensing reviews, and regulation and guidance 

reviews. They also interface and coordinate with internal and 

external stakeholders including other NRC offices, the public, 

industry, the international nuclear community, and Federal and 

State government agencies. In FY 2006, NSIR’s budget for 

preparedness and response activities was comprised of 85 fulltime equivalent (FTE) staff and $1.018 million. This resource 

allocation included funding for 60 NRC Headquarters personnel, 

and 25 FTE 
Audit of NRC’s Emergency Preparedness Program 

2

at NRC Regional offices, including 2 FTE per regional office for 

conducting the portion of reactor safety inspections that addresses 

the EP cornerstone of the Reactor Oversight Process. 

NRC Emphasis on Emergency Preparedness

Since the terrorist attacks of September 11, 2001, NRC has placed 

renewed emphasis on emergency planning and response, as 

evidenced by subsequent regulatory actions and participation in 

interagency initiatives. For example, NSIR staff: 

 Issued orders to operating reactors in October 2002 to 

review and address enhancements to security and 

emergency preparedness programs. 

 Issued generic communications to operating reactors in 

2004 specific to security-related emergency preparedness 

enhancement lessons learned. 

 Surveyed and provided information to nuclear power plant 

licensees in 2005 to determine how licensees have 

incorporated new security features into their emergency 

plans and programs. 

 Reviewed existing EP regulations and guidance during 2006, 

and identified potential enhancements, particularly in the 

area of security. 

 Participated in comprehensive reviews of security and 

emergency response capabilities around nuclear facilities. 

NRC and the Federal Emergency Management Agency (FEMA)1

Oversight of Emergency Preparedness 

Both NRC and FEMA have roles in the emergency planning 

activities for nuclear power plants. NRC regulates the emergency 

planning activities within the physical boundaries of nuclear power 

plant facility perimeters. FEMA evaluates the emergency planning 

activities outside the physical boundaries of nuclear power plants. 

 

1

 On March 1, 2003, the Federal Emergency Management Agency (FEMA) became part of the 

Department of Homeland Security (DHS). FEMA's continuing mission within the new department 

is to lead the effort to prepare the Nation for all hazards and effectively manage Federal response 

and recovery efforts following any national incident. 
Audit of NRC’s Emergency Preparedness Program 

3

During biennial full-participation EP exercises, NRC evaluates 

licensees implementation of their emergency plans, while FEMA 

assesses State and local authorities’ abilities to carry out offsite 

emergency plans. 

Figure 2: NRC regulates the emergency planning activities within the 

physical boundaries of nuclear power plant facility perimeters. 

NRC EP Oversight 

NRC regulations require licensees to have comprehensive onsite2

EP programs, which include dedicated emergency response 

facilities, systems, equipment, and staffing. Licensees must 

describe their EP programs in facility-specific plans and procedures 

that provide licensee staff with guidance for responding to a range 

of emergency situations, including natural disasters, operational 

accidents, and terrorist attacks.3 In fulfilling NRC’s Reactor 

Oversight Process, NRC inspectors assess the ability of licensees 

to execute specific elements of their EP plans such as coordination 

with offsite emergency response organizations during EP drills and 

 

2

 Onsite refers to emergency preparedness activities that occur within the perimeter of NRC 

licensed facilities such as nuclear power plants. 

3

 Emergency preparedness planning standards are contained in 10 CFR 50.47(b) and 10 CFR 50 

Appendix E. 
Audit of NRC’s Emergency Preparedness Program 

4

exercises. Licensees conduct periodic onsite EP drills, as well as 

biennial EP exercises that involve NRC and State and local 

authorities. Biennial exercises are evaluated by the NRC and 

FEMA. These biennial exercises simulate incidents that typically 

escalate in seriousness to a “general emergency,” the highest-level 

emergency category for nuclear power plants. 

FEMA EP Oversight 

FEMA oversees State and local authorities’ offsite4

 emergency 

plans and programs, which are designed to protect communities 

surrounding nuclear power plants. FEMA formulates 

determinations regarding the adequacy of offsite emergency 

preparedness. To determine whether offsite plans and programs 

are adequate and can be implemented during an actual 

emergency, FEMA evaluates the offsite performance of State and 

local authorities during EP biennial exercises. A memorandum of 

understanding between FEMA and NRC provides for NRC review 

and feedback concerning FEMA EP-related determinations and for 

the two agencies’ collaboration in other areas of mutual interest. 

II. PURPOSE 

The audit objectives were to evaluate: 

1) NRC’s efforts to ensure that nuclear power plant licensees have 

adequate EP plans and programs for security-based 

emergencies. 

2) NRC’s coordination with Federal, State, and local authorities to 

plan and prepare for security-based emergencies. 

See Appendix A for a description of the audit scope and 

methodology. 

 

4

 Offsite refers to emergency preparedness activities that occur outside the parameters of NRC 

licensed facilities. 
Audit of NRC’s Emergency Preparedness Program 

5

III. FINDING 

In regard to the first objective, NRC has completed EP initiatives 

over the past several years, and additional EP management 

initiatives are underway that will further enhance the EP program. 

The audit team observed biennial exercises at four nuclear power 

plants, interviewed EP inspectors, and gathered training 

documentation and found that NRC fulfills its EP exercise 

inspection requirements by: 

 Routinely assessing licensees using criteria in the Reactor 

Oversight Process (IMC 0308). 

 Staffing EP inspections with a lead inspector who has 

completed the agency’s EP specialist training and supporting 

inspectors who have received specific EP training related to 

their inspection focus. 

NRC is making a sufficient effort to ensure that nuclear power plant 

licensees have adequate EP plans and programs. No weaknesses 

were found regarding the first objective during the EP exercises 

that OIG observed. 

In regard to the second objective, this audit found a weakness 

within the EP program. Specifically, NRC should improve its 

processes for communication of its coordination responsibilities 

with State and local government authorities during emergency 

preparedness exercises. 

Weakness in NRC’s Coordination with State and Local Government 

Authorities 

In the event of radiological emergencies that occur at nuclear 

power plants, NRC is responsible for supporting State and local 

emergency management organizations and coordinating the 

Federal Government’s response. However, NRC has repeatedly 

demonstrated problems coordinating with State authorities during 

EP exercises. The weakness in NRC’s coordination with State 

authorities recurs because (1) NRC has not followed a consistent 

approach for working with the States during these exercises and (2) 

has not clearly defined or communicated its coordination role. 

Inadequate coordination adversely affects NRC’s operations with 

State agencies during EP exercises and could diminish public 

confidence in NRC. 
Audit of NRC’s Emergency Preparedness Program 

6

The National Response Plan 5

 is the Federal Government’s plan for 

how Federal agencies should coordinate efforts to manage specific 

types of emergencies. The National Response Plan assigns NRC 

responsibility as the coordinating agency for the Federal response 

to nuclear or radiological emergencies occurring at nuclear power 

plants under NRC jurisdiction. The coordinating agency role 

includes supporting State, local, and tribal authorities, which are 

primarily responsible for managing public health and safety in 

communities surrounding nuclear facilities in case of emergency. 

NRC’s internal guidance identifies the agency’s roles and 

responsibilities in accordance with the National Response Plan. 

The NRC Incident Response Plan reflects the agency’s policy for 

responding to emergencies involving NRC-regulated facilities, and 

specifically addresses coordination with external organizations. At 

the Federal level, NRC coordinates actions of other agencies such 

as DHS, the Food and Drug Administration, Department of Energy, 

and the Environmental Protection Agency, which are involved in 

response and recovery operations, and advises key 

decisionmakers such as the President and the Congress. At the 

non-Federal level, NRC provides technical assistance and 

coordinates Federal support upon the request of State, local, and 

tribal authorities. 

Management Directive and Handbook 8.2 (MD 8.2), “NRC Incident 

Response Program,” identifies procedures for carrying out the NRC 

Incident Response Plan and assigns the roles and responsibilities 

of NRC organizations involved in implementing the plan. For 

instance, MD 8.2 requires that: 

 NSIR develop, direct, and implement the NRC Incident 

Response Plan, including outreach elements to Federal, State, 

local, and tribal organizations. 

 The Office of State and Tribal Programs6

 assists NSIR in 

implementing the State outreach program to increase and 

improve NRC's interactions with State authorities during 

exercises and briefings. To support increased outreach efforts, 

the Office of State and Tribal Programs provided each regional 

 

5 The National Response Plan addresses the objectives of the National Strategy for Homeland 

Security; Homeland Security Act of 2002; and Homeland Security Presidential Directive-5 

(HSPD-5), Management of Domestic Incidents, by establishing in writing a concerted national 

effort to prevent terrorist attacks within the United States; reduce America’s vulnerability to 

terrorism, major disasters, and other emergencies; and minimize the damage and recover from 

attacks, major disasters, and other emergencies that occur. 6

 This office was merged with another office in October 2006 to create the Office of Federal and 

State Materials and Environmental Management Programs. 
Audit of NRC’s Emergency Preparedness Program 

7

office with FTE resources for its Regional State Liaison Officer7

function as part of the FY 2007 budget allotment. Appendix B 

contains a chart that describes selected functions of the 

Regional State Liaison Officer in each regional office. 

 

 Regional administrators support an outreach program to ensure 

that licensees and State, local, and tribal organizations are 

aware of the support that NRC and other Federal agencies can 

provide during emergencies. 

Coordination Problems 

NRC repeatedly demonstrates coordination problems with State 

authorities during EP exercises. Despite acknowledging in past 

evaluations of agency exercise performance that NRC has 

communicated poorly during EP exercises, NRC headquarters staff 

during subsequent exercises have not taken adequate steps to 

change NRC’s methodology for its outreach and communications 

role with State authorities. 

 

For example, during a March 2004 EP exercise, NRC headquarters 

staff repeatedly contacted State authorities directly to obtain status 

updates. These interruptions occurred despite protests from State 

officials that they lacked time and staff to accommodate NRC’s 

information requests. After the exercise, State officials filed a 

complaint with DHS to document what they regarded as 

unnecessary NRC interference in their operations. NRC officials 

subsequently acknowledged the State officials’ concerns and 

recommended a review of existing NRC procedures to determine 

whether revisions were appropriate. NRC officials also considered 

longer-term, programmatic initiatives to improve communications 

with State authorities, with specific focus on exercise preparation 

and outreach activities. 

In May 2005, NSIR developed a program plan to integrate EP 

outreach activities that had previously been carried out by various 

NRC offices. Nevertheless, coordination problems recurred during 

subsequent EP exercises. 

During an April 2006 EP exercise, a State official stated that a NRC 

headquarters executive caused problems by calling State 

executives at least five times to obtain status updates. DHS was 

grading the State’s EP performance during this exercise; therefore 

NRC’s calls were more of a nuisance than help to the State 

executives. Furthermore, State executives were preoccupied with 

 

7

 Regional State Liaison Officers are assigned to NRC regional offices, and report to their 

respective Regional Administrators. 
Audit of NRC’s Emergency Preparedness Program 

8

their emergency management duties and had neither time nor need 

to speak directly with NRC headquarters staff. The State official 

commented that NRC’s Regional State Liaison Officer observed 

that NRC’s actions were disruptive and attempted to remedy the 

situation by advising the headquarters staff to direct 

communications through him. 

NRC noted in its evaluation of this EP exercise that the NRC 

headquarters executives encountered internal difficulties when 

facilitating communications with key State decisionmakers and 

attributed these problems to limited participation by senior State 

executives. NRC’s assessment of this exercise recommended that 

agency staff evaluate the means for improving interaction with 

States during EP exercises, but did not evaluate reasons why past 

corrective actions in this area had not been effective to remedy 

known problems. 

More recently, NRC commented in its after action evaluation of a 

September 2006 exercise, that NRC headquarters executives 

performed a cumbersome change in authority, which impacted the 

overall executive team performance. This resulted in: 

 State officials were kept waiting on the telephone for 

approximately 23 minutes while the incoming executive team 

director was briefed. 

 The licensee was kept waiting during a prescheduled nonsecure 

video teleconference. 

As a result, State officials were distracted from completing work 

related to the exercise. A DHS letter to NRC expressed concern 

over the quality and timing of NRC Headquarters actions taken 

during this exercise when not needed. NRC’s assessment of the 

exercise acknowledges that headquarters coordination problems 

compromised communication with State officials. 

To further assess NRC’s communication and coordination with 

State governments in the area of EP, OIG surveyed 43 State 

emergency management officials. Among the 31 officials who 

responded to this survey, 27 indicated that they had participated in 

EP exercises with NRC. Of the 27 State officials, 9 described 

communication problems that occurred during the 3 exercises 

previously discussed. Concerns among this group included the 

adequacy of pre-exercise coordination with NRC headquarters 

staff, as well as the timing and appropriateness of NRC 

headquarters’ communications. Several of these respondents 

acknowledged that NRC staff had met with State officials following 

the exercises to address State concerns. 
Audit of NRC’s Emergency Preparedness Program 

9

NRC Roles Not Consistent or Defined 

The weakness in NRC’s coordination with State authorities recurs 

because NRC has not followed a consistent approach for working 

with State officials to plan and conduct EP exercises. Furthermore, 

NSIR has not clearly defined or communicated NRC’s emergency 

response roles and responsibilities to State officials in its EP 

outreach efforts. 

Inconsistencies occur regarding NRC’s interactions with State and 

local officials, particularly in the areas of advance planning and 

involvement in exercises. NRC Regional State Liaison Officers 

interact regularly with State and local officials within their respective 

regions, yet interaction between headquarters-based NRC staff and 

State and local officials is inconsistent. Also, while NRC Regional 

State Liaison Officers’ specific duties vary across the four NRC 

regions, all play an EP outreach role, such as representing NRC at 

emergency planning conferences involving State and Federal 

Government officials. During EP exercises, however, a single 

agency position has not been identified to serve as the primary 

interface between their State government counterparts and NRC 

headquarters. In addition, NRC does not always conduct advance 

or consistent preparation to clarify roles and responsibilities of the 

various organizations involved in EP exercises. Lastly, the scope 

of NRC’s participation in EP exercises varies; sometimes agency 

staff are observers, while on other occasions, they are actively 

engaged as role players in the exercise scenarios. 

Senior NSIR officials recognize that the National Response Plan

and NRC’s implementing guidance are unclear in stating NRC’s 

mission as a Federal coordinating agency and therefore have 

initiated several measures to define and communicate the agency’s 

role with external stakeholders. 

In January 2006, NSIR proposed tentative plans for updating 

internal guidance, conducting tabletop exercises, and hosting 

regional conferences designed to help NRC, Federal, and State 

government officials better understand mutual EP roles and 

responsibilities. These activities are to reflect expected changes in 

a forthcoming revision of the National Response Plan. 
Audit of NRC’s Emergency Preparedness Program 

10

Impact of Coordination on Public Confidence 

Inadequate coordination adversely affects NRC’s operations with 

State agencies during EP exercises and could diminish public 

confidence in NRC. Communication problems between NRC and 

State emergency management counterparts compromise State 

agency performance in EP exercises. Exercises typically simulate, 

within a 6- to 8-hour period, incidents that would likely occur over 

several days. Given these compressed timelines, State officials 

operating with limited staff may lack time and personnel to resolve 

communications problems or coordinate their activities with NRC. 

Moreover, DHS evaluates State agency performance during EP 

exercises, so State officials must focus their efforts on their primary 

duties and demonstrate DHS evaluation objectives, which do not 

include communications with NRC. 

Ineffective communications also are reflected by comments made 

by State officials surveyed by OIG. For example, three officials 

surveyed complained that NRC had inappropriately asserted a 

command role rather than a support role during exercises. Two 

other officials surveyed said that they lacked an understanding of 

NRC’s mission because NRC staff had not explained to them how 

the agency could provide support. Overall, nearly half of all survey 

respondents recommended that NRC increase staff interaction with 

State agencies through activities such as regular drill and exercise 

participation, site-visits, and regional conferences. These types of 

outreach activities foster better understanding of NRC’s mission, 

thereby improving public confidence in the agency. 

Recommendations:

OIG recommends that the Executive Director for Operations: 

1. Identify, clarify in NRC policy, and communicate to internal 

and external stakeholders, NRC’s coordination role and 

responsibilities under the National Response Plan. 

2. Develop and implement a consistent approach for carrying 

out NRC’s coordination role and responsibilities in 

accordance with the National Response Plan. 
Audit of NRC’s Emergency Preparedness Program 

11

IV. AGENCY COMMENTS 

At an exit conference held on June 6, 2007, agency managers 

generally agreed with the audit findings and recommendations and 

provided comments concerning the draft audit report. We modified 

the report in response to these comment as we determined 

appropriate. NRC reviewed these modifications and opted not to 

submit formal written comments for the final version of this report. 
Audit of NRC’s Emergency Preparedness Program 

12

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Audit of NRC’s Emergency Preparedness Program 

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Appendix A

SCOPE AND METHODOLOGY 

Auditors evaluated NRC’s EP program to determine the 

effectiveness of the program since the EP program was integrated 

with NSIR’s Incident Response Program in June 2004. 

OIG audit team reviewed relevant internal agency criteria, such as 

NRC’s inspection and training procedures, management directives 

and Commission guidance. The OIG audit team also reviewed 

relevant laws and regulations pertaining to emergency 

preparedness. 

Auditors interviewed NSIR to learn their roles and responsibilities 

as they pertain to EP. Auditors also interviewed EP inspectors in 

Regions I, II, III, and IV to assess their understanding of the EP 

program and process to determine if their activities are conducted 

in accordance with program requirements. 

Auditors observed EP exercises at Columbia Generation Station, 

Palisades Nuclear Power Plant, Pilgrim Nuclear Power Station, and 

North Anna Nuclear Power Station and interviewed licensee EP 

Managers at those locations. Auditors also observed an EP 

exercise at the NRC Headquarters Operations Center. 

To assess NRC’s interaction with State agencies in the area of EP, 

OIG auditors analyzed relevant internal and external guidance, 

analyzed internal documentation of the agency’s participation in EP 

exercises, and interviewed agency officials responsible for external 

outreach. In addition, auditors created a questionnaire and 

distributed it by e-mail to 43 State emergency management 

officials. These officials were identified as cognizant points of 

contact by NRC Regional State Liaison Officers. OIG received 

responses directly from, or on behalf of, 30 State officials from all 

four NRC regions.8

 As appropriate, OIG contacted respondents by 

telephone to clarify remarks submitted in the questionnaire’s 

narrative sections. 

This work was conducted from September 2006 through March 

2007, in accordance with generally accepted Government auditing 

standards and included a review of management controls related to 

audit objectives. The work was conducted by Beth Serepca, Team 

Leader; Shyrl Coker, Audit Manager; Vicki Foster, Senior 

Management Analyst; David Ditto, Senior Management Analyst; 

and Paul Rades, Senior Management Analyst. 

 

8

 Four respondents indicated that they had not participated in an EP exercise with NRC. 
Audit of NRC’s Emergency Preparedness Program 

14

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Audit of NRC’s Emergency Preparedness Program 

15

Appendix B 

SELECTED REGIONAL STATE LIAISON OFFICER (RSLO) FUNCTIONS9 

RSLO Function/Responsibility Similarities Between the Four 

Regions

Differences Between the Four Regions

Frequent contacts with States to 

provide information 

Role consistent in all four regions Wide variation in involvement/interest by the 

States; thus, the time demands of this effort vary 

considerably. Some Regions have more than 

one RSLO to perform activities. 

Responds to requests from staff and 

management regarding State issues 

and political inquiries; supports 

meetings before government officials

Role consistent in all four regions Level of effort varies considerably, with the most 

significant demands in Region I, followed by 

Region III 

Serves as the Government Liaison 

Manager during exercises and 

emergencies 

Role consistent in all four regions Region I RSLO also is Protective Measures and 

emergency response coordinator qualified; the 

Region IV RSLO has additional duties. 

Attends regularly scheduled meetings in 

specific states - typically requested by 

the State 

No similarities Region I supports two separate, regularly 

scheduled quarterly emergency management 

meetings plus two annual meetings on nuclear 

plant status and issues and quarterly State 

emergency management meetings 

Region II does not have such regularly 

scheduled meetings 

Region III supports one regularly scheduled 

quarterly meeting and one annual meeting 

Region IV supports one regularly scheduled 

quarterly meeting as well as one annual meeting 

Participates as a FEMA evaluator for 

biennial exercises and reviews final 

FEMA exercise reports. 

Some similarities Region I covers three FEMA- Regions; RSLO 

covers 2-3 biennial exercises and serves as 

FEMA evaluator when needed. 

Region II covers two FEMA - Regions 

Region III covers two FEMA - Regions; RSLO 

covers 3-4 exercises per year 

Region IV covers five FEMA - Regions; RSLO 

covers 3-4 exercises per year. 

Supports the coordinated scheduling of 

emergency exercises 

Some similarities The Region I RSLO has a central role in 

planning this activity. 

Regions II, III, and IV, FEMA has assumed the 

lead for this activity and the RSLO has only a 

supporting role 

Region IV RSLO coordinates this activity for its 

licensees, but RSLO remains in a support role. 

 

9 Adapted from NRC memorandum dated October 13, 2006, Regional State Liaison Officer 

Benchmarking/Best Practices Initiative.