GAO 

United States Government Accountability Office

Report to Congressional Committees

COMBATING 

NUCLEAR 

TERRORISM 

Actions Needed to 

Better Prepare to 

Recover from Possible 

Attacks Using 

Radiological or 

Nuclear Materials 

January 2010 

GAO-10-204 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

January 2010

COMBATING NUCLEAR TERRORISM

Actions Needed to Better Prepare to Recover from 

Possible Attacks Using Radiological or Nuclear 

Highlights of GAO-10-204, a report to Materials

congressional committees 

A terrorist’s use of a radiological 

dispersal device (RDD) or 

improvised nuclear device (IND) to 

release radioactive materials into 

the environment could have 

devastating consequences. GAO 

was asked to examine (1) the 

extent to which the federal 

government is planning to fulfill its 

responsibilities to help cities and 

their states clean up contaminated 

areas from RDD and IND incidents, 

(2) what is known about the federal 

government’s capability to 

effectively clean up these 

contaminated areas, and (3) 

suggestions for improving federal 

preparedness to help cities and 

states recover from these incidents. 

The report also discusses recovery 

activities in the United Kingdom. 

GAO reviewed federal laws and 

guidance; interviewed officials 

from the Department of Homeland 

Security (DHS), Federal 

Emergency Management Agency 

(FEMA), Department of Energy 

(DOE), and Environmental 

Protection Agency (EPA); and 

surveyed emergency management 

officials from 13 cities at high risk 

of attack, their 10 states, and FEMA 

and EPA regional offices. 

What GAO Recommends

GAO recommends that, among 

other things, FEMA prepare a 

national recovery strategy that 

clarifies federal roles for cleaning 

up areas contaminated by attacks 

using RDDs or INDs, and schedule 

additional exercises to assess 

recovery preparedness. DHS and 

DOE agreed with our 

recommendations, and EPA did not 

agree or disagree with them. 

FEMA, the DHS agency responsible for developing a comprehensive 

emergency management system, has not developed a national disaster 

recovery strategy, as required by law, or issued specific guidance to 

coordinate federal, state, and local government recovery planning for RDD 

and IND incidents, as directed by executive guidance. To date, most federal 

attention has been given to developing a response framework, with less 

attention to recovery. Responding to an attack would involve evacuations and 

providing treatment to those injured; recovering from an attack would include 

cleaning up the radioactive contamination to permit people to return to their 

homes and businesses. Existing federal guidance provides limited direction 

for federal, state, and local agencies to develop recovery plans and to conduct 

exercises to test recovery preparedness. Of the over 90 RDD and IND 

exercises to test response capabilities in the last 6 years, only 3 included a 

recovery component. GAO’s survey found that almost all 13 cities and most 

states believe they would need to rely heavily on the federal government to 

conduct and fund analysis and environmental cleanup activities. However, 

city and state officials were inconsistent in views on which federal agencies to 

turn to for help, which could hamper the recovery effort. 

Although DOE and EPA have experience cleaning up localized radiationcontaminated areas, it is unclear whether this federal capability is sufficient to 

effectively direct the clean up after RDD or IND incidents, and to efficiently 

address the magnitude of cleanup that would follow these incidents. 

According to an expert at DOE’s Idaho National Laboratory, experience has 

shown that not selecting the appropriate decontamination technology can 

generate waste types that are more difficult to remove than the original 

material and can create more debris requiring disposal—leading to increased 

costs. Limitations in laboratory capacity to rapidly test potentially millions of 

material samples during cleanup, and uncertainty regarding where to dispose 

of radioactive debris could also slow the recovery process. At least two-thirds 

of the city, state, and federal respondents expressed concern about federal 

capability to provide the necessary cleanup actions after these incidents. 

Nearly all survey respondents had suggestions to improve federal recovery 

preparedness for RDD and IND incidents. For example, almost all the cities 

and states identified the need for a national disaster recovery strategy to 

address gaps and overlaps in federal guidance. All but three cities wanted 

additional guidance, for example, on monitoring radioactivity levels, cleanup 

standards, and management of radioactive waste. Most cities wanted more 

interaction with federal agencies and joint exercising to test recovery 

preparedness. Finally, GAO’s review of the United Kingdom’s preparedness to 

recover from radiological terrorism showed that it has already taken actions 

similar to those suggested by GAO’s survey respondents, such as issuing 

national recovery guidance, conducting a full-scale recovery exercise, and 

publishing national recovery handbooks for radiation incidents. View GAO-10-204 or key components.

For more information, contact Gene Aloise at 

(202) 512-3841 or aloisee@gao.gov. 
Page i GAO-10-204 

Contents 

Letter 1

Background 5 

The Federal Government Has Not Completed Planning to Help 

Cities and States Clean up Areas Contaminated with Radioactive 

Materials from RDD or IND Incidents 7 

Uncertainty about Federal Capability to Effectively Clean up Areas 

Contaminated with Radioactive Materials from an RDD or IND 

Incident 14 

City, State, and Federal Emergency Management Officials Provided 

Suggestions to Improve Federal Recovery Preparedness for RDD 

and IND Incidents 20 

The United Kingdom’s Handling of the 2006 Polonium Incident and 

Subsequent Actions Provide Information That May Help U.S. 

Federal Agencies Prepare for RDD and IND Incidents 22 

Conclusions 25 

Recommendations for Executive Action 25 

Agency Comments and Our Evaluation 26 

Appendix I Scope and Methodology 28 

Appendix II Recovery Exercises 32 

Appendix III Radiological Recovery Experiences in the United 

Kingdom 34 

Appendix IV GAO Contact and Staff Acknowledgments 47

Table 

Table 1: RDD Exercises Containing Recovery Objectives, May 2003 

to April 2010 32 

 Combating Nuclear Terrorism 
Figure 

Figure 1: Example of a Datasheet on High Pressure Hosing for 

Cleaning Contaminated Surfaces in the UK Recovery 

Handbooks for Radiation Incidents: 2009 41 

Abbreviations 

CERCLA Comprehensive Environmental Response, Compensation, 

 and Liability Act 

DHS Department of Homeland Security 

DOD Department of Defense 

DOE Department of Energy 

EPA Environmental Protection Agency 

FEMA Federal Emergency Management Agency 

FRMAC Federal Radiological Monitoring and Assessment Center 

IMAAC Interagency Modeling and Atmospheric Assessment Center 

IND improvised nuclear device 

NNSA National Nuclear Security Administration 

NRC Nuclear Regulatory Commission 

RDD radiological dispersal device 

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Page ii GAO-10-204 Combating Nuclear Terrorism
Page 1 GAO-10-204 

United States Government Accountability Office

Washington, DC 20548 

 

January 29, 2010 

The Honorable Bennie G. Thompson 

Chairman 

The Honorable Peter T. King 

Ranking Member 

Committee on Homeland Security 

House of Representatives 

The Honorable Yvette D. Clarke 

Chairwoman 

The Honorable Daniel E. Lungren 

Ranking Member 

Subcommittee on Emerging Threats, Cybersecurity, 

 and Science and Technology 

Committee on Homeland Security 

House of Representatives 

The Honorable Michael T. McCaul 

Ranking Member 

Subcommittee on Intelligence, Information Sharing, and 

 Terrorism Risk Assessment 

Committee on Homeland Security 

House of Representatives

A terrorist’s use of either a radiological dispersal device (RDD)—

frequently referred to as a dirty bomb—or an improvised nuclear device 

(IND) to release radioactive materials into the environment could have 

devastating consequences. However, quickly analyzing and cleaning up 

contaminated areas from such an incident, particularly from an RDD 

attack, could speed up the recovery and allow restoration of normal 

operations of critical infrastructure, services, businesses, and public 

activities, thus reducing the many adverse consequences from an attack of 

this kind. Responding to such an attack would involve evacuations, 

providing medical treatment to those who were injured, and protecting 

property; recovery would include cleaning up areas contaminated with 

radioactive materials in order to permit people to return to their homes 

and businesses. According to a 2008 report of the National Science and 

Technology Council, which coordinates science and technology policy 

within the Executive Office of the President, the ability of government to 

quickly and decisively respond to and recover from an RDD or IND 

 Combating Nuclear Terrorism 
 

incident is key to national resiliency.1 Importantly, the council noted that 

being prepared to recover from these incidents may even provide an 

element of deterrence if the adversary perceives less potential for longlasting harm. 

The consequences of a terrorist attack using an RDD or IND would include 

not only loss of life, but also enormous psychological and economic 

impacts. An RDD would disperse radioactive materials into the 

environment through a conventional explosive or through other means. 

Depending on the type of RDD, the area contaminated could be as small as 

part of a building or a city block or as large as several square miles. 

Hundreds of individuals might be killed or injured from the RDD explosion 

or face the risk of later developing cancer due to exposure to radiation and 

radioactive contamination. An IND is a crude nuclear bomb made with 

highly enriched uranium or plutonium. It would create an explosion 

producing extreme heat, powerful shockwaves, and intense radiation that 

would be immediately lethal to individuals within miles of the explosion, 

as well as radioactive fallout over thousands of square miles. 

Nonproliferation experts estimate that a successful IND could produce the 

same force as the equivalent of the yield of the bomb that destroyed 

Nagasaki, Japan in 1945; it could devastate the heart of a medium-sized 

U.S. city. The explosion could cause hundreds of thousands of deaths and 

injuries, as well as pose long-term cancer risks to those exposed to the 

radioactive fallout. An RDD is thought to be a more likely terrorist weapon 

than an IND given the prevalent commercial use of radioactive source 

material—for example, in some medical and industrial equipment—and 

the relatively easy way in which this material could be dispersed through 

conventional explosives, like dynamite, or other means. 

If an RDD or IND incident occurred, as part of the recovery process, a 

number of federal, state, and local government departments and agencies 

would be involved in the analysis and environmental cleanup of areas 

contaminated with radioactive materials. Generally, state and local 

governments have primary responsibility for recovering from disasters, 

but the federal government may provide assistance when an incident 

exceeds state and local government resources or when an incident is 

managed by federal agencies under their own authorities or occurs within 

federal jurisdiction (e.g., on a military base or a federal facility or lands). 

 

1

National Science and Technology Council, Roadmap for Nuclear Defense Research and 

Development: Fiscal Years 2010-2014 (Washington, D.C., July 2008). 

Page 2 GAO-10-204 Combating Nuclear Terrorism
 

The Department of Homeland Security (DHS) is the principal federal 

agency responsible for domestic incident management. The primary 

mission of its Federal Emergency Management Agency (FEMA) is to 

develop a comprehensive emergency management system of 

preparedness, protection, response, recovery, and mitigation. For an RDD 

or IND incident, DHS would be the lead agency in coordinating federal 

assistance to state and local governments. For these incidents, DHS would 

have responsibility for coordinating the federal response, with the support 

of other federal agencies, to assist state and local governments in the 

analysis and environmental cleanup of areas contaminated with 

radioactive materials. For example, in certain circumstances, the 

Department of Energy (DOE) would have primary responsibility for 

coordinating the analysis or characterization of areas contaminated with 

radioactive materials through its leadership of the interagency Federal 

Radiological Monitoring and Assessment Center (FRMAC).2

 The 

Environmental Protection Agency (EPA) would take over leadership of 

FRMAC for coordinating the long-term monitoring of radiological 

contamination and supporting the detailed assessment of property 

contamination in the affected areas to support the cleanup of these areas. 

The Department of Defense (DOD), along with other agencies, would act 

in support of FRMAC. Federal agencies, including EPA, DOE, and the 

Nuclear Regulatory Commission (NRC), as well as state regulatory 

agencies have set various cleanup standards for areas contaminated with 

radioactive materials, but not specifically for RDD or IND incidents. The 

national laboratories have also provided research support assessing 

methods and technologies for analysis and environmental cleanup 

activities. 

The risk of terrorists using an RDD or IND is, in large part, determined by 

their ability to gain access to the materials needed to construct these 

devices. Over the past few years, we have issued a number of reports on 

the security of nuclear and radiological materials and facilities that house 

them. Overall, our work has shown that despite investing billions of 

dollars in new technology to upgrade security procedures, gaps continue 

to exist in our nation’s ability to prevent terrorists from accessing or 

smuggling dangerous quantities of radioactive material into the country. 

For example, in 2007, we testified before Congress that our own 

 

2

FRMAC is responsible for coordinating all environmental radiological monitoring, 

sampling, and assessment activities for the federal response to a radiological release into 

the environment. 

Page 3 GAO-10-204 Combating Nuclear Terrorism
 

investigators were able to set up phony businesses and obtain a legitimate 

NRC license that would have permitted them to obtain dangerous 

quantities of radioactive material.3

 Our investigators were able to obtain 

this NRC license just months after NRC had completed a lengthy process 

to strengthen its licensing procedures. In 2008, we reported that NRC, in 

developing its security requirements for research reactors, had not fully 

considered the risks associated with terrorists attacking these facilities—

many of which are located on college campuses.4

 Such an attack could 

involve terrorists sabotaging a reactor in order to disperse radioactive 

material over neighboring communities—similar to an RDD. We have also 

reported on DHS’s and FEMA’s preparedness for, response to, and 

recovery from disasters in 2007, 2008, and 2009.5

We were asked to review the federal government’s preparedness to help 

cities and states recover from possible attacks using an RDD or IND. 

Accordingly, this report addresses the following: (1) the extent to which 

federal agencies are planning to fulfill their responsibilities to help cities 

and states clean up areas contaminated with radioactive materials from 

RDD and IND incidents, (2) what is known about the federal government’s 

capability to effectively clean up areas contaminated with radioactive 

materials from RDD and IND incidents, and (3) suggestions from 

government emergency management officials for improving federal 

preparedness to help cities and states recover from RDD and IND 

incidents. In addition, we are providing information on actions taken in the 

United Kingdom to prepare for recovering from RDD and IND incidents. 

 

3

GAO, Nuclear Security: Actions Taken by NRC to Strengthen Its Licensing Process for 

Sealed Radioactive Sources Are Not Effective,GAO-07-1038T (Washington, D.C.: July 12, 

2007). 

4

GAO, Nuclear Security: Action May Be Needed to Reassess the Security of NRC-Licensed 

Research Reactors, GAO-08-403 (Washington, D.C.: Jan. 31, 2008). 

5

GAO, Observations on DHS and FEMA Efforts to Prepare for and Respond to Major and 

Catastrophic Disasters and Address Related Recommendations and Legislation, 

GAO-07-1143T (Washington, D.C.: July 31, 2007); Actions Taken to Implement the PostKatrina Emergency Management Reform Act of 2006, GAO-09-59R (Washington, D.C.: Nov. 

21, 2008); and National Preparedness: FEMA Has Made Progress, but Needs to Complete 

and Integrate Planning, Exercise, and Assessment Efforts, GAO-09-369 (Washington, D.C.: 

Apr. 30, 2009). 

Page 4 GAO-10-204 Combating Nuclear Terrorism
 

This report follows preliminary observations that we provided in 

testimony at a September 14, 2009, congressional hearing.6

To address these objectives, we examined pertinent federal law, 

presidential directives, and other executive guidance; interviewed 

cognizant officials from DHS, DOE, EPA, FEMA, NRC, and from both DOE 

and EPA national laboratories; and conducted a survey of emergency 

management officials in 13 cities considered to be at high or medium risk 

for an RDD or IND incident, officials in these cities’ states, and federal 

emergency management officials in FEMA and EPA regional offices.7

 We 

also reviewed information on the number and type of RDD and IND 

response and recovery exercises that have been conducted in the last 6 

years. Finally, we visited the United Kingdom to review its preparedness to 

recover from RDD and IND incidents at the suggestion of EPA officials 

and because it has addressed a fairly recent radiological release incident in 

a large urban area. Appendix I provides more detail on our scope and 

methodology. 

We conducted this performance audit from October 2008 to January 2010 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. 

In the aftermath of the terrorist attacks on September 11, 2001, security 

experts have raised concerns that terrorists may try to smuggle 

radiological or nuclear materials into the United States to produce either 

an RDD or IND. These experts have also raised concerns that terrorists 

could obtain radioactive materials used in medicine, research, agriculture, 

and industry to construct an RDD, or dirty bomb. This radioactive material 

Background 

 

6

GAO, Combating Nuclear Terrorism: Preliminary Observations on Preparedness to 

Recover from Possible Attacks Using Radiological or Nuclear Materials, GAO-09-996T

(Washington, D.C.: Sept. 14, 2009). 

7

The high- and medium-risk cities are Boston, Chicago, Dallas, Denver, Detroit, Houston, 

Los Angeles, Miami, New York, Philadelphia, San Francisco, Seattle, and St. Louis. While 

Washington, D.C., is considered a high-risk city, we excluded it from our survey because it 

is unlike other cities in its reliance on the federal government and the federal agencies that 

would take over analysis and environmental cleanup activities. 

Page 5 GAO-10-204 Combating Nuclear Terrorism
 

is encapsulated, or sealed, in metal, such as stainless steel, titanium, or 

platinum, to prevent its dispersal and is commonly called a sealed 

radiological source. Sealed sources are used throughout the United States 

and other countries in equipment designed to, among other things, 

diagnose and treat illnesses, preserve food, detect flaws in pipeline welds, 

and determine the moisture content of soil. Depending on their use, sealed 

sources contain different types of radioactive material, such as strontium90, cobalt-60, cesium-137, plutonium-238, and plutonium-239. While no 

terrorists have detonated a dirty bomb in a city, Chechen separatists 

placed a canister containing cesium-137 in a Moscow park in the mid1990s. Although the device was not detonated and no radioactive material 

was dispersed, the incident demonstrated that terrorists have the 

capability and willingness to use radiological materials as weapons of 

terrorism. In contrast, detonating an IND would require a terrorist group 

to obtain nuclear weapons material—which is generally heavily secured—

and to have highly sophisticated expertise and equipment to fabricate this 

material into a weapon. 

Another form of nuclear terrorism occurred with the dispersal of 

radioactive materials through a sequence of events in London during 

November and December 2006. On November 23, 2006, Alexander 

Litvinenko, a former officer of the Russian Federal Security Service, was 

poisoned with a milligram of polonium-210—about the size of a grain of 

salt.8

 The dispersal of the polonium by the perpetrators of the crime and 

the victim resulted in widespread contamination across London and even 

abroad. His poisoning was detected only after he was hospitalized for a 

few weeks and tested for symptoms of radiation exposure because of hair 

loss. Following the poisoning, forensic investigators examined 47 sites 

across London for traces of polonium, both resulting from the handling of 

the polonium by his perpetrators and maybe other attempts to poison him. 

Of these locations, about 12 showed signs of this radioactive material, 

including a restaurant, hotel room, soccer stadium, and an eastbound 

British Airways plane. British investigators also identified over 1,000 

people who might have been in various ways exposed to the polonium. 

Health officials tested 738 of them and found that 137 had reportable levels 

of this substance, although few of these individuals turned out to have 

levels that warranted medical attention. The decontamination activities at 

these sites spanned 19 days, involved a number of methods and 

 

8

British investigators believe that this pure polonium was probably produced in a Russian 

research reactor. 

Page 6 GAO-10-204 Combating Nuclear Terrorism
 

technologies, and cost more than $200,000. However, the estimated total 

cost of managing this incident, including law enforcement investigation, 

testing individuals, sampling materials, and cleanup, was $4 million.9

FEMA has not completed planning to help cities and states recover from 

RDD or IND incidents as evidenced by not (1) developing a national 

disaster recovery strategy as required by law and (2) issuing specific 

guidance to coordinate federal, state, and city planning to recover from 

RDD or IND incidents. Moreover, federal agencies have conducted few 

exercises to test recovery plans for these incidents. 

The Federal 

Government Has Not 

Completed Planning 

to Help Cities and 

States Clean up Areas 

Contaminated with 

Radioactive Materials 

from RDD or IND 

Incidents 

FEMA Has Not Developed 

a National Disaster 

Recovery Strategy to Help 

Guide RDD or IND 

Recovery Planning 

FEMA has not developed a national disaster recovery strategy, as required 

by law and directed by executive guidance, or issued specific guidance to 

coordinate federal, state, and local government recovery planning for RDD 

or IND incidents. The Post-Katrina Emergency Management Reform Act of 

2006 requires FEMA to develop, coordinate, and maintain a national 

disaster recovery strategy.10 Among other things, the strategy is to clearly 

define the roles, programs, authorities, and responsibilities of each agency 

that may provide assistance to the recovery from a major disaster. In 

addition, the National Strategy for Homeland Security also called on the 

federal government to prepare a recovery strategy.11 The federal 

government has placed a higher priority on developing a strategy to 

respond to domestic incidents, including RDD and IND incidents, than it 

has on developing a comparable strategy for recovering from these 

 

9

A.C. Perkins, “The London Polonium Poisoning: Events and Medical Implications,” World 

Journal of Nuclear Medicine, Vol. 6, No. 2, (April 2007) 102-106. 

10The Post-Katrina Emergency Management Reform Act, Pub. L. No. 109–295, § 682, 120 

Stat. 1355, 1445-46 (2006). The act also requires FEMA to submit a report to Congress 

within 270 days of enactment describing the strategy in detail. 

11Homeland Security Council, National Strategy for Homeland Security (Washington, D.C., 

October 2007). 

Page 7 GAO-10-204 Combating Nuclear Terrorism
 

incidents. For example, the response strategy, captured in the 2008 

National Response Framework, does not include guidance on long-term 

recovery activities.12 The FEMA coordinator for the development of a 

national disaster recovery strategy told us that while the previous 

administration had drafted a “white paper” addressing this strategy, the 

new administration has decided to rethink the entire approach.13 The 

FEMA coordinator also told us that FEMA recognizes its responsibility to 

prepare a national disaster recovery strategy but could not provide a time 

frame for its completion. This same official did say that in developing this 

strategy, FEMA plans to seek out opinions of nonfederal stakeholders. 

Once completed, the official said that the recovery strategy would provide 

guidance to federal, state, and local agencies in revising their operational 

plans for recovery activities, including recovery from RDD and IND 

incidents. 

Currently, the limited federal planning guidance related to the recovery 

from RDD and IND incidents can be found in a number of documents. 

There are several annexes to the National Response Framework that 

address, in part, federal agency responsibilities and assets to help state 

and local governments recover from these incidents. For example, a 

December 2004 emergency support function annex covering long-term 

community recovery and mitigation, led by FEMA, provides a framework 

for federal support to localities to enable community recovery from the 

long-term consequences of events of national significance. While this 

annex addresses FEMA’s responsibilities to coordinate the transition from 

response to recovery in field operations, it does not provide details on 

recovery planning for RDD and IND incidents. The January 2003 

emergency support annex covering hazardous materials, led by EPA, 

provides the framework for federal support in response to an actual or 

potential discharge and release of hazardous materials following a major 

disaster or emergency. EPA officials informed us that this annex will give 

them a significant federal role in leading cleanup efforts after RDD or IND 

incidents, in coordination with affected state and local governments. The 

June 2008 nuclear and radiological incident annex describes federal 

 

12In January 2008, DHS issued the National Response Framework, as an update of the 2004 

and the 2006 National Response Plan. The framework provides a guide for how the nation 

should conduct all-hazard response, including the roles and responsibilities of federal 

agencies involved in response efforts. 

13In our November 21, 2008 report (GAO-09-59R), we found that FEMA had drafted a 

national disaster recovery strategy but that it was under review at the time with no 

timeframe for completion. 

Page 8 GAO-10-204 Combating Nuclear Terrorism
 

responsibilities and provides some operational guidance for pertinent 

response activities and, to a lesser extent, recovery activities in support of 

state and local governments. DHS is identified as the technical lead for 

recovery activities, but may request support from other federal agencies—

for example, EPA and the United States Army Corps of Engineers—that 

have cleanup and recovery experience and capabilities. According to this 

annex, the federal government, upon request of state and local 

governments, can assist in developing and executing recovery plans, but 

such plans would not generally be developed until after the incident 

occurs. 

The lack of a national disaster recovery strategy that would include RDD 

and IND incidents is problematic because, according to survey 

respondents, most localities would count on the federal government being 

prepared to carry out analysis and environmental cleanup activities 

following these incidents. Specifically, emergency management officials 

from almost all 13 cities and most of their 10 states indicated in our survey 

that they believe they would need to rely heavily on the federal 

government to conduct and fund all or almost all analysis and 

environmental cleanup activities associated with recovering from an RDD 

or IND incidents of the magnitude described in the national planning 

scenarios. They indicated that their technical and financial resources 

would be overwhelmed by a large RDD incident—and certainly by an IND 

incident. Most of these officials reported that they believe they could 

adequately address a smaller RDD incident, such as one that is confined to 

a city block or inside a building. Despite this anticipated reliance on the 

federal government, we obtained mixed responses as to whether these 

RDD and IND recovery activities should be primarily a federal 

responsibility. Almost half of the respondents from the cities (6 of 13), but 

most of those from states (8 of 10), indicated that these activities should 

be primarily a federal responsibility. The others stressed the need for 

shared responsibilities with the federal government. However, when 

respondents were asked in our survey to identify which federal agencies 

they would turn to for help in the analysis and environmental cleanup of 

areas contaminated with radioactive materials from RDD or IND incidents, 

they provided inconsistent responses and frequently listed several federal 

agencies for the same activity. These responses seem to indicate that there 

might be some confusion among city and state emergency management 

officials regarding federal agency responsibilities to provide assistance to 

them under these circumstances. In our view, this confusion, if not 

addressed, could hamper the timely recovery from these incidents and 

demonstrates the need for development and implementation of a national 

disaster recovery strategy. In commenting on the draft report, EPA 

Page 9 GAO-10-204 Combating Nuclear Terrorism
 

indicated that as no single federal department or agency has the sole 

requisite technical capacity and capabilities to respond to the scope of 

RDD or IND incidents, it is expected that numerous federal agencies 

would need to work together in a single mission, such as through FRMAC. 

Nevertheless, EPA stated that our survey results underscore the 

importance having clear communication and notification among federal 

agencies, which if not addressed, could hamper recovery efforts. 

FEMA Has Not Issued 

Specific Guidance to 

Coordinate Federal, State, 

and City Planning to 

Recover from an RDD or 

IND Incidents 

FEMA has not issued specific guidance describing how federal capabilities 

would be integrated into and support state and local plans for recovery 

from RDD or IND incidents,14 as called for by presidential directive.15

According to a senior FEMA official, the agency has delayed issuing this 

guidance pending the reevaluation of its planning approach by the new 

administration. However, a senior FEMA planning official told us that 

because FEMA is already aware that its planning system does not fully 

recognize the involvement of state and local governments, the agency is 

developing regional support plans—including for RDD and IND 

incidents—through its regional offices, which will reflect state and local 

government roles and responsibilities. Moreover, according to FEMA 

officials, in August 2008, DHS issued stop-gap guidance outside of FEMA’s 

planning guidance framework to provide some immediate direction to 

federal, state, and local emergency response officials in developing their 

own operational plans and response protocols for protection of emergency 

workers after RDD or IND incidents.16 In regard to recovery, EPA officials 

informed us that FEMA and other federal agencies worked together on 

this guidance in an attempt to clarify the processes for providing federal 

cleanup assistance following such an incident. These officials informed us 

that DHS’s guidance was intended to cover the existing operational 

 

14The planning for RDD and IND incidents is based on a national planning scenario for each 

incident. Scenario 11 represents a radiological attack using an RDD spreading 

contamination over 36 city blocks, causing hundreds of fatalities, costing billions of dollars 

in economic impacts, and taking months to years for recovery. Scenario 1 represents a 

nuclear detonation using a 10-kiloton IND spreading contamination over approximately 

3,000 square miles, causing hundreds of thousands deaths, hundreds of billions of dollars in 

economic impacts, and taking years for recovery. 

15Homeland Security Presidential Directive 8, Annex 1 (December 2007), titled National 

Planning, is intended to further enhance the preparedness of the United States by formally 

establishing, developing, and maintaining a standard and comprehensive approach to 

national planning. 

16DHS, Planning Guidance for Protection and Recovery Following Radiological Dispersal 

Device (RDD) and Improvised Nuclear Device (IND) Incidents, 73 Fed. Reg. 45,029 (Aug. 1, 

2008). 

Page 10 GAO-10-204 Combating Nuclear Terrorism
 

guidelines for implementing the protective action guides and other 

response actions, and to encourage their use in developing specific 

response protocols. In responding to a draft of this report, EPA informed 

us that DOE had convened an interagency workgroup to address gaps in 

DHS’s guidance and had issued a preliminary report, for comment by 

September 30, 2009, containing additional operational guidelines to 

respond to an RDD incident.17 Moreover, these officials indicated that EPA 

has also worked with other federal agencies to examine its own 1992 

protective action guides to address shortcomings and to incorporate more 

recent guidance.18 However, according to EPA officials, much work 

remains to convert the new guidance into operational guidance. In 

addition, DOD has established operational plans for consequence 

management following terrorist incidents, including RDD and IND 

attacks.19 

Without federal guidance for coordinating federal, state, and local 

planning for recovery from RDD or IND incidents, cities and states lack a 

framework for developing their own recovery strategies. Emergency 

management officials representing all 13 cities and their states in our 

survey indicated that while their jurisdictions had prepared emergency 

response and recovery plans for domestic incidents, few of these plans 

specifically addressed RDD and IND recovery activities, particularly for 

the analysis and environmental cleanup of areas contaminated with 

radioactive materials. For example, few city respondents (3 of 13) 

indicated that their recovery plans included preparations for an RDD 

incident, although respondents from two cities indicated that their cities 

were drafting these plans. In regard to IND preparation, all city 

respondents informed us that recovery planning was still important 

despite the magnitude of such events, but none of them had prepared such 

plans. Respondents from all states in our survey indicated that they had 

prepared emergency response plans for domestic incidents, and most of 

 

17C. Yu et al., Preliminary Report on Operational Guidelines Developed for Use in 

Emergency Preparedness and Response to a Radiological Dispersal Device Incident, 

DOE/HS-0001, prepared for DOE, Office of Health Safety, and Security, February 2009. 

18EPA, EPA Guidance on the Optimization Process Following a Radiological Dispersal 

Device or Improvised Nuclear Device Incident (Draft), and Revisions to the Protective 

Action Guides Manual for Radiological Incidents (Draft). 

19We provided testimony on this DOD initiative in GAO, Homeland Defense: Preliminary 

Observations on Defense Chemical, Biological, Radiological, Nuclear, and High-Explosive 

Consequence Management Plans and Preparedness, GAO-09-927T (Washington, D.C.: July 

28, 2009). 

Page 11 GAO-10-204 Combating Nuclear Terrorism
 

them (8 of 10) indicated that these plans included a recovery component. 

However, we were told that few of these recovery plans address an RDD 

incident, or specific analysis and environmental cleanup activities 

following such an incident, although respondents from 8 states mentioned 

that they planned to prepare such plans. The lack of recovery planning for 

RDD and IND incidents may be due, in part, to the relatively low priority 

given to preparing for them by city and state emergency management 

officials that we surveyed when compared with other types of risks facing 

their jurisdictions. For example, the majority of city respondents indicated 

that natural disasters, such as severe weather and infrastructure failure, 

were the most significant risks facing their jurisdictions. 

Federal Agencies Have 

Conducted Few Exercises 

to Test Recovery Plans for 

RDD or IND Incidents 

Federal agencies and local jurisdictions have used existing federal 

guidance as a basis for planning RDD and IND response exercises and, to a 

much lesser extent, recovery exercises to test the adequacy of their plans 

and level of preparedness. According to DHS guidance, preparedness is 

the foundation of a successful national incident management system 

involving all levels of government and other nongovernmental 

organizations as necessary.20 The cycle of preparedness for prevention, 

protection, response, and recovery missions ends with adequate 

exercising, evaluation, and improvement. Our search of FEMA’s National 

Exercise Schedule—a scheduling system for federal, state, and local 

exercises—revealed 94 RDD or IND response exercises planned and 

carried out by these authorities from May 2003 through September 2009. 

These exercises were identified as either full-scale, tabletop, workshop, 

seminar, functional, or a drill, and some locations have conducted several 

of them over a period of time. While many of these exercises listed both 

response and recovery objectives, as well as other exercise objectives, 

officials with FEMA’s National Exercise Division told us that only three of 

them actually included a recovery component that exercised activities 

associated with environmental cleanup. However, our survey of city, state, 

and federal regional office emergency management officials found that 

many response and a few recovery exercises were conducted over the last 

6 years that do not appear in FEMA’s National Exercise Schedule. We 

previously reported that information in the National Exercise Schedule 

database was unreliable.21 Nevertheless, for the purpose of this report, it is 

clear that very few RDD and IND response exercises have included a 

 

20DHS, National Preparedness Guidelines (Washington, D.C., September 2007). 

21GAO-09-369. 

Page 12 GAO-10-204 Combating Nuclear Terrorism
 

recovery component. According to National Exercise Division officials, a 

recovery discussion following an RDD or IND response exercise has 

typically not occurred because of the time needed to fully address the 

response objectives of the exercise, which are seen as a higher priority. 

While two response exercises in 2003 and 2007 included brief follow on 

recovery discussions, a more recent exercise set aside more time for this 

discussion. The most recent RDD response exercise, based in Albany, New 

York, set aside 2 days (June 16-17, 2009) for federal, state, and local 

agencies to discuss operational recovery issues. One unresolved 

operational recovery issue discussed during this exercise pertained to the 

transition of the leadership of FRMAC from the initial analysis of the 

contaminated area, led by DOE, to the later cleanup phase, led by EPA. 

For example, there are unresolved operational issues regarding the level 

and quality of the monitoring data necessary for EPA to accept the 

leadership of FRMAC from DOE. According to EPA officials, while this 

transitional issue has been discussed in exercises dating back to the 

development of the Federal Radiological Emergency Response Plan in 

1984, it has only recently been discussed in RDD or IND response 

exercises. Another unresolved operational recovery issue discussed during 

this exercise pertained to the distribution of responsibilities for the 

ownership, removal, and disposal of radioactive debris from RDD or IND 

incidents. According to EPA exercise planning documents, both of these 

operational issues are to be addressed again in the first full-scale RDD 

recovery exercise—Liberty RadEx—set to take place April 26-30, 2010, in 

Philadelphia, Pennsylvania. According to an EPA coordinator for this 

event, this exercise is to focus on a few technical recovery issues involving 

intergovernmental coordination, such as setting environmental cleanup 

priorities and levels, as well as managing radioactive waste staging and 

disposal. Appendix II contains a brief summary of three national-level 

exercises, since May 2003, which contained a recovery component, along 

with the exercise objectives for the planned April 2010 RDD exercise, 

which is to contain a recovery component. In addition to this RDD 

recovery exercise, the National Exercise Schedule has listed two planned 

IND response exercises in 2010 that are to have some recovery 

components. 

Page 13 GAO-10-204 Combating Nuclear Terrorism
 

It is uncertain whether federal capability is sufficient to effectively clean 

up from RDD or IND incidents because federal agencies have only carried 

out environmental cleanup of localized areas of radioactive materials, and 

some limitations exist in federal capabilities to help address the magnitude 

of the cleanup that would follow these incidents. 

Uncertainty about 

Federal Capability to 

Effectively Clean up 

Areas Contaminated 

with Radioactive 

Materials from RDD 

or IND Incidents 

Effectiveness of 

Environmental Cleanup 

Methods and Technologies 

Following RDD or IND 

Incidents Are Untested on 

a Large Scale 

Some federal agencies, such as DOE and EPA, have substantial experience 

using various analysis and environmental cleanup methods and 

technologies to address localized areas contaminated with radioactive 

materials, but little is known about how these methods and technologies 

might be applied in recovering from the magnitude of RDD or IND 

incidents. For example, DOE has invested hundreds of millions of dollars 

in research, development, and testing of methods and technologies for 

cleaning up and decommissioning contaminated structures and soils—

legacies of the Cold War. In addition, since the passage of the 

Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA), which established the Superfund program,22 EPA has 

undertaken significant efforts to study, develop, and use technologies that 

can address radioactive contamination. DOD has also played a major role 

in studying potential applications for innovative technologies for its 

Superfund sites. 

As a result of federal agencies’ experience with radioactive materials, 

there is evidence that the agencies could effectively carry out the analysis 

and environmental cleanup of localized areas contaminated by these 

materials. In regard to analysis, DOE’s National Nuclear Security 

Administration (NNSA) has developed operational plans, orders, and 

publications on how to respond to a radiological or nuclear incident. 

NNSA has developed various FRMAC manuals to guide operational, 

assessment and monitoring activities. In addition, EPA’s National 

Decontamination Team has published guidelines that provide a framework 

 

22Comprehensive Environmental Response, Compensation, and Liability Act, 42 U.S.C. §§ 

9601-9675. CERCLA gives the federal government the authority to respond to releases or 

threatened releases of hazardous substances (including radionuclides) that may endanger 

public health or the environment. 

Page 14 GAO-10-204 Combating Nuclear Terrorism
 

for how to develop sampling plans to support decontamination efforts 

after a radiological release. In regard to environmental cleanup, EPA has 

published inventories of radiological methods and technology guidance for 

contaminated sites, surfaces, and media.23 The cleanup technologies are 

generally grouped into chemical and physical technologies. During the 

initial response phase to an incident, responders might rely on fairly 

simple cleanup approaches, such as washing down exposed people and 

surfaces, mowing grass, pruning trees, and sweeping up affected areas. 

The latter recovery phase might require no additional action or use of 

complex decontamination technologies depending on the level of desired 

cleanup. EPA has also published guidance for its On-Scene Coordinators 

at each regional office to aid in their response to a radiological incident.24

This guidance covers the full range of radiological incidents, but its focus 

is primarily on the early to intermediate phases of an RDD incident, as this 

incident is expected to present a challenge for these coordinators. This 

guidance addresses possible decontamination approaches for eight types 

of radionuclides that experts believe are most likely to be used in an RDD. 

As previously mentioned, federal agencies’ current approaches to analysis 

and environmental cleanup have only been applied in localized areas, as 

an RDD or IND incident has not occurred; however, decontamination 

research is currently under way to gain a better understanding of potential 

applications of current and experimental methods and technologies for 

primarily RDD incidents. According to decontamination experts at DOE’s 

Lawrence Livermore National Laboratory, current research has focused on 

predicting the effects of radiation release in urban settings through 

simulation, small-scale testing, and theory. In addition, researchers at 

EPA’s National Homeland Security Research Center informed us that 

while there are available methods that have proven successful for cleaning 

up various types of contamination, more research is needed to develop 

standard national guidance for their efficacious application in urban areas 

 

23EPA, Inventory of Radiological Methodologies for Sites Contaminated with Radioactive 

Materials, EPA-402-R-06-007 (Washington, D.C., October 2006); Technology Screening 

Guide for Radioactively Contaminated Sites, EPA-402-R-96-017 (Washington, D.C., 

November 1996); Technology Reference Guide for Radiologically Contaminated Surfaces, 

EPA-402-R-06-003 (Washington, D.C., March 2006); and Technology Reference Guide for 

Radioactively Contaminated Media, EPA-402-R-07-004 (Washington, D.C., October 2007). 

24EPA, OSC Radiological Response Guidelines (Washington, D.C., October 2006). The EPA 

On-Scene Coordinators direct and coordinate the agency’s response at the scene of an 

incident through the local incident command system in accordance with the National Oil 

and Hazardous Substances Pollution Contingency Plan and the National Response 

Framework. 

Page 15 GAO-10-204 Combating Nuclear Terrorism
 

and to other RDD or IND incident scenarios. According to a 

decontamination expert at DOE’s Idaho National Laboratory, experience 

has shown that without guidance and discussion early in the response 

phase, a contractor might use a decontamination technology during this 

phase for no other reason than it was used before in an unrelated 

situation. The expert told us that this situation might lead to selecting 

environmental cleanup technologies that generate waste types that are 

more difficult to remove than the original material and that create more 

debris requiring disposal—leading to increased costs. For example, the 

Lawrence Livermore National Laboratory decontamination experts told us 

that the conventional use of high-pressure hosing to decontaminate a 

building is effective under normal conditions but could be the wrong 

cleanup approach for an RDD using cesium-137. In this case, the imbibing 

(absorbing) properties of some porous surfaces such as concrete would 

actually cause this soluble radioactive isotope to penetrate even further 

into surfaces making subsequent decontamination more difficult and 

destructive.25 A senior EPA official with the Office of Radiation and Indoor 

Air told us that the agency has studies under way to determine the efficacy 

of high-pressure hosing for removing contamination from porous urban 

surfaces that would result from the terrorists’ use of an RDD using certain 

radioisotopes. 

Limitations in Federal 

Capabilities to Address 

Magnitude of Cleanup 

Following RDD or IND 

Incidents 

There are also limitations in federal capabilities to help address, in a 

timely manner, the magnitude of cleanup that would be associated with 

RDD or IND incidents. For example, we found that limitations in federal 

capabilities to complete some analysis and environmental cleanup 

activities might slow the recovery from an incident, including (1) 

characterizing the full extent of areas contaminated with radioactive 

materials, (2) completing laboratory validation of contaminated areas and 

levels of cleanup after applying decontamination approaches, and (3) 

removing and disposing of radioactive debris and waste. 

There are some limitations in the capability of federal agencies to 

efficiently characterize the full extent of the areas contaminated with 

radioactive materials in the event of RDD or IND incidents. For example, 

the current predictive capability of various plume models is not sufficient, 

Characterizing Areas 

Contaminated with Radioactive 

Materials 

 

25The experts also said that decontamination costs can dramatically increase depending on 

the selection of an initial approach and the length of time before remediation actions are 

taken. 

Page 16 GAO-10-204 Combating Nuclear Terrorism
 

and may never be sufficient to reduce the time necessary to fully 

characterize the extent of contaminated areas after RDD or IND 

incidents.26 According to a senior official at the Lawrence Livermore 

National Laboratory’s Interagency Modeling and Atmospheric Assessment 

Center (IMAAC), the predictive capabilities of existing plume models are 

not at the resolution necessary to produce this added value for urban 

areas, as modeling for this purpose is only theoretical at this point. This 

official told us while there are data about debris dispersal from building 

demolition and weapons testing, there is little research data on the likely 

dispersal patterns of concrete, asphalt, and glass that would result from 

use of an RDD or IND. However, some federal agency officials question 

the need to improve the predictive capabilities of these plume models. For 

example, the DHS IMAAC director told us that the current state-of-the-art 

and plume modeling approach is sufficient for its primary purpose in 

directing the protective actions of first responders. Nevertheless, NNSA 

officials informed us they are working with FEMA on a multiyear program 

to improve federal capabilities to model the release of material during a 

radiological or nuclear incident. However, they contend that plume 

modeling will never replace the need for actual measurements for 

radioactive contamination. In commenting on a draft of this report, EPA 

agreed that characterization of areas contaminated with radioactive 

materials from RDD or IND incidents would be challenging because 

existing plume models are not entirely applicable to urban areas. 

Moreover, EPA added that other types of contamination, such as in the 

drinking water and wastewater infrastructure, would also involve very 

complex systems that would be difficult to model. 

There are some limitations in federal capabilities to complete laboratory 

validation of contaminated areas and levels of cleanup after applying 

decontamination approaches. Moreover, FEMA’s proposed process for 

determining cleanup standards during the recovery phase for RDD and 

IND incidents has not been fully exercised, although there was a tabletop 

discussion among government officials in a June 2009 exercise. EPA has 

conducted an examination of federal, state, local, and private laboratory 

capabilities to conduct environmental sampling and testing in order to 

determine the nationwide laboratory capacity required to support 

environmental monitoring and decontamination of chemical, biological, 

Completing Laboratory 

Validation of Areas 

Contaminated with Radioactive 

Materials 

 

26Information from plume models—mathematical or computer equations—is intended to 

provide first responders with early estimates of potentially contaminated areas to help 

guide field sampling of sites, that data from which will in turn be used to update plume 

predictions in a cyclical process until the affected area has been accurately characterized. 

Page 17 GAO-10-204 Combating Nuclear Terrorism
 

and radiochemical-nuclear agents. EPA determined that there was a 

significant capacity and competency gap in efficiently meeting the 

laboratory evaluation needs for an RDD scenario. In addition, while EPA 

did not conduct a detailed assessment of the national planning scenario 

for an IND incident, it determined that such an incident could contaminate 

3,000 square miles and require potentially millions of samples for 

laboratory analysis. According to EPA documentation, the gap in 

laboratory capacity would result in the lack of timely, reliable, and 

interpretable data, which would delay national and local response and 

recovery activities. EPA has documented that it is currently establishing 

an all-media Environmental Response Laboratory Network, and it is also 

conducting a demonstration project to enhance the capacity and capability 

of public laboratories. 

A related environmental cleanup issue pertains to the process for 

determining the cleanup standards that would be applied to urban areas 

contaminated with radioactive materials in recovering from RDD or IND 

incidents. According to a decontamination expert at the Idaho National 

Laboratory, an important consideration in decontamination is the starting 

level of radioactivity and desired ending level. This official told us that no 

technology removes all of the contamination all the time; some 

technologies are more efficient than others at removing certain kinds of 

contamination. The current DHS planning guidance for RDD and IND 

incidents recommends a framework for incident cleanup and recovery 

using a process called “site-specific optimization” for determining the level 

of environmental cleanup after RDD or IND incidents. The guidance 

recommends that this process include potential future land uses, technical 

feasibility, costs, cost-effectiveness, and public accountability. In 

commenting on a draft of this report, EPA informed us that draft guidance 

intended to outline the structure of, and responsibilities for the conduct of 

the optimization process as they pertain to EPA’s involvement in RDD or 

IND incidents is under review by the new Administrator.27 EPA added that 

it looks forward to the lessons to be learned from the upcoming Liberty 

RadEx exercise in 2010, which officials believe should provide significant 

insights into the issues under discussion in this report. 

 

27EPA, EPA Guidance on the Optimization Process Following a Radiological Dispersal 

Device or Improvised Nuclear Device Incident (Draft). 

Page 18 GAO-10-204 Combating Nuclear Terrorism
 

There are also limitations in federal capabilities to help state and local 

governments address the interim storage and eventual disposal of the 

radioactive waste that would arise from RDD or IND incidents. The 

National Science and Technology Council’s 2008 report found gaps in our 

nation’s capabilities to effectively remove and dispose of radioactive 

debris in the event of an RDD or IND incident. This is due, in part, to 

current restrictions on accessing possible disposal facilities for the 

radioactive debris stemming from such incidents. According to NNSA 

officials, DOE’s disposal sites currently can only accept low-level and 

mixed low-level radioactive waste from its own and DOD facilities under 

certain circumstances. Moreover, according to an EPA decontamination 

expert, EPA is concerned about access to commercial radioactive waste 

disposal sites in the event of such an incident. Currently, there is only one 

low-level radioactive waste disposal site located in Utah that could be 

used by most states for radioactive debris disposal, although a limited 

number of states have access to low-level radioactive waste disposal 

facilities for waste generated by users of radioactive materials in their 

states. Another issue is paying for waste disposal. In the Superfund 

program, EPA can bill the responsible party, if known. However, covering 

the cost of waste disposal would be complicated in the case of RDD or 

IND incidents. One additional complicating factor would be the mixing 

and problematic separation of radioactive, biological, and chemical 

materials in the debris that would stem from such incidents. According to 

a recent research paper on disposal issues, the proper characterization of 

the quantity, properties, and level of debris contamination and 

decontamination residue from an RDD or other radiological incidents can 

have significant impacts on cleanup costs and restoration timelines.28 In 

commenting on a draft of the report, EPA officials informed us that its 

Office of Research and Development is currently developing a suite of 

decision support tools for the management of waste and debris from a 

variety of different events, including radiological incidents. 

Storing and Disposing of Waste 

from Areas Contaminated with 

Radioactive Materials 

Concerns about limitations in these federal capabilities were expressed by 

many city, state, and federal regional office emergency management 

officials who responded to our survey. Respondents representing most of 

the cities (9 of 13), states (7 of 10), FEMA regional offices (6 of 9), and 

almost all EPA regional offices (9 of 10) expressed concerns about the 

Concerns about Federal 

Capabilities from Survey 

Respondents 

 

28P. Lemieux et al., “Updated Decision Support Tool for the Management of Waste and 

Debris from Radiological Incidents,” (conference paper presented at Waste Management 

2009 Conference, Phoenix, Ariz., March 1-5, 2009). 

Page 19 GAO-10-204 Combating Nuclear Terrorism
 

capabilities of federal agencies to provide the assistance needed to 

complete the necessary analysis and environmental clean up activities in 

the event of RDD or IND incidents. For example, respondents from several 

cities told us that they were concerned about how rapidly the federal 

government could provide this assistance, despite the strengthening of 

some capabilities since the terrorist attack of September 11, 2001. 

Respondents from most states expressed the same expectations of the 

federal government. For example, one state was particularly concerned 

about current federal capabilities to handle multiple and simultaneous 

RDD incidents across the country. 

The National Science and Technology Council’s 2008 report also found 

that cities and states would need to rely heavily on a strong federal 

response to a radiological incident. This report identified similar 

limitations in federal capabilities to rapidly characterize an incident site 

and contaminated critical infrastructure, contain and control contaminant 

migration, decontaminate and cleanup affected areas, and remove and 

dispose of the waste to facilitate long-term recovery. Moreover, the report 

claimed that catastrophic effects of RDD or IND incidents could be 

reduced and the path to recovery shortened with more effective 

decontamination, mitigation, and rapid recovery operations. 

City and state emergency management officials responding to our survey, 

as well as emergency management officials at EPA and FEMA regional 

offices across the country, provided a number of suggestions for ways to 

improve federal recovery preparedness for RDD and IND incidents, 

particularly with the environmental cleanup of areas that would be 

contaminated with radioactive materials from such incidents. Respondents 

from nearly all the cities and states expressed the need for a national 

disaster recovery strategy to address gaps and overlaps in current federal 

guidance in the context of RDD and IND incidents. This is important 

because, according to one city official, “recovery is what it is all about.” In 

developing such a recovery strategy, respondents from the cities, like 

those from their states, want the federal government to consult with them 

in the initial formulation of a recovery strategy through working and focus 

groups, perhaps organized on a regional basis. Respondents representing 

most cities (10 of 13) and states (7 of 10) also provided specifics on the 

type of planning guidance necessary, including integration and 

clarification of responsibilities among federal, state, and local 

governments. For example, respondents from some of the cities sought 

better guidance on monitoring radioactivity levels, acceptable cleanup 

standards, and management of radioactive waste. Most respondents from 

City, State, and 

Federal Emergency 

Management Officials 

Provided Suggestions 

to Improve Federal 

Recovery 

Preparedness for 

RDD and IND 

Incidents 

Page 20 GAO-10-204 Combating Nuclear Terrorism
 

cities expressed the need for greater planning interactions with the federal 

government and more exercises to test recovery plans. One city 

respondent cited the need for recovery exercises on a regional basis so the 

cities within the region might better exchange lessons learned. 

Respondents from most cities (11 of 13) and their states (7 of 10) said that 

they planned to conduct RDD and IND recovery exercises in the future. 

Finally, emergency management officials representing almost all cities and 

states in our survey offered some opinions on the need for intelligence 

information on RDD and IND threats. They generally said that sharing 

information with law enforcement agencies is necessary for appropriate 

planning for RDD or IND incidents and that the law enforcement fusion 

centers were a step in the right direction. However, only half of the 

respondents indicated that they were getting sufficient intelligence 

information from law enforcement sources. 

The EPA and FEMA regional office emergency management officials that 

responded to our survey also offered a number of suggestions on ways to 

improve federal preparedness to recover from RDD and IND incidents, 

generally concurring with the suggestions of the city and state 

respondents. The majority of the EPA regional offices (6 of 10) and FEMA 

regional offices (7 of 9) indicated that a national disaster recovery strategy 

was needed to address overlaps and gaps in current government 

responsibilities in the context of RDD and IND incidents. Almost all of 

them stressed the need to reach out and involve state and local 

governments in developing this recovery strategy. The majority of the EPA 

regional office (7 of 10) and FEMA regional office (5 of 9) respondents 

indicated that additional guidance was needed on the distribution of 

government responsibilities for the recovery phase of RDD or IND 

incidents, including the transfer of FRMAC responsibilities and the 

process for determining acceptable cleanup levels. Many of the federal 

regional office respondents mentioned the need to conduct recovery 

exercises that involve state and local governments. Finally, EPA and 

FEMA regional office respondents differed somewhat on the need for 

standard national guidance on the application of approaches for 

environmental cleanup of areas contaminated with radioactive materials. 

While about half of the EPA regional office respondents expressed the 

need for guidance on the application of existing approaches for RDD or 

IND incidents, most FEMA regional office respondents (7 of 9) indicated 

that it would be beneficial to synchronize existing guidance from multiple 

and disparate sources to ensure that they are complementary and not 

competing. 

Page 21 GAO-10-204 Combating Nuclear Terrorism
 

While it was more limited in scope than what is usually envisioned as an 

RDD incident, the aftermath of the 2006 polonium poisoning incident in 

London had many of the characteristics of an RDD incident, including 

testing hundreds of people who may have been exposed to radiation and a 

cleanup of numerous radiation-contaminated areas. Because of its 

experience in dealing with the cleanup from this incident and from other 

actions the United Kingdom has taken to prepare for an RDD or IND 

attack, we met with officials from this country to obtain a better 

understanding of their approach to recovery preparedness. These officials 

told us that the attention to recovery in their country is rooted in decades 

of experience with the conflict in Northern Ireland, dealing with 

widespread contamination from the Chernobyl nuclear power plant 

accident, and a national history of resilience—that is, the ability to manage 

and recover from hardship. We found that actions the United Kingdom 

reported taking to prepare for recovery from RDD and IND incidents are 

similar to many of the suggestions for improvement in federal 

preparedness that we obtained through our survey of city, state, and 

federal regional office emergency management officials in the United 

States. For example, we found that the United Kingdom reported taking 

the following actions: 

The United Kingdom’s 

Handling of the 2006 

Polonium Incident 

and Subsequent 

Actions Provide 

Information That May 

Help U.S. Federal 

Agencies Prepare for 

RDD and IND 

Incidents 

• Enacted civil protection legislation in 2004. This civil protection legislation 

includes subsequent emergency response and recovery guidance, issued in 

2005, to complement the legal framework established for emergency 

preparedness. This guidance describes the generic framework for 

multiagency response and recovery for all levels of government. The 

guidance emphasizes that response and recovery are not discrete activities 

and do not occur sequentially; rather, recovery should be an integral part 

of response from the very beginning, as actions taken at all times can 

influence longer-term outcomes for communities. 

• Established a Government Decontamination Service in 2005. This 

organization was created out of recognition that it would not be costeffective for each entity—national, regional, and local government—to 

maintain the level of expertise needed for cleaning up chemical, biological, 

radiological, and nuclear materials, given that such events are rare.29 The 

Government Decontamination Service provides advice and guidance to 

local governments, maintains and builds a framework of specialized 

analysis and environmental cleanup contractors, and advises the national 

 

29The Government Decontamination Service is similar in size and responsibilities to EPA’s 

National Decontamination Team, which became fully operational in August 2007. 

Page 22 GAO-10-204 Combating Nuclear Terrorism
 

government regarding response capabilities. This service implemented its 

responsibilities by assisting the City of Westminster respond to the 

analysis and environmental cleanup needs following the November 2006 

polonium poisoning of Alexander Litvinenko. 

• Developed online national recovery guidance in 2007. This guidance 

reinforces and updates the early emergency response and recovery 

guidance by establishing, among other things, a recovery planning process 

during the response phase so that the potential impacts of early advice and 

actions are explored and understood for the future recovery of the 

affected areas. Moreover, the guidance—reviewed every 3 months and 

updated as necessary—emphasizes the need for training recovery 

personnel on essential roles, responsibilities, and procedures to test 

competencies, as well as to design and conduct recovery exercises. 

• Updated the recovery handbooks for radiation incidents in 2008 and 2009. 

The handbooks are intended to aid decision makers in developing 

recovery strategies for contaminated food production systems, drinking 

water, and inhabited areas following the release of radioactive materials 

into the environment. The handbooks were first published in 2005 in 

response to the Chernobyl nuclear power plant accident. The current 

handbooks include management options for application in the prerelease, 

emergency and longer-term phases of an incident. Sources of 

contamination considered in the handbooks include nuclear accidents, 

radiological dispersion devices, and satellite accidents. The handbooks are 

divided into several independent sections comprising supporting scientific 

and technical information, an analysis of the factors influencing recovery, 

compendia of comprehensive, state-of-the-art datasheets for around 100 

management options, guidance on planning in advance, a decision-aiding 

framework comprising color-coded selection tables, look-up tables and 

decision trees, and several worked examples. The handbooks can also be 

applied for training purposes and during emergency exercises. 

• Conducted a full-scale RDD recovery exercise in 2008. This exercise, 

involving several hundred participants, provided a unique opportunity to 

examine and test the recovery planning process within the urgency of a 

compressed time frame. The exercise, which took place 6 weeks after the 

response exercise, had participants address three scenarios: rural 

contamination of crops and livestock, contamination of the urban transit 

infrastructure, and disruption of the water supply. The lessons learned 

from this exercise were incorporated into the United Kingdom’s recovery 

strategy. One key lesson is the benefit of exercising the handover of 

government leadership during the response phase to leadership of the 

recovery phase. 

Page 23 GAO-10-204 Combating Nuclear Terrorism
 

• Established a national risk register in 2008. This register provides 

information on the risks facing the country, including malicious attacks 

such as with an RDD. This threat information was previously held 

confidential by the government. The government reported that the release 

of this information is intended to encourage public debate on security and 

help organizations, individuals, families, and communities that want to 

prepare for these emergencies. This register is designed to complement 

community risk registers that have been published by local emergency 

planners since passage of the 2004 civil protection legislation. The 

community risk registers are based on local judgments of risks, as well as 

from information contained in the national risk assessment—a 5-year 

planning assessment that is still a classified document. The government 

has conducted this risk assessment since 2005. 

• Issued specific nuclear recovery planning guidance in 2009. This guidance, 

the UK Nuclear Recovery Plan Template, provides a generic recovery 

strategy and structures needed to address a radiological release from a 

civil or defense nuclear reactor, as well as incidents involving nuclear 

weapons and special nuclear materials in transit. It is also considered 

applicable to recovery from RDD and IND incidents. Among other things, 

it provides guidance on the formation of a Recovery Advisory Group and 

Science and Technology Advisory Cell early in the response phase. The 

Recovery Advisory Group would be charged with identifying immediate 

and high-level strategic recovery objectives—recorded in templates to 

keep the process focused and on track—for, among other activities, 

cleanup levels, management of radioactive waste, compensation 

arrangements, and recovery costs. This advisory group would transition 

into a broader Strategic Recovery Coordinating Group during the recovery 

phase. The guidance requires that all high-risk cities in the United 

Kingdom prepare recovery plans. 

Finally, according to United Kingdom officials, the 2006 polonium incident 

in London showed the value of recovery planning. In particular, through 

this incident, United Kingdom officials gained an appreciation for the need 

to have an established cleanup plan, including a process for determining 

cleanup levels, sufficient laboratory capacity to analyze a large quantity of 

samples for radiation, and procedures for handling the radioactive waste. 

Furthermore, they found that implementing cleanup plans in the polonium 

poisoning incident and testing plans in the November 2008 recovery 

exercise have helped the United Kingdom to better prepare for larger RDD 

or IND incidents. Appendix III contains a more thorough review of the 

approach to recovering from RDD and IND incidents in the United 

Kingdom. 

Page 24 GAO-10-204 Combating Nuclear Terrorism
 

Recovering from RDD or IND incidents would likely be difficult and 

lengthy. Completing the analysis and environmental cleanup of areas 

contaminated with radioactive materials would be among the first steps in 

the recovery process after the initial response to save lives. A faster 

recovery—meaning people can return sooner to their homes and 

businesses and get back to the routines of everyday life—would help 

lessen the consequences of RDD and IND incidents. In fact, being fully 

prepared to recover from such an incident may also serve as a deterrent to 

those who would do us harm. 

However, our work demonstrates that the federal government is not fully 

prepared to help cities and states with the analysis and environmental 

cleanup of areas contaminated with radioactive materials from RDD and 

IND incidents. To date, FEMA has not developed a national disaster 

recovery strategy, as required by law, which would help guide RDD and 

IND recovery planning, or issued specific guidance to coordinate federal, 

state, and city recovery planning for these incidents. Federal agencies have 

also included only a few recovery discussions in the response exercises to 

these incidents. The lack of clearly communicated guidance on federal 

responsibilities and activities has left emergency management officials in 

the cities and states we surveyed confused about which federal agency to 

turn to for assistance, and many federal regional office officials we 

surveyed were not certain about which environmental cleanup methods 

and technologies would be the most successful in removing radioactive 

materials from buildings and infrastructure. 

As the United States moves forward in recovery preparation, some insights 

might be gained from the actions already taken by the United Kingdom to 

increase its preparedness to recover from acts of nuclear and radiological 

terrorism, many of which are similar to those suggested by the city, state, 

and federal emergency management officials we surveyed for improving 

federal preparedness to recover from RDD and IND incidents. 

To better prepare federal agencies to coordinate with state and local 

governments on the analysis and environmental cleanup of areas 

contaminated with radioactive materials following RDD or IND incidents, 

we recommend that the Secretary of Homeland Security direct the Federal 

Emergency Management Agency Administrator to 

Conclusions 

Recommendations for 

Executive Action 

• prepare a national disaster recovery strategy that would clarify federal 

responsibilities for assisting state and local governments with the 

Page 25 GAO-10-204 Combating Nuclear Terrorism
 

analysis and environmental cleanup of areas contaminated with 

radioactive materials in the event of RDD or IND incidents; 

• issue guidance that describes how federal capabilities would be 

integrated into and support state and local plans for recovery from 

RDD and IND incidents; and 

• schedule additional recovery exercises, in partnership with other 

federal, state, and local governments that would, among other things, 

specifically assess the preparedness of federal agencies and their 

contractors to conduct effective and efficient analysis and 

environmental cleanup activities associated with RDD and IND 

incidents. 

GAO provided DHS, DOE, and EPA with a draft of this report for their 

review and comment. DHS and FEMA concurred with the 

recommendations in the report. DOE, through NNSA, generally agreed 

with our report findings and provided technical comments, which we 

incorporated as appropriate. EPA did not agree or disagree with the report 

findings, but offered technical comments, which we incorporated as 

appropriate. 

Agency Comments 

and Our Evaluation 

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

appropriate congressional committees as well as to the Secretaries of 

Homeland Security and Energy; the Administrators of NNSA and EPA; and 

other interested parties. The report will also be available at no charge on 

the GAO Web site at http://www.gao.gov. 

Page 26 GAO-10-204 Combating Nuclear Terrorism
 

If you or your staffs have any questions about this report, please contact 

me at (202) 512-3841 or aloisee@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made key contributions to this report are 

Gene Aloise 

listed in appendix IV. 

Director, Natural Resources 

 and Environment 

Page 27 GAO-10-204 Combating Nuclear Terrorism
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

In our review, we examined (1) the extent to which federal agencies are 

planning to fulfill their responsibilities to help cities and states clean up 

areas contaminated with radiation materials from radiological dispersal 

device (RDD) and improvised nuclear device (IND) incidents, (2) what is 

known about the federal government’s capability to effectively clean up 

areas contaminated with radioactive materials from RDD and IND 

incidents, and (3) suggestions from government emergency management 

officials for improving federal preparedness to help cities and states 

recover from RDD and IND incidents. In addition, we are providing 

information on actions taken in the United Kingdom to prepare for 

recovering from RDD and IND incidents. 

To determine the extent to which federal agencies are planning to fulfill 

their responsibilities to help cities and states clean up areas contaminated 

with radioactive materials from RDD and IND incidents, we reviewed 

pertinent federal law, presidential directives, and other executive 

guidance; interviewed cognizant officials from the Department of 

Homeland Security (DHS), Department of Energy (DOE), Environmental 

Protection Agency (EPA), Federal Emergency Management 

Administration (FEMA), and Nuclear Regulatory Commission (NRC); 

conducted a survey of 13 cities considered to be at high or medium risk to 

such attacks and their states,1

 and all federal FEMA and EPA regional 

offices; and reviewed information on the number and type of RDD and 

IND response and recovery exercises that have been conducted from May 

2003 through September 2009. More specifically, we reviewed existing 

planning documents for domestic incidents to determine the extent to 

which they addressed recovery issues, particularly from RDD and IND 

incidents. For example, we found limited discussion of recovery planning 

for these incidents in various annexes to the National Response 

Framework, such as its emergency support function annexes and nuclear 

and radiological incident annex, as well as other planning documents. In 

addition, after speaking with emergency management officials in San 

Francisco and comparable state officials near Sacramento, California, we 

developed a semistructured telephone survey instrument—pretested in 

Denver, Colorado—in order to obtain the perspectives of city and state 

emergency management officials on government responsibilities and plans 

to fulfill them. We originally selected 13 high- and medium-risk cities and 

 

1

The high- and medium-risk cities came from a list compiled by an advisory group to the 

insurance industry that conducts catastrophe event modeling. DHS also maintains a list of 

high-risk cities. However, DHS considers its list to be sensitive information. Nonetheless, 

DHS officials agreed that using the insurance industry list for our survey was reasonable. 

Page 28 GAO-10-204 Combating Nuclear Terrorism 
Appendix I: Scope and Methodology 

their 11 states to cover the mostly likely target cities for a terrorist attack 

and to ensure that we had at least 1 city in each of the 10 EPA and FEMA 

regions. The cities included Atlanta, Boston, Chicago, Dallas, Denver, 

Detroit, Houston, Los Angeles, New York, Philadelphia, San Francisco, 

Seattle, and St. Louis. While Washington, D.C., is considered a high-risk 

city, we excluded it from our survey because it is unlike other cities in its 

reliance on the federal government and the agencies that would take over 

analysis and environmental remediation activities. Emergency 

management officials representing these cities and their states responded 

to our survey, except for Atlanta and the states of Georgia and 

Massachusetts. After repeated attempts to include this city and the two 

states in our survey, we decided to drop them. We replaced Atlanta and 

the state of Georgia with Miami and the state of Florida, which are in the 

same federal region. Because we decided to retain Boston despite 

receiving no response from Massachusetts, we ended up with 10 states in 

our survey. We also visited EPA regional offices in San Francisco and 

Denver, and the FEMA regional office in Oakland, to develop questions to 

survey all 10 EPA and FEMA regional offices in order to obtain a federal 

field perspective on this issue. All EPA and FEMA regional offices 

responded to our survey, except FEMA region 8. We tabulated the yes and 

no responses to each pertinent question from the city, state, and federal 

surveys and conducted a content analysis of the explanatory statements 

accompanying many of the questions. FEMA’s National Exercise Schedule 

database was used to identify the location and types of RDD and IND 

response and recovery exercises—based on national planning scenarios. 

Because we determined in our April 2009 report (GAO-09-369) that this 

database is unreliable, we asked each city, state, and federal regional 

office in our survey to list RDD and IND response and recovery exercises 

that had taken place in their jurisdiction, as well as any plans for future 

exercises to check the accuracy of the federal exercise database. In 

addition, we attended the first full-scale recovery tabletop exercise—

Empire09—based on an RDD incident scenario in Albany, New York that 

was conducted on June 16-17, 2009, and an interagency planning session 

held in Philadelphia on October 28-29, 2009, to prepare for the Liberty 

RadEx recovery exercise scheduled for April 26-30, 2010 in Philadelphia. 

To determine what is known about the federal government’s capabilities 

to effectively clean up areas contaminated with radioactive materials from 

RDD and IND incidents, we reviewed pertinent guidance on available 

methods and technologies and obtained information from subject matter 

experts at the federal agencies and national laboratories about their 

potential application for RDD and IND incidents. More specifically, we 

spoke with subject matter experts at the National Nuclear Security 

Page 29 GAO-10-204 Combating Nuclear Terrorism
Appendix I: Scope and Methodology 

Administration, EPA, and FEMA, as well as at DOE’s Lawrence Livermore 

National Laboratory and Idaho National Laboratory and EPA’s Andrew W. 

Breidenbach Environmental Research Center, National Air and Radiation 

Environmental Laboratory, National Decontamination Team, National 

Homeland Security Research Center, and the Radiation and Indoor 

Environments National Laboratory. We also observed a demonstration of 

the capabilities of the Interagency Modeling and Atmospheric Assessment 

Center at Lawrence Livermore National Laboratory and some 

decontamination research projects at the National Homeland Security 

Research Center. In addition, we reviewed reports and documents from 

these agencies, national laboratories, and research centers that addressed 

methods and technologies for analysis and environmental remediation of 

areas contaminated with radioactive materials as well as some that 

specifically discussed their potential use for RDD or IND incidents. 

Moreover, we included questions about the potential use of these 

approaches in our semistructured phone survey of federal, state, and city 

emergency management officials. 

To identify suggestions from government emergency management officials 

for improving federal preparedness to help cities and states recover from 

RDD and IND incidents, we included relevant questions in our 

semistructured phone survey of federal, state, and city officials. We 

conducted a content analysis of these questions to identify patterns in the 

responses, that is, what types of suggestions were most prevalent. We also 

reviewed past GAO reports and other documents that addressed areas for 

improvement in federal preparedness. 

In addition, to broaden our review of potential areas for improvement in 

federal involvement in planning and preparing for the recovery from RDD 

and IND incidents, we included the United Kingdom in our scope. This 

country has actual experience with recovery from a radiological incident 

in an urban area and was suggested to us by EPA officials as a country that 

is one of the leaders in recovery planning. We interviewed selected central 

and regional government officials responsible for response and recovery 

planning and preparation, and we visited a decontamination contractor 

that performed environmental remediation activities in the aftermath of 

the 2006 radioactive poisoning of Alexander Litvinenko in London. We also 

reviewed documents provided by these officials and from other sources to 

obtain a better understanding of this system and how it might apply to the 

United States. Two officials from the United Kingdom who we interviewed 

during our site visit reviewed a draft of the information contained in 

appendix III for content and accuracy. 

Page 30 GAO-10-204 Combating Nuclear Terrorism
Appendix I: Scope and Methodology 

We conducted this performance audit from October 2008 to January 2010 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. 

Page 31 GAO-10-204 Combating Nuclear Terrorism
Appendix II: Recovery Exercises 

Table 1 provides a brief summary of four RDD exercises, since May 2003, 

which contained recovery objectives including a planned exercise for April 

2010. 

Table 1: RDD Exercises Containing Recovery Objectives, May 2003 to April 2010 

Name of 

exercise 

Dates of 

exercise Lead agency 

Locations of 

exercise 

Objectives of recovery 

exercise 

Issues discussed at recovery 

exercise 

Nationallevel 

exercise 

(TOPOFF 2) 

May 12-16, 

2003: RDD 

response 

exercise 

included a largescale game 

involving 

recovery issues 

DHS and State 

Department 

Seattle, Wash. 

and Chicago, Ill. 

• To improve incident 

management 

capabilities 

• To collect and 

coordinate 

distribution of RDD 

plume modeling data 

• Data collection and 

coordination 

• Coordinating the distribution 

of plume model analysis 

products 

• Federal Radiological 

Monitoring and Assessment 

Center (FRMAC) transition 

Nationallevel 

exercise 

(TOPOFF 4) 

October 15-19, 

2007: RDD 

response 

exercise was 

followed by a 

long-term 

recovery tabletop 

exercise on 

December 4, 

2007 

DHS Phoenix, Ariz., 

Portland, Ore, and 

Guam 

• To identify gaps in 

role definitions, 

authorities, 

standards, 

capabilities, etc., for 

key recovery 

measures 

• To determine costbenefit tradeoffs in 

defining acceptable 

risk for long-term 

exposures as a guide 

to cleanup and 

recovery activity 

• To identify measures 

and communication 

strategies for 

maintaining public 

confidence 

• Sampling and laboratory 

capacity 

• Decontamination 

technologies 

• Radioactive waste disposal 

and management 

• FRMAC leadership 

transition 

Empire 2009 June 1-5, 2009: 

RDD response 

exercise was 

followed by a 

facilitated 

discussion 

recovery 

exercise on June 

16-17, 2009 

DOE Albany, N.Y. • To establish criteria 

for the release of 

public areas 

• To establish cleanup 

values, and long-term 

monitoring, sampling 

and community 

recovery plans 

• To discuss the 

transfer of FRMAC 

leadership 

responsibility 

• Cleanup planning and 

guidance 

• Implementation of cleanup 

and optimization process for 

determining cleanup levels 

• Data management 

optimization 

• Waste disposal 

• FRMAC leadership 

transition 

Appendix II: Recovery Exercises 

Page 32 GAO-10-204 Combating Nuclear Terrorism 
Appendix II: Recovery Exercises 

Name of 

exercise 

Dates of 

exercise Lead agency 

Locations of 

exercise 

Objectives of recovery 

exercise 

Issues discussed at recovery 

exercise 

Liberty 

RadEx 2010 

April 26-30, 

2010: RDD 

response 

exercise is to 

include recovery 

related issues 

EPA Philadelphia, 

Penn. 

• To exercise roles for 

hazardous materials 

assessment, 

mitigation, cleanup 

and FRMAC 

leadership transition 

• To apply guidelines 

for mitigation and 

short-term cleanup 

• To review community 

recovery activities for 

contamination and 

long-term cleanup 

• To utilize the 

optimization process 

to prioritize mitigation 

and cleanup activities 

in post-emergency 

phase and to develop 

long-term cleanup 

standards 

• Coordination between 

cleanup and public health 

• Community/stakeholder 

involvement 

• Long-term cleanup planning 

and prioritization 

• Involvement and 

coordination with FEMA on 

long-term community 

recovery in cleanup 

planning 

• Long-term relocation 

decision making 

• Waste disposal 

Source: GAO analysis of federal agency documents. 

Page 33 GAO-10-204 Combating Nuclear Terrorism
Appendix III: Radiolo

Experie

gical Recovery

nces in the United Kingdom 

Page 34 GAO-10-204 

Appendix III: Radiological Recovery 

Experiences in the United Kingdom 

The United Kingdom provides an example of another country’s efforts to 

prepare to recover from a terrorist attack using chemical, biological, 

radioactive, or nuclear materials. This country’s attention to recovery 

needs is reflected in promulgating emergency response and recovery 

legislation, establishing a government decontamination service, creating 

online national recovery guidance, updating a recovery handbook for 

radiation incidents, conducting a full-scale RDD recovery exercise, 

establishing a community and national risk register system, and preparing 

specific nuclear recovery planning guidance. The particular emphasis on 

recovery activities in the United Kingdom has been linked to decades of 

experience with the conflict in Northern Ireland, widespread 

contamination from the Chernobyl nuclear power plant accident, and a 

national history of resilience—that is, the ability to manage and recover 

from hardship. 

Emergency Response and 

Recovery Framework 

The United Kingdom has established a framework for addressing the 

release of radiological materials that prompted planning for the recovery 

from these events. This framework was primarily established through the 

2001 Radiation (Emergency Preparedness and Public Information) 

Regulations1

 and the 2004 Civil Contingencies Act, as well as guidance 

issued pursuant to the Civil Contingencies Act.2

 According to a senior 

official from the United Kingdom’s Health Protection Agency, the radiation 

regulations were developed in response to a European Union directive 

following the 1986 Chernobyl, Ukraine, nuclear power plant accident.3

These regulations require preparation of on- and off-site emergency 

management plans for release of radioactive materials in the event of a 

nuclear power plant accident, as well as the conduct of exercises to test 

preparedness to respond to radiological releases. According to this 

official, while the radiation regulations did not include directives to 

prepare for recovery from such accidents, they established a Nuclear 

Emergency Planning Liaison Group, which formed a Recovery Subgroup 

to begin addressing this planning need. 

 

1

The Radiation (Emergency Preparedness and Public Information) Regulations 2001, 2001 

No. 2975, August 27, 2001. 

2

Civil Contingencies Act 2004, 2004 Chapter 36, Royal Assent on November 18, 2004. 

3

The Radiation (Emergency Preparedness and Public Information) Regulations 2001, 

implemented Council Directive 96/29/Euratom on laying down basic safety standards for 

the protection of the health of workers and the general public against the dangers arising 

from ionizing radiation. 

 Combating Nuclear Terrorism 
Appendix III: Radiological Recovery 

Experiences in the United Kingdom 

The 2004 Civil Contingencies Act was enacted following a government 

consultation exercise that concluded that previous legislation provided an 

inadequate framework for civil protection against twenty-first century 

risks, including terrorism. The Civil Contingencies Act established a 

statutory framework of roles and responsibilities for local responders to 

address the effects of the most serious emergencies facing the country. 

Guidance issued pursuant to this legislation established an integrated 

emergency management system, not unlike that in the United States,4

comprising six related activities: anticipation, assessment, prevention, 

preparation, response, and recovery. The November 2005 guidance 

addressing emergency response and recovery covers the principles, 

practical considerations, operational doctrine, and examples of good 

practice for these activities.5

 This guidance describes the generic 

framework for multiagency response and recovery activities at all levels of 

government, emphasizing that these activities are not separate activities 

that occur sequentially. Instead, this guidance contends that recovery 

considerations should take place early in the response phase, as initial 

decisions can affect the long-term outcomes for communities. Moreover, 

because the government recognized that no single approach could meet 

the needs of every affected area, it did not intend this guidance to be either 

prescriptive or an operational manual. 

Government 

Decontamination Service 

In 2005, the United Kingdom established a special Government 

Decontamination Service to address issues associated with contaminated 

land, buildings, open space, infrastructure, and transportation routes from 

both deliberate and accidental releases of chemical, biological, 

radiological, and nuclear materials.6

 This service was established because 

the national government recognized that it would not be cost-effective for 

each responsible authority—national, regional, and local governments—to 

maintain the level of expertise needed for the analysis and environmental 

 

4

In 2004, the United States established its National Incident Management System to provide 

a consistent nationwide approach for government, private sector, and nongovernmental 

organizations to prepare for, respond to, and recover from domestic incidents. 

5

HM Government, Emergency Response and Recovery: Non-Statutory Guidance to 

Complement Emergency Preparedness (York: Easingwold, Library and Information Centre, 

Emergency Planning College, November 2005). 

6

The Government Decontamination Service has been compared to EPA’s National 

Decontamination Team, which became fully operational in August 2007. Both organizations 

are similar in size and have similar advisory missions to local authorities, but the EPA team 

does not itself maintain a framework of contractors. 

Page 35 GAO-10-204 Combating Nuclear Terrorism
Appendix III: Radiological Recovery 

Experiences in the United Kingdom 

cleanup of affected areas given that the release of such material would be 

a rare event. The Government Decontamination Service has no statutory 

powers itself, nor does it directly provide analysis and environmental 

remediation services. Instead, it provides advice and guidance to local 

governments, maintains and builds a framework of specialized contractors 

to conduct these activities, and advises the national government regarding 

response capabilities. 

In regard to advice to local governments, in November 2006, the 

Government Decontamination Service was requested to respond to an 

incident involving the poisoning of Alexander Litvinenko with a 

milligram—about the size of a grain of salt—of polonium-210. This service 

was asked to assist the City of Westminster, within greater London, given 

the international nature of the event, even though the incident was 

classified as a hazardous materials event rather then a terrorist incident. 

According to the recovery planning process, the city selected a contractor 

from the Government Decontamination Service list of specialized 

contractors for the remediation work and used a model contract 

developed by this service for this purpose. This model contract contains 

allowable costs per unit, equipment charges, and charge out rates for the 

emergency response. Under the contract, the selected specialized 

contractor agrees to start off with nonaggressive, simple, and less 

expensive decontamination approaches, and then apply more 

sophisticated approaches, if necessary, to meet the desired cleanup level. 

The actual payments for these services were made by the owners of 

properties, such as a hotel where the perpetrators of the crime had stayed, 

that were contaminated with polonium. However, the cleaning up of 

public premises was a responsibility of the local government. The national 

government has established ways to help cover the costs of such incidents. 

This includes insurance coverage for damages resulting from acts of 

terrorism. For large commercial concerns, the insurance industry offers 

terrorist insurance that is underwritten by the government. For smaller 

companies, terrorist insurance is offered for an additional 20 percent 

surcharge on an existing policy. Other funding is available for local 

governments if such an event would overwhelm their financial resources, 

such as applying for grants from the national government or European 

Union. 

In regard to its framework of specialized contractors, the service has 

identified three specialized contractors that have capabilities to address 

various decontamination scenarios, and it certifies their capabilities 

through testing. A specialized contractor is invited to visit the location, 

receives a briefing on the incident scenario, and is asked to develop a 

Page 36 GAO-10-204 Combating Nuclear Terrorism
Appendix III: Radiological Recovery 

Experiences in the United Kingdom 

recommended decontamination strategy. The Government 

Decontamination Service then assesses the contractor’s approach and 

recommendations to identify issues, strengths, and weaknesses. In 

addition, the service develops improvement plans, backed with exercises, 

to address identified performance gaps. For example, in December 2007, 

the Government Decontamination Service tested and evaluated the 

capabilities of one of its specialized contractors to analyze and clean up 

areas contaminated with radioactivity from an RDD event scenario in 

downtown Birmingham. In Exercise Streetwise, a specialized contractor 

was fully tested at the venue on its capability to detect and clean up actual 

radioactive materials. According to a senior official with the Government 

Decontamination Service, “you cannot get a realistic picture of recovery 

needs and issues through only tabletop exercises.” 

Finally, in regard to advice to national government, the Government 

Decontamination Service participates in efforts to identify, prioritize, and 

as necessary maintain decontamination-related research projects, and it 

has established a library of the relevant knowledge and experiences drawn 

from national and international sources. For example, a Government 

Decontamination Service official told us that this agency is currently 

engaged in learning more about how to deal with the disposal of 

radioactive waste that has no known owner, which might be similar to the 

radioactive waste stemming from an RDD incident. The issue is not only 

ownership, but where to put the radioactive debris and how to cover the 

cost of storage and disposal. In this regard, the United Kingdom has a 

clearance rule for allowing very low-level radioactive waste to be disposed 

of in less expensive and more numerous solid and hazardous waste landfill 

sites without specific regulatory approval or exemption.7

 In addition, the 

United Kingdom and the United States have agreed to increase the 

exchange of information and personnel regarding the research, 

development, testing, evaluation, and development of technical standards 

 

7

The United States does not have a clearance rule to allow very low-level radioactive waste 

to be disposed of at more conventional landfill sites. Rather, the Nuclear Regulatory 

Commission takes a case-by-case approach, which has also been implemented by some 

Agreement States. 

Page 37 GAO-10-204 Combating Nuclear Terrorism
Appendix III: Radiological Recovery 

Experiences in the United Kingdom 

and operations to address chemical, biological, radiological, and nuclear 

incidents.8

Online National Recovery 

Guidance 

While passage of the 2004 Civil Contingencies Act was an important 

legislative step to further emergency preparedness, the reaction of local 

responders to several domestic incidents following passage of this act 

made it clear to the national government that these responders needed 

more comprehensive guidance than that contained in the 2005 guidance 

for emergency response and recovery activities. One such event was the 

July 2005 subway bombing in London by a terrorist group that killed 52 

people. This incident, in conjunction with other events in 2005, such as the 

Buncefield Fire and severe flooding, prompted the government in 2006 to 

form a National Recovery Working Group to address the need for 

additional recovery guidance for multiple risk scenarios. This working 

group was comprised of a wide range of government departments and 

agencies, as well as other stakeholders who had been involved in the 

recovery phase following these events. The government charged this 

working group with, among other things (1) producing national recovery 

guidance for local responders, (2) identifying gaps in the country’s 

recovery capability with recommendations to address them, and (3) 

contributing to the ongoing review of the 2005 nonstatutory guidance for 

emergency response and recovery activities. In 2007, the working group 

produced a National Recovery Guidance document.9

 This guidance 

establishes a planning process for involving recovery stakeholders during 

the response phase to ensure that the potential impact of early advice and 

actions for the future recovery of the area are explored and understood. 

This online guidance covers 14 generic issues, such as recovery structures 

and processes, training and exercises, and a lessons learned process, 

which are reviewed every 3 months and updated as necessary.10 For 

 

8

Agreement Between the Government of the United States of America and the Government 

of the United Kingdom of Great Britain and Northern Ireland on Cooperation in Science 

and Technology for Critical Infrastructure Protection and Other Homeland/Civil Security 

Matters. There are also 10 annexes attached to this agreement, including joint exercises 

and training on decontamination approaches. 

9

The National Recovery Guidance is a guide to emergency response and recovery 

maintained by the national government. 

10The U.S. administration and Congress directed the preparation of a national disaster 

recovery strategy or framework in The National Strategy for Homeland Security of 2007 

and the Post Katrina Emergency Management Reform Act of 2006, but no action has been 

taken to date. 

Page 38 GAO-10-204 Combating Nuclear Terrorism
Appendix III: Radiological Recovery 

Experiences in the United Kingdom 

example, the National Recovery Guidance addresses the need for training 

recovery personnel on essential roles, responsibilities, and procedures to 

test competencies, as well as the need to design and conduct recovery 

exercises. While acknowledging that recovery training and exercises lag 

behind those for response, the National Recovery Working Group found 

that many organizations had already conducted small-scale recovery 

exercises and had applied lessons learned from them. One of the lessons 

identified was the need to exercise the shift from the response phase to 

the recovery phase. 

Updated Recovery 

Handbooks for 

Radiological Incidents 

The 2009 version of the UK Recovery Handbooks for Radiological 

Incidents is considered relevant to radiological releases—accidental and 

intentional—from the nuclear and nonnuclear industry sectors.11 The 

handbooks, first published in 2005 by the United Kingdom’s Health 

Protection Agency, were developed in response to the need for further 

recovery guidance following the Chernobyl nuclear power plant accident. 

The development of these handbooks was sponsored by six government 

departments and agencies representing national and local governments. 

According to a senior official from the Health Protection Agency, the 

European Union also supported the development of a series of generic 

recovery handbooks for use by other countries based on the structure, 

format, and content of the handbook developed for the United Kingdom. 

This official told us that member countries of the European Union are 

currently customizing their handbooks for use at national, regional, and 

local levels. The current handbooks, updated from the 2008 version, 

include management options for application in the prerelease, emergency 

and longer-term phases of an incident. Sources of contamination 

considered in the handbooks include nuclear accidents, radiological 

dispersion devices, and satellite accidents. The handbooks are divided into 

several independent sections comprising supporting scientific and 

technical information, an analysis of the factors influencing recovery, 

compendia of comprehensive, state-of-the-art datasheets for around 100 

management options, guidance on planning in advance, a decision-aiding 

framework comprising color-coded selection tables, look-up tables and 

decision trees, and several worked examples. The handbooks can be 

applied as part of the decision-aiding process to develop a recovery 

 

11A. Nisbet et. al., UK Recovery Handbooks for Radiation Incidents 2009, version 3, 

prepared for the Radiation Protection Division, Centre for Radiation, Chemical and 

Environmental Hazards, Health Protection Agency (Chilton, Didcot, Oxfordshire, U.K., 

December 2009). 

Page 39 GAO-10-204 Combating Nuclear Terrorism
Appendix III: Radiological Recovery 

Experiences in the United Kingdom 

strategy following an incident, for training purposes, and during 

emergency exercises. An example of a datasheet for one of the 

management options—high pressure hosing—contained in the UK 

Recovery Handbooks for Radiation Incidents: 2009, is provided in figure 1. 

Page 40 GAO-10-204 Combating Nuclear Terrorism
Appendix III: Radiological Recovery 

Experiences in the United Kingdom 

Figure 1: Example of a Datasheet on High Pressure Hosing for Cleaning 

Contaminated Surfaces in the UK Recovery Handbooks for Radiation Incidents: 

2009

Page 41 GAO-10-204 Combating Nuclear Terrorism
Appendix III: Radiological Recovery 

Experiences in the United Kingdom 

Page 42 GAO-10-204 Combating Nuclear Terrorism
Appendix III: Radiological Recovery 

Experiences in the United Kingdom 

Source: A. Nisbet et. al., UK Recovery Handbooks for Radiation Incidents 2009, version 3, prepared for the Radiation Protection 

Division, Centre for Radiation, Chemical and Environmental Hazards, Health Protection Agency (Chilton, Didcot, Oxfordshire, U.K., 

December 2009).

Page 43 GAO-10-204 Combating Nuclear Terrorism
Appendix III: Radiological Recovery 

Experiences in the United Kingdom 

In November 2008, Exercise Green Star tested government capabilities to 

recover from a terrorist attack based on RDD scenarios.12 This was the 

first time that complex recovery issues had been considered in a nationallevel exercise. In this exercise, several hundred participants were wholly 

focused on recovery issues. About 6 weeks after an initial RDD tabletop 

response exercise, which set the scene for the participants, a 2-day 

recovery exercise took place involving three scenarios: rural 

contamination of crops and livestock, contamination of the urban transit 

infrastructure, and disruption of the water supply. On day one of the 

exercise, participants looked at immediate cleanup issues, including 

resource priorities and management responsibilities. On day two, 

participants considered the longer-term issues of environmental 

contamination, monitoring strategies, and financial considerations. The 

use of a real radioactive isotope within the exercise scenario ensured that 

participants were able to investigate their own and wider mechanisms for 

obtaining scientific advice during an incident. A scientific advisory group 

was put in place to expedite the recovery process by helping to manage 

scientific input into the decision-making process. An after-action report 

was prepared following this exercise to capture lessons learned.13 One 

observation was that this exercise provided a unique opportunity to 

develop remediation policies within a compressed time frame, resulting in 

the development of a sound framework for recovery. 

RDD Recovery Exercises 

Community and National 

Risk Registration System 

The United Kingdom has developed a comprehensive program to ensure 

an effective response to a range of disruptive emergencies that might 

affect the country. The country uses the term “resilience” as the ability of 

organizations, like individuals, to withstand or recover easily and quickly 

from hardships, such as major flooding or a terrorist attack. Community 

risk registers have been published by local emergency management 

planners since passage of the 2004 Civil Contingencies Act. These 

community risk registers address specific risks identified by 

representatives from local emergency services and public, private, and 

voluntary organizations. Local resilience forums are required to develop 

 

12The United States plans to conduct its first full-scale recovery exercise, Liberty RadEx, in 

April 2010. 

13In the United States, the implementation plan for the national exercise program provides 

that after-action reports should be completed in 6 months or less following an exercise. In 

our April 2009 report (GAO-09-369), we found that FEMA had not ensured that after-action 

reports for Tier 1 exercises were completed in a prompt manner. 

Page 44 GAO-10-204 Combating Nuclear Terrorism
Appendix III: Radiological Recovery 

Experiences in the United Kingdom 

and maintain these registers that include a description of potential 

outcomes, likelihoods, impacts, and ratings for various risk categories and 

subcategories of events. One of the risk categories is an actual terrorist 

attack using an explosive device. The national government does not 

expect communities to directly track these risks, but rather to improve 

their own preparedness based on information from the national risk 

assessment, which is a classified document. In 2008, the government 

published a national risk register, which is based on this classified 

assessment and discusses the likelihood and potential impacts of a range 

of risks facing the country, including attacks using chemical, biological, 

radiological, and nuclear materials. This national risk register contains 

information that was previously held confidential within government but 

was published to encourage public debate on security and to help 

organizations, individuals, families, and communities prepare for 

encountering threats. The government reports that while there have been 

very few examples of attacks such as the 1995 release of Sarin gas in a 

Tokyo subway, it still recognizes the need to prepare and plan for them. 

Specific Nuclear Recovery 

Planning Guidance 

In March 2009, the Nuclear Emergency Planning Liaison group published a 

UK Nuclear Recovery Plan Template based on the National Recovery 

Guidance and Recovery Plan Guidance Template.

14 This document 

provides generic guidance for a recovery strategy and structures needed to 

address a radiological release from a civil or defense nuclear reactor 

accident, as well as from incidents involving nuclear weapons or special 

nuclear materials in transit. This guidance is based on examples from 

existing local government recovery plans and experiences. While not 

specific to malicious use of radiological and nuclear materials, according 

to a senior government official with the Health Protection Agency, this 

guidance and associated monitoring templates would have potential 

application for recovery from RDD or IND incidents. 

The UK Nuclear Recovery Plan Template considers recovery to be more 

than simply the replacement of what has been destroyed and the 

rehabilitation of those affected—it is a complex social and developmental 

process rather than just a remediation process. The manner in which 

recovery processes are undertaken is thus critical to their success and, 

therefore, best achieved when the affected community is able to exercise a 

 

14Nuclear Emergency Planning Liaison Group, UK Nuclear Recovery Plan Template (United 

Kingdom, March 10, 2009). 

Page 45 GAO-10-204 Combating Nuclear Terrorism
Appendix III: Radiological Recovery 

Experiences in the United Kingdom 

high degree of self-determination. As such, this document provides that 

during the initial response phase, a Strategic Coordinating Group, which 

manages this phase of the process, would receive input from a Recovery 

Advisory Group and a Science and Technology Advisory Cell. The 

Recovery Advisory Group would be charged with identifying immediate 

and high-level strategic objectives for recovery early in the response 

phase, including, among other actions, determining remediation levels and 

when to stop remediation, managing radiation-contaminated waste, and 

managing compensation arrangements and recovery costs. These 

objectives would be accompanied by targets and milestones that the 

community would use as a basis to track recovery progress—for example, 

cleanup activities—with the aid of various predesigned templates. The 

Science and Technology Advisory Cell would include experts to advise on 

health and welfare, environment and infrastructure, and monitoring 

response and recovery activities. On transition to the recovery phase of an 

incident, the Strategic Coordinating Group would be replaced by a 

Strategic Recovery Coordinating Group. 

The Strategic Recovery Coordinating Group would be supported by 

specific subgroups. These subgroups would include ones for finance and 

legal, communications, business and economic recovery, health and 

welfare, environment and infrastructure, and monitoring. For example, the 

subgroup on environment and infrastructure would identify viable options 

for remediation of food production systems, drinking water, and inhabited 

areas, including identifying options for the restoration and cleanup of the 

physical infrastructure and natural environment. The guidance suggests 

that this subgroup consider forming task groups to, among other things, 

address waste management and disposal, criteria to determine when 

remediation can cease, evaluate feasibility, and recommend remediation 

options for defined affected areas.15 The templates would be referred to 

throughout the recovery to ensure that the work of the Strategic Recovery 

Coordinating Group is focused and on track. 

 

15In the United States, DHS’s Planning Guidance for Protection and Recovery Following 

Radiological Dispersal Device (RDD) and Improvised Nuclear Device ( IND) Incidents 

(August 2008) describes a process for establishing late-phase cleanup criteria through a 

site-specific optimization process that should include potential future land uses, technical 

feasibility, costs, cost-effectiveness, and public acceptability. 

Page 46 GAO-10-204 Combating Nuclear Terrorism
Appendix IV: 

A

GAO Contact and Staff 

cknowledgments 

Page 47 GAO-10-204 

Appendix IV: GAO Contact and Staff 

Acknowledgments 

Gene Aloise (202) 512-3841 or at aloisee@gao.gov 

In addition to the person named above, individuals who made important 

contributions to this report were Dr. Timothy Persons (Chief Scientist), 

Ned Woodward (Assistant Director), Nancy Crothers, James Espinoza, 

Tracey King, Thomas Laetz, Jay Smale, Vasiliki Theodoropoulos, and Keo 

Vongvanith. 

 Combating Nuclear Terrorism 

GAO Contact 

Staff 

Acknowledgments 

(361001) 
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