EMERGENCY 

PREPAREDNESS

NRC Needs to Better 

Understand Likely 

Public Response to 

Radiological Incidents

at Nuclear Power 

Plants

Report to Congressional Requesters

March 2013

GAO-13-243

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-243, a report to 

congressional requesters

March 2013

EMERGENCY PREPAREDNESS 

NRC Needs to Better Understand Likely Public 

Response to Radiological Incidents at Nuclear Power 

Plants 

Why GAO Did This Study

On March 11, 2011, a tsunami 

severely damaged the Fukushima 

Daiichi nuclear power plant in Japan 

and led to the largest release of 

radiation since the 1986 Chernobyl 

disaster. Japanese authorities 

evacuated citizens within 19 miles of 

the plant. GAO was asked to examine 

issues related to emergency 

preparedness at nuclear power plants. 

This report examines (1) federal, 

licensees’, and local and state 

authorities’ responsibilities in 

radiological emergency preparedness, 

(2) the activities NRC and FEMA take 

to oversee licensee and local and state 

radiological emergency preparedness, 

and (3) NRC and FEMA requirements 

for informing the public on 

preparedness and NRC’s 

understanding of public awareness. 

GAO reviewed laws, regulations, and 

guidance; examined emergency plans 

from licensees and local and state 

authorities; visited four nuclear power 

plants; and interviewed federal, local 

and state, and industry officials.

What GAO Recommends

To better inform radiological 

emergency preparedness efforts, GAO 

recommends that NRC obtain 

information on public awareness and 

likely public response outside the 10-

mile zone, and incorporate insights into 

guidance, as appropriate. NRC 

generally disagreed with GAO’s 

finding, stating that its research shows 

public response outside the zone 

would generally have no significant 

impact on evacuations. GAO continues 

to believe that its recommendation 

could improve radiological emergency 

preparedness efforts and is consistent 

with NRC guidance. 

What GAO Found

The U.S. Nuclear Regulatory Commission (NRC) and the Federal Emergency 

Management Agency (FEMA) are collectively responsible for providing 

radiological emergency preparedness oversight and guidance to commercial 

nuclear power plant licensees and local and state authorities around the plants. 

In general, NRC is responsible for overseeing licensees’ emergency 

preparedness at the plant (on-site), and FEMA is responsible for overseeing 

preparedness by local and state authorities around the plant (off-site). NRC and 

FEMA have also established a 10-mile emergency planning zone around nuclear 

power plants. Licensees are responsible for managing on-site radiological 

emergency preparedness and developing and maintaining plans that define 

activities that the nuclear power plant must take to prepare for and respond to a 

potential incident at the plant. Participating local and state authorities within the 

10-mile zone must develop protective actions for responding to a radiological 

incident, including plans for evacuations and sheltering in place. A recent NRC 

task force considered the adequacy of the zone size and concluded that no 

change was currently needed but will be re-evaluated as part of its lessons 

learned efforts for the Fukushima incident. 

NRC and FEMA conduct activities to ensure that licensees and local and state 

authorities have adequate plans and capabilities to respond to a radiological 

incident. For example, NRC and FEMA review emergency plans developed by 

licensees and local and state authorities to ensure that planning standards are 

met. In addition, NRC and FEMA observe exercises for each plant that licensees 

and local and state authorities conduct every 2 years to demonstrate their ability 

to respond to an incident. NRC also requires licensees to develop estimates of 

how long it would take for those inside the 10-mile zone to evacuate under 

various conditions. Licensees are to provide these evacuation time estimates to 

local and state authorities to use when planning protective action strategies.

NRC and FEMA require licensees and local and state authorities, respectively, to

provide information annually on radiation and protective actions for the public 

only inside the 10-mile zone. Those in the 10-mile zone have been shown to be 

generally well informed about these emergency preparedness procedures and 

are likely to follow directions from local and state authorities in the event of a 

radiological emergency. In contrast, the agencies do not require similar 

information to be provided to the public outside of the 10-mile zone and have not 

studied public awareness in this area. Therefore, it is unknown to what extent the 

public in these areas is aware of these emergency preparedness procedures, 

and how they would respond in the event of a radiological emergency. Without 

better information on the public’s awareness and potential response in areas 

outside the 10-mile zone, NRC may not be providing the best planning guidance 

to licensees and state and local authorities.

View GAO-13-243. For more information, 

contact Frank Rusco at (202) 512-3841 or 

ruscof@gao.gov or Stephen Caldwell at (202)

512-9610 or caldwells@gao.gov
Page i GAO-13-243 Emergency Preparedness

Letter 1 

Background 4

NRC and FEMA Guide Licensees and Local and State Authorities in 

Radiological Emergency Preparedness 9

NRC and FEMA Oversee Radiological Emergency Preparedness by 

Reviewing Plans and Exercises 13

NRC and FEMA Require That the Public within the 10-Mile Zone Be 

Informed Annually about Preparedness, but NRC Has Little 

Information about Public Awareness Outside This Zone 20

Conclusions 25

Recommendation for Executive Action 26

Agency Comments and Our Evaluation 27

Appendix I NRC and FEMA Planning Standards 30

Appendix II Comments from the Nuclear Regulatory Commission 32

Appendix III GAO Contacts and Staff Acknowledgments 33

Abbreviations

EPA Environmental Protection Agency

FEMA Federal Emergency Management Agency

KI Potassium Iodide

NRC Nuclear Regulatory Commission

REP Radiological Emergency Preparedness

Contents 

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Page 1 GAO-13-243 Emergency Preparedness

United States Government Accountability Office

Washington, DC 20548

March 11, 2013

The Honorable Barbara Boxer

Chairman 

Committee on Environment and Public Works 

United States Senate

The Honorable Sheldon Whitehouse

Chairman

Subcommittee on Oversight

Committee on Environment and Public Works 

United States Senate

The Honorable Robert P. Casey, Jr.

United States Senate

The Honorable Bernard Sanders

United States Senate

In March 11, 2011, a 9.0-magnitude earthquake and subsequent tsunami 

devastated northeastern Japan and severely damaged the Fukushima 

Daiichi nuclear power plant. The resulting radiological emergency 

involved the most extensive release of radioactive material at a nuclear 

power plant since the 1986 Chernobyl disaster. Following this release, the 

Japanese government evacuated people within 12 miles of the plant, and 

later extended the evacuation to 19 miles. In total, almost 150,000 people 

were evacuated. On March 16, 2011, the U.S. Nuclear Regulatory 

Commission (NRC)—an independent federal agency that licenses the 

104 U.S. commercial nuclear power reactors and regulates their safe 

operation and security—recommended that U.S. citizens within 50 miles 

of the Fukushima Daiichi plant evacuate.1

 

1

NRC grants licenses to companies that may operate more than one commercial nuclear 

power plant. For purposes of this report, we refer to both licensed companies and the 

physical power plants as licensees. 

NRC officials said that this 

recommendation was a conservative estimate based on limited and often 

 
 

Page 2 GAO-13-243 Emergency Preparedness

conflicting information about the exact conditions of the reactors and 

spent fuel pools at the power plant.2

The Japanese experience raised questions in the United States about 

radiological emergency preparedness for commercial nuclear power 

plants,3

Federal preparedness guidance generally states that planning for 

evacuations should extend to 10 miles from the plant because NRC 

studies have shown that health risks to the public outside of 10 miles 

would be low in a radiological incident. NRC and FEMA officials told us 

that if conditions warranted, current planning would allow evacuation to 

occur beyond 10 miles. Nationwide, each of the 65 operating commercial 

nuclear power plants has a 10-mile emergency planning zone around the 

particularly as populations near plants have grown. NRC and the 

Federal Emergency Management Agency (FEMA), within the Department 

of Homeland Security (DHS), are the two primary federal agencies 

responsible for radiological emergency preparedness for U.S. nuclear 

power plants and their surrounding areas. The Atomic Energy Act of 

1954, as amended, requires that NRC grant licenses only when assured 

that the public’s health and safety are adequately protected. In carrying 

out this requirement, NRC makes radiological health and safety 

determinations on the overall state of emergency preparedness for a 

commercial nuclear power plant site—both at the plant (on-site) and in 

the area surrounding the plant (off-site). FEMA is responsible for leading 

the nation’s disaster preparedness activities. In the context of radiological 

preparedness, FEMA is responsible for assessing off-site preparedness 

and providing guidance and assistance to local and state authorities 

through its Radiological Emergency Preparedness (REP) program. In 

making its overall determinations about radiological public health and 

safety for a commercial nuclear power plant, NRC reviews FEMA’s 

assessments of off-site emergency preparedness as part of NRC’s 

licensing and regulatory requirements.

 

2

In this report, when we use the term power plant, we are referring to an entire site, and 

nuclear power reactors are the individual units at each site. Some nuclear plants store 

spent nuclear fuel in specially designed pools of water, and a fire at a spent fuel pool 

could result in the widespread release of radiation.

3

For the purposes of this report, radiological emergency preparedness involves a 

combination of planning, resources, training, conducting exercises, and organizing to 

build, sustain, and improve operational capabilities for responding to an incident at a 

commercial nuclear power plant. 
 

Page 3 GAO-13-243 Emergency Preparedness

plant; in total, these zones include at least 490 local and state authorities, 

according to NRC and FEMA officials.4,5 These plants and surrounding

local and state authorities develop plans for evacuations and other 

protective actions, such as sheltering in place, to protect public health and 

safety during an incident in which there is a potential for radiological 

release.6

In this context, you asked us to review radiological emergency 

preparedness for commercial nuclear power plants. The objectives of this 

report were to (1) describe the roles and responsibilities of NRC and 

FEMA, the licensees, and local and state authorities for radiological 

emergency preparedness; (2) describe the actions NRC and FEMA take 

to oversee licensee and local and state radiological emergency 

preparedness; and (3) examine NRC and FEMA requirements for 

informing the public about preparedness and NRC’s understanding of 

public awareness. This report focuses on NRC, FEMA, and local and 

state efforts inside the 10-mile emergency planning zone, where the 

majority of radiological emergency preparedness planning takes place.

To address these three objectives, we reviewed relevant federal laws and 

regulations and NRC and FEMA guidance documents, and local and 

state authorities’ radiological emergency response plans associated with 

the four commercial nuclear power plants we visited including Indian 

Point Energy Center in New York, St. Lucie Nuclear Power Plant in 

Florida, and Limerick Generating Station in Pennsylvania. We selected 

this nonprobability sample of nuclear power plants based on multiple 

criteria. These criteria included plants that (1) had over 1 million people 

within 50 miles and over 200,000 people within 10 miles and (2) were 

located in different FEMA regions. In addition, we wanted to observe a 

plant conducting a radiological emergency preparedness exercise, which 

 

4

For the purposes of this report, local and state authorities include any local, state, or 

tribal government; supporting private industry and voluntary organizations; and any other 

off-site response organization responsible for carrying out emergency functions in the area 

surrounding the plant during a radiological emergency.

5

There are 104 operating reactors at the 65 operating commercial power plants.

6

Protective actions include measures to avoid or reduce the public’s exposure to radiation 

from a release of radioactive material, such as sheltering in place, evacuation, and/or use 

of potassium iodide (KI) in pill or liquid form. 
 

Page 4 GAO-13-243 Emergency Preparedness

each plant must conduct once every 2 years.7

We conducted this performance audit from February 2012 to March 2013 

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.

Congressional requesters 

also expressed interest that we increase our regional sample by visiting a 

plant outside of the East Coast. As a result, we selected the San Onofre 

Nuclear Generating Station because it was the only plant outside the East 

Coast that met some of our criteria, including that it has the second 

highest population in the country within 50 miles of a plant. We 

interviewed NRC and FEMA officials from headquarters and the regional 

offices in which the plants were located, the Environmental Protection

Agency (EPA), licensee officials for the four plants we visited, and local 

and state authorities responsible for emergency preparedness in areas 

around the plants. We observed a radiological emergency preparedness 

exercise to determine how the licensee and federal, local, and state 

stakeholders conduct and evaluate preparedness exercises. We also 

reviewed the four power plants’ studies of estimated times for evacuation 

from the area around the plants to understand how these studies inform 

updates to local and state radiological emergency response plans. To 

determine how radiological emergency preparedness information is to be 

communicated to the public, we reviewed NRC and FEMA guidance on 

how licensees and local and state authorities should provide information 

to the public. We also interviewed federal, state, and local officials to 

understand how the public is informed of evacuation planning and 

radiological emergency preparedness.

The key federal agencies involved in emergency preparedness at 

commercial nuclear power plants include NRC and FEMA. NRC makes 

radiological health and safety determinations on the overall state of 

emergency preparedness for a commercial nuclear power plant site—

both at the plant (on-site) and in the area surrounding the plant (off-site). 

 

7

Because this was a nonprobability sample, the information collected during these site 

visits cannot be generalized to all 65 commercial nuclear power plants but provides 

illustrative information.

Background 
 

Page 5 GAO-13-243 Emergency Preparedness

In addition, FEMA is responsible for providing guidance and assistance to 

local and state authorities and for assessing off-site radiological 

emergency preparedness and communicating those assessments to 

NRC. EPA also supports radiological emergency preparedness by 

developing a radiation guide that helps licensee officials and local and 

state authorities make decisions during a radiological incident at a 

commercial nuclear power plant.

In 1978, a joint NRC and EPA task force issued guidance that provided a 

planning basis for off-site preparedness around commercial nuclear 

power plants8 and, in this guidance, the agencies established two 

emergency planning zones. NRC defines emergency planning zones as 

areas for which planning is needed to ensure that prompt and effective 

actions can be taken to protect the public in the event of a radiological 

incident at a nuclear power plant.9

• 10-Mile Plume Exposure Pathway Emergency Planning Zone.

According to the guidance, the principal health risks in this zone 

include direct exposure to radiation and inhalation exposure from the 

passing radioactive plume. For the plume exposure pathway, 

evacuation or shelter in place should be the primary protective 

actions. The radius for the emergency planning zone implies a circular 

area, but the actual shape can depend upon the characteristics of a 

particular site. For example, local authorities around the Limerick 

Generating Station in Pennsylvania told us that the Pennsylvania 

Turnpike was used as a boundary for part of the 10-mile zone. This 

road established a well-known landmark as a boundary that could be 

referenced when communicating instructions to the public about a 

radiological incident.

In 1980, NRC and FEMA directed that 

this emergency planning zone guidance should be incorporated into 

emergency preparedness documents and planning. The 1978 guidance 

established the following two emergency planning zones:

 

8

NRC and EPA, Planning Basis For the Development of State and Local Government 

Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants, 

NUREG-0396/EPA 520/1-78-016 (Washington, D.C.: December 1978).

9

NRC guidance uses the term “incident” instead of “accident” in discussing radiological 

planning and preparedness because an intentional hostile action directed at a nuclear site 

could become the direct cause of a radiological emergency.

Emergency Planning Zones
 

Page 6 GAO-13-243 Emergency Preparedness

• 50-Mile Ingestion Exposure Pathway Emergency Planning Zone.

According to the guidance, the principal health risk in this zone is 

exposure from ingesting contaminated water or foodstuffs such as 

milk, fresh vegetables, or fish. In this pathway, health risks would 

come from longer term problems associated with contaminated food 

and water. Early actions to prevent contamination should include 

removing cows from pasture and putting them on stored feed.

According to NRC officials, the 10-mile and 50-mile emergency planning 

zones established in 1978 remain adequate, as indicated by recent NRC 

studies examining potential consequences at two nuclear power plants,10

Protective actions are designed to decrease the time of exposure to 

radiation so that the benefits of the action offset any undesirable 

consequences, increase the distance from a radioactive source, provide 

shielding from the radiation plume, or limit ingestion of contaminated 

foodstuffs. Local and state authorities can implement a number of 

protective actions within the 10-mile emergency planning zone, including 

evacuating the public from areas that the projected plume is expected to 

cover, sheltering the public in homes or other structures, and providing 

potassium iodide to the public and emergency workers, if necessary, to 

provide some protection from an internal radiation exposure of radioactive 

iodine.

as well as public health impacts from the March 1979 incident at Three 

Mile Island in Pennsylvania and the 2011 Fukushima incident.

11

 

10NRC, State of the Art Reactor Consequence Analyses Project Volume I: Peach Bottom 

Integrated Analysis, NUREG/CR-7110 (Albuquerque, New Mexico: January 2012). The 

Peach Bottom Atomic Power Station is located in Peach Bottom Township, Pennsylvania.

NRC, State of the Art Reactor Consequence Analysis Project Volume 2: Surry Integrated 

Analysis NUREG/CR-7110 (Albuquerque, New Mexico: January 2012). The Surry Power 

Station is located in Surry County, Virginia.

Further, for any given radiological incident, the same protective 

action may not necessarily be appropriate for all areas within the 10-mile 

zone. For example, the public in areas of the zone closest to the plant 

may be instructed to evacuate, while the public in other parts of the zone 

may be told to shelter in place. The appropriate protective action will 

11According to NRC officials, the use of iodine to protect against the effects of radiation is 

recognized as an effective supplement to evacuation for situations involving radiation 

releases when evacuation cannot be implemented, or if exposure were to occur as a 

result of evacuation. Potassium iodide’s usefulness as a protective measure is limited and 

only affords protection for the thyroid gland from an internal radiation exposure of 

radioactive iodine. It does not protect the body from radiation exposure or radiation dose. 
 

Page 7 GAO-13-243 Emergency Preparedness

depend on a number of factors, including the projected beginning and 

duration of the radiological release, composition and direction of the 

release, weather conditions, and time of day. According to FEMA 

guidance, certain weather conditions, plume direction, or an event caused 

by a terrorist attack may pose an undue risk to evacuation and could 

make sheltering in place the preferred protective action.12

The incident at the Three Mile Island nuclear power plant near 

Middletown, Pennsylvania, on March 28, 1979, was the most serious in 

U.S. commercial nuclear power plant operating history, even though it led 

to no deaths or injuries to plant workers or members of the nearby

community. In the incident, equipment malfunctions, design-related 

problems, and worker errors led to a partial meltdown of the core of one 

reactor and small off-site releases of radioactivity. Following the March 

1979 incident, the White House transferred the federal lead role for offsite emergency planning and preparedness activities from NRC to 

FEMA13 and, in 1980, NRC and FEMA entered into a memorandum of 

understanding to establish a framework of cooperation in matters of 

planning of radiological emergency preparedness.14

 

12FEMA, Radiological Emergency Preparedness Program Manual (April 2012).

This memorandum 

created a joint NRC and FEMA Steering Committee to implement and 

maintain these efforts. FEMA was directed to coordinate all federal 

planning for the off-site impact of radiological incidents and take the lead 

for assessing local and state authorities’ radiological emergency response 

plans, make findings and determinations on the adequacy and capability 

of implementing off-site emergency plans, and communicate those 

findings and determinations to NRC. NRC agreed to review those FEMA 

findings and, in conjunction with NRC findings for licensees’ emergency 

plans, determine the overall state of emergency preparedness. NRC uses 

these overall determinations to make radiological health and safety 

13See 44 C.F.R. § 350.3(a) (2012), NRC and FEMA, Memorandum of Understanding 

Between NRC and FEMA To Accomplish a Prompt Improvement in Radiological 

Emergency Planning and Preparedness, 45 Fed. Reg. 5847 (Jan. 24, 1980) (referencing 

directive).

1444 C.F.R. pt. 353 app. A “Memorandum of Understanding Between Federal Emergency 

Management Agency and Nuclear Regulatory Commission.” (2012) (codifying current 

memorandum of understanding, as last revised 2003).

NRC and FEMA 

Framework for 

Radiological Emergency 

Preparedness
 

Page 8 GAO-13-243 Emergency Preparedness

decisions when it issues licenses to nuclear power plants and during 

continuous monitoring of the overall state of radiological preparedness.

To manage its new responsibility for off-site emergency planning and 

preparedness in areas around commercial nuclear power plants, FEMA 

established the REP program. The REP program coordinates FEMA’s 

effort to provide policies and guidance to local and state authorities to 

ensure that they have adequate capabilities to respond and recover from 

a radiological incident at a commercial nuclear power plant. The REP 

program has two funding sources: (1) a flat fee paid by licensees that is 

the same for each power plant and (2) variable fees paid by licensees to 

cover the cost of REP program activities associated with biennial 

exercises that each nuclear power plant and relevant local and state 

authorities must conduct every 2 years demonstrating the capabilities in 

their radiological emergency response plans. Local and state participation 

in off-site radiological emergency preparedness is voluntary, but 

participation in the program necessitates that local and state authorities 

adhere to the program’s requirements set forth in federal regulations and 

guidance.15 FEMA officials told us that all local and state governments 

that have a 10- or 50-mile commercial nuclear power plant emergency 

planning zone within their boundaries participate in the REP program. If 

local and state authorities opted not to participate in the REP program, 

licensees would have to demonstrate sufficient capabilities to fulfill off-site

emergency response responsibilities.16

In the aftermath of the Fukushima incident, NRC established the NearTerm Task Force in March 2011. The goal of the task force was to review 

NRC processes and regulations to determine whether additional 

improvements were needed to NRC’s regulatory system and to make 

recommendations for these improvements. The task force review resulted 

in 12 recommendations to NRC, including 3 related to strengthening 

radiological emergency preparedness. For example, the task force 

observed gaps in public awareness in the United States following the 

incident at Fukushima. It recommended that, as part of a follow-on 

review, NRC should pursue emergency preparedness topics related to 

 

1544 C.F.R. pt. 350 (2012); FEMA, Radiological Emergency Preparedness Program 

Manual, (April 2012).

1610 C.F.R. 50.47 § (c)(1) (2012).

NRC Task Force 

Established after 

Fukushima 
 

Page 9 GAO-13-243 Emergency Preparedness

decision making, radiation monitoring, and public education, particularly 

to increase education and outreach in the vicinity of each nuclear power 

plant in the areas of radiation, radiation safety, and the appropriate use of 

potassium iodide. With regard to the size of the emergency planning 

zones, NRC officials told us that the task force considered the existing 

planning structure, including the 10-mile plume exposure pathway and 

50-mile ingestion exposure pathway emergency planning zones, and 

found no basis for recommending a change.17

NRC and FEMA are responsible for guiding licensees and local and state 

authorities in radiological emergency preparedness. Specifically, NRC 

and FEMA’s regulations and guidance establish the framework for on-site 

and off-site radiological emergency preparedness. Licensees manage 

preparedness on-site, and local and state authorities manage 

preparedness off-site.

NRC and FEMA’s regulations for radiological emergency preparedness, 

originally issued in 1980 and 1983, respectively, are based upon 1980 

guidance developed by a joint NRC and FEMA Steering Committee.18,19

 

17NRC officials told us that the agency might consider a review of the basis for the 

emergency planning zone size in the future.

The regulations include 16 planning standards that nuclear power plants 

and local and state authorities are to address in their radiological 

emergency response plans. The standards require such actions as 

assigning responsibilities for the licensee and local and state authorities 

within the 10-mile emergency planning zone; establishing procedures on 

when and how the licensee is to notify local and state authorities and the 

public; developing a range of protective actions for emergency workers 

and the public within this emergency planning zone, such as evacuations 

or recommendations that the public remain indoors; and providing and 

maintaining adequate emergency facilities and equipment to support the 

emergency response. (App. I lists the 16 planning standards.) NRC and 

1810 C.F.R. § 50.47(b) (2012); 44 C.F.R. § 350.5 (b)(2012).

19NRC and FEMA, Criteria for Preparation and Evaluation of Radiological Emergency 

Response Plans and Preparedness in Support of Nuclear Power Plants, NUREG0654/FEMA-REP-1, Rev. 1 (Washington, D.C.: November 1980).

NRC and FEMA Guide 

Licensees and Local 

and State Authorities 

in Radiological 

Emergency 

Preparedness 

NRC and FEMA’s 

Regulations and Guidance 

Establish the Framework 

for On-site and Off-site 

Radiological Emergency 

Preparedness
 

Page 10 GAO-13-243 Emergency Preparedness

FEMA have published four supplements that support and expand on the 

1980 guidance, including a 2011 supplement that provides guidance to 

(1) licensees on how to develop site-specific procedures for protective 

action recommendations and (2) local and state authorities on how to 

prepare for protective actions.20

FEMA has issued guidance for local and state authorities that includes a 

2012 update to the REP program manual, the principal source of policy 

and guidance relating to off-site radiological emergency preparedness. 

The manual interprets the planning standards established in 1980 and 

provides additional detail to local and state authorities on what FEMA 

expects them to include in their radiological emergency response plans. 

In addition, the manual provides criteria that FEMA uses to evaluate the 

ability of local and state governments to implement their emergency 

plans. Numerous FEMA and local officials we spoke with said that 

counties that participate in REP planning are much better prepared for 

other nonradiological emergencies, like hurricanes, because of the 

planning and exercises required by the REP program.

NRC and FEMA officials told us that they 

are in the early stages of developing new guidance to update the planning 

standards and associated guidance originally developed in 1980—an 

effort that they expect will take 4 to 5 years.

 

20NRC and FEMA, Criteria for Preparation and Evaluation of Radiological Emergency 

Response Plans and Preparedness in Support of Nuclear Power Plants: Guidance for 

Protective Action Strategies, NUREG-0654/FEMA-REP-1, Rev. 1 Supplement 3 

(Washington, D.C.: November 2011).
 

Page 11 GAO-13-243 Emergency Preparedness

Licensees are responsible for managing on-site radiological emergency 

preparedness and developing and maintaining radiological emergency 

response plans that define specific actions and activities that the nuclear 

power plant must take to prepare for and respond to a potential incident 

at the plant. For example, according to the NRC regulations, the licensee 

must have met certain requirements, including the following:

• defined on-site emergency response staff responsibilities and 

maintained adequate staffing in key areas at all times,

• developed a standard emergency classification and action level 

scheme to help local and state authorities in determining initial off-site 

response measures,

• established notification procedures for the licensee to communicate 

emergency information to off-site local and state emergency 

organizations, and

• provided adequate methods and systems for assessing and 

monitoring actual or potential off-site consequences from a 

radiological incident.

Under the NRC regulations, the licensee is also responsible for 

recommending protective actions during a radiological incident generally 

to be implemented by the local and state authorities responsible for offsite radiological emergency preparedness—for example, recommending 

which communities should evacuate, and which should shelter in place—

to minimize and/or avoid exposure to a radiological release. The licensee 

is to make these protective action recommendations based on specific 

plant conditions during the emergency, and the potential for, or actual 

amounts of, radiation being released into the atmosphere. For example, 

the representatives of the licensee at the San Onofre Nuclear Generating 

Station in San Clemente, California, told us that they consider wind 

direction, evacuation impediments, and information about how long the 

radiological release would occur and its projected dose when making 

protective action recommendations.

FEMA regulations and guidance apply where local and state authorities 

take responsibility for managing off-site radiological emergency 

preparedness efforts for the public near nuclear power plants. 

Specifically, local and state authorities develop radiological emergency 

response plans for their jurisdictions using the planning standards and 

Licensees Manage 

Emergency Preparedness 

On-site 

Local and State Authorities 

Manage Emergency 

Preparedness Off-site
 

Page 12 GAO-13-243 Emergency Preparedness

guidance detailed in the REP program manual. These off-site plans are to 

define specific actions and activities that local and state emergency 

response organizations should take to protect the public from a potential 

incident at the nearby nuclear power plant. For example, according to 

FEMA regulations and guidance, appropriate local and state 

organizations are to take a number of planning actions, including the 

following:

• identifying and assigning the principal roles, such as the 

responsibilities for the emergency management and law enforcement 

personnel who lead the emergency planning, preparedness, and 

response functions, and the support roles for federal agencies (e.g., 

FEMA) and volunteer organizations (e.g., the American Red Cross);

• coordinating classifications for different levels of emergencies and 

protective action strategies that are consistent with those established 

by the nearby nuclear power plant;

• establishing and describing the methods, both primary and backup, 

that are to be used to communicate between all local and state 

governments within the emergency planning zone and with the public; 

and

• establishing and describing an emergency operations center for use in 

directing and controlling response functions.

Differences in state laws and governing structures, as well as differences 

in FEMA’s regional offices, can result in off-site emergency plans that 

meet FEMA regulations in different ways.21

 

21FEMA is composed of 10 regional offices that oversee FEMA activities. FEMA officials 

told us that regional REP offices have flexibility when interpreting FEMA guidance in order 

to reflect regional conditions.

In some states, local officials 

lead off-site radiological emergency preparedness activities, with support 

from state emergency officials; in other states, radiological emergency 

preparedness activities are directed at a regional or state level. For 

example, the municipal, county, and school district jurisdictions near the 

Limerick Generating Station in Limerick, Pennsylvania, lead their own 

jurisdictions’ activities for radiological emergency preparedness with state 

support, whereas the jurisdictions near the San Onofre Nuclear 

Generating Station in San Clemente, California, work together on a 
 

Page 13 GAO-13-243 Emergency Preparedness

regional, interjurisdictional planning committee to jointly develop plans 

and policies and to decide on radiological emergency preparedness.

NRC and FEMA oversee licensees’ and local and state authorities’ 

radiological emergency preparedness, respectively, by reviewing 

emergency plans. The two agencies also oversee licensees and local and 

state authorities by assessing their respective capabilities during biennial 

emergency preparedness exercises. These oversight efforts are intended 

to provide reasonable assurance that adequate measures can and will be 

taken in the event of a radiological emergency.

Under its responsibilities to protect the radiological health and safety of 

the public, NRC must find that there is reasonable assurance that 

adequate protective measures can and will be taken in the event of a 

radiological emergency before it issues an operating license for a nuclear 

power reactor.22

NRC bases its assessment of a licensee’s emergency planning adequacy 

on its review of the licensee’s plans to ensure that they meet the planning 

standards established in NRC regulations.

NRC is to base its overall finding of reasonable 

assurance on (1) its assessment of the adequacy of a licensee’s on-site 

emergency plans and (2) a review of FEMA findings about whether local 

and state off-site emergency plans are adequate and whether there is 

reasonable assurance they can be implemented.

23

 

22NRC issues licenses for commercial nuclear power reactors to operate for 40 years. 

Under current regulations, licensees may renew their licenses for up to 20 years. 

Licensees seeking operating license renewal of reactors do not require a new finding of 

reasonable assurance.

According to the 

memorandum of understanding between NRC and FEMA, once it grants 

an operating license, NRC maintains its finding of reasonable assurance 

by overseeing the licensee’s on-site preparedness and communicating

with FEMA about off-site preparedness. A licensee may make changes to

its emergency plans without NRC approval if the licensee conducts and 

retains an analysis of the changes and its determination that the changes 

do not reduce the plan’s effectiveness. If an emergency plan change is 

23NRC officials told us that they also review license conditions for the facility.

NRC and FEMA 

Oversee Radiological 

Emergency 

Preparedness by 

Reviewing Plans and 

Exercises 

NRC Reviews Licensees’ 

Emergency Plans, and 

FEMA Evaluates Local and 

State Plans

NRC Reviews
 

Page 14 GAO-13-243 Emergency Preparedness

expected to result in a reduction in effectiveness, the licensee must 

provide the plan changes and supporting documentation to NRC for 

review and approval to ensure the plan continues to meet the required 

planning standards. For example, if an off-site fire department is identified 

and relied upon in the licensee’s emergency plan, but is no longer able to 

respond to the site because of conflicting responsibilities assigned in local 

emergency plans, then the licensee must identify plan changes that 

ensure that the original capability exists in some form. To help maintain 

its finding of reasonable assurance on-site, NRC has established a 

reactor oversight process that describes the agency’s program to inspect, 

measure, and assess the safety performance of commercial nuclear 

power plants and to respond to any decline in performance. One of the 

cornerstones of this process is emergency preparedness, and NRC 

measures the effectiveness of power plant staff in carrying out emergency 

plans and testing licensee emergency plans during biennial exercises. 

NRC’s resident inspectors, who are permanently located at the plant, as 

well as inspectors from its regional offices, are to ensure that the licensee 

is effectively implementing and reviewing emergency preparedness, 

according to NRC’s reactor oversight process.

As part of the licensing process, NRC also requires nuclear power plants 

to develop studies of estimated evacuation times in order to identify 

potential challenges to efficient evacuation in the event of a nuclear 

power plant incident. These studies are to include an analysis of the time 

required to evacuate different portions of a nuclear power plant’s 10-mile 

planning zone.24

 

2410 C.F.R. pt. 50 app. E (IV) (2012).

Licensees are to (1) use these evacuation time 

estimates in formulating protective action recommendations and (2) 

provide the estimates to local and state authorities for use in developing 

off-site protective action strategies. To account for demographic changes 

around commercial nuclear power plants, NRC revised regulations, 

effective December 2011, to require that these evacuation time estimates 

be updated (1) after every decennial census and (2) any time an increase 

in the permanent population results in an evacuation time increase of 25 

percent or 30 minutes, whichever is less for one of the potential 

evacuation areas. In addition, 2011 NRC guidance directs that evacuation 

time estimates include a consideration of shadow evacuations, defined as 

an evacuation of the public in areas outside an officially declared 
 

Page 15 GAO-13-243 Emergency Preparedness

evacuation area.25

As stated above, NRC considers FEMA’s reviews of each local and state 

authority’s emergency plan for off-site preparedness during the initial 

licensing process. In reviewing these plans, FEMA uses the planning 

standards and evaluation criteria collectively identified in its regulations 

and guidance to determine whether these off-site plans are adequate to 

protect public health and safety by providing reasonable assurance that 

appropriate protective measures can be taken off-site in the event of a 

radiological emergency. In addition, the local and state authorities must 

participate in an initial full-scale exercise with the licensee.

Specifically, the guidance states that these evacuation 

time estimate studies should include a shadow evacuation consideration 

of 20 percent of the population out to 15 miles away from the nuclear 

power plant. In addition, NRC guidance states that the shadow population 

consideration is to account for the extent to which this population’s 

evacuation would impede the evacuation of those under evacuation 

orders.

26 FEMA 

approves the authorities’ plans as being adequate if the plans and the 

exercise provide reasonable assurance that the plans are adequate and 

can be implemented.27

After the initial FEMA finding that the off-site emergency plans and their

capabilities provide reasonable assurance about off-site radiological 

emergency preparedness, FEMA relies on a combination of other 

activities to ensure that local and state authorities maintain this 

reasonable assurance. In particular, FEMA relies on the following:

FEMA then communicates this approval or 

disapproval to the state and to NRC for consideration in the licensing 

process.

 

25NRC, Criteria for Development of Evacuation Time Estimate Studies, NUREG/CR-7002 

(Albuquerque, New Mexico: November 2011).

26To support the initial licensing process, the licensee and local and state authorities must 

conduct a full-scale exercise. According to FEMA guidance, the full-scale exercise should 

include all response organizations that would be involved in a response to an incident at 

the plant, but subsequent biennial exercises may not need to include all response 

organizations. 

27A public meeting must also be held near the power plant to, among other things, 

acquaint the public with the plans and answer questions about FEMA’s review of the plan 

and the exercise.

FEMA Reviews 
 

Page 16 GAO-13-243 Emergency Preparedness

• Biennial exercises. Each nuclear power plant and its relevant local 

and state authorities must conduct an exercise every 2 years that 

demonstrates their abilities to implement their respective emergency 

plans.28 Local and state authorities that participate in the biennial 

exercises submit their emergency plans to FEMA staff before the 

exercises, and FEMA evaluators review the plans and assess off-site 

performance based on the activities identified in those plans.

• Annual letter of certification. To help FEMA determine whether local 

and state authorities’ plans and implementation activities provide 

reasonable assurance about off-site radiological preparedness, states 

that participate in the REP program annually submit a letter of 

certification to FEMA providing assurance that all required activities 

have been undertaken as appropriate by local and state authorities. 

Among other things, the state is asked to certify that the plans have 

been reviewed for accuracy and completeness and provide 

documentation that supports off-site planning, such as the information 

that authorities are required to provide annually to those in the 10-mile 

emergency planning zone (e.g., establishing classifications for 

different levels of emergencies and protective action instructions)

• Staff assistance visits. FEMA assigns a representative to serve as the 

primary advisor for the local and state authorities near each nuclear 

power plant, and the FEMA representatives are to visit local and state 

authorities to answer questions and assist in planning and exercise 

preparation. Local authorities near the Limerick Generating Station in 

Limerick, Pennsylvania, told us that they are in contact with FEMA 

representatives several times a month, including during site 

assistance visits, and feel they have a well-established relationship 

with FEMA.

FEMA may also review off-site emergency preparedness following events 

such as electric grid blackouts, intentional harm, or natural disasters in 

the vicinity of commercial nuclear power plants, which can result in 

infrastructure damage that can degrade the capabilities of local and state 

authorities to respond to a radiological incident. For example, natural 

disasters that destroy roads or bridges around a plant could affect the 

 

28Licensees and local and state authorities told us they conduct other drills and exercises 

throughout the year to train emergency response staff and ensure emergency 

preparedness is adequate.
 

Page 17 GAO-13-243 Emergency Preparedness

ability of local and state authorities to effectively conduct evacuations. 

According to the memorandum of understanding between NRC and 

FEMA, FEMA is to (1) inform NRC promptly if FEMA questions the 

continued adequacy of off-site emergency preparedness, (2) review offsite radiological emergency preparedness if it believes that a review is 

necessary to determine whether off-site preparedness remains adequate, 

and (3) inform NRC in writing about the results of its review. NRC is to 

consider the information FEMA provides, in addition to its assessment of 

the licensee’s facility, in deciding to allow the restart or continued 

operation of an affected operating nuclear power plant. For example, after 

Hurricane Katrina in 2005, the Waterford Nuclear Generating Station in 

Killona, Louisiana, was shut down for about 2 weeks. FEMA conducted a 

review of local and state authorities’ ability to respond to a radiological 

incident and concluded that off-site radiological preparedness was 

adequate to justify restarting the plant.

NRC and FEMA also oversee radiological emergency preparedness by 

reviewing the biennial exercises conducted by licensees and local and 

state authorities.29 According to NRC and FEMA guidance, these 

exercises simulate incidents at nuclear power plants that require 

coordination between licensees, local and state authorities, and federal 

entities, and provide the opportunity for NRC and FEMA officials to 

evaluate the emergency plans in action. According to NRC guidance, 

NRC’s inspectors are to observe these biennial exercises to evaluate the 

adequacy of the licensee’s performance, including the operation of the 

alert and notification system and the individual performance of the 

emergency response staff.30

 

29According to FEMA and NRC officials, these exercises are usually conducted 

simultaneously, but simultaneous exercises are not required. NRC officials told us that this 

flexibility is provided to address circumstances in which there are multiple commercial 

nuclear power plant sites within a state, or two licensees on the same site.

In addition, NRC inspectors are to evaluate 

the licensee’s ability to assess and critique its own performance to identify 

and correct weaknesses observed during the exercise. For example, one 

NRC inspector told us that he observes how the licensee responds to an 

escalation of events, prepares and issues protective action 

recommendations, and makes assessments of radiological doses during 

an exercise. The inspector also said that he observes whether the 

30Licensees are required by the planning standards to have procedures to notify local and 

state authorities and emergency personnel.

NRC and FEMA Oversee 

and Evaluate Radiological 

Emergency Preparedness 

Exercises
 

Page 18 GAO-13-243 Emergency Preparedness

licensee is able to identify its own performance problems and then takes 

the necessary corrective actions.

With respect to off-site evaluation, under agency guidance, FEMA 

evaluators are to observe the conduct of local and state authorities and 

write detailed after-action reports that identify planning and performance 

problems, if any. FEMA is also to work with the local and state authorities 

to develop an improvement plan that contains information on how the 

authorities will improve performance or correct problems identified in the 

after-action report, the personnel responsible for specific actions, and an 

anticipated timeline for improvement or correction. Local and state 

authorities are expected to correct the problem or redemonstrate a 

capability within a specified time frame.31

Licensees develop exercise scenarios ahead of biennial exercises with 

input from local and state authorities to provide the maximum training 

opportunities for all the entities involved.

If the local and state authorities 

do not address the problems, FEMA officials told us that they would notify 

NRC that off-site preparedness was insufficient to protect public health 

and safety. Furthermore, NRC officials told us that they could require the 

plant to shut down until the off-site problems were addressed but that 

they have never required such a shutdown.

32

 

31The time frames vary depending on the type of problem identified and the steps taken, if 

any, to address them.

However, those who 

participate in the exercises, including power plant staff, do not know about 

the contents of the exercise scenario beforehand. In addition, an official 

with one local authority near the St. Lucie Nuclear Power Plant told us 

that they have injected certain incidents into an ongoing exercise, such as 

a disabled truck on a freeway, to test elements of their emergency plans 

that may not otherwise be included in the initial scenario. Exercises begin 

when an initiating event is simulated at the nuclear power plant in 

accordance with the scenario the licensee developed. Plants must be 

able to assess, classify, and declare an emergency condition within 15 

minutes after plant operators have information indicating that an 

emergency condition exists. Plants are then to provide local and state 

authorities with an emergency classification level that identifies the 

severity of the event and the actions that could be taken. The 

32FEMA officials told us that FEMA and NRC also participate in some aspects of scenario 

development.
 

Page 19 GAO-13-243 Emergency Preparedness

classification levels are considered trigger points for surrounding 

authorities, so that when a certain level is set, a series of actions must be 

performed. The classification levels are the following:

• Notification of unusual event—a potential degradation of safety or 

indication of a security threat that involves no expected release of 

radiation unless further degradation occurs.

• Alert—an actual or potential substantial degradation of safety at the 

plant or a security event that involves probable life threatening risk to 

site personnel or damage to site equipment, and any release is 

expected to be limited to small fractions of EPA protective action 

guide exposure levels.33

• Site area emergency—an actual or likely major failure of plant 

protection equipment that protects the public or a security event that 

could lead to the likely failure of or prevents access to plant protection 

equipment. Any radiation releases are not expected to exceed 

exposure levels from the EPA protective action guides beyond the site 

boundary. A site area emergency may, for example, trigger 

precautionary evacuations of schools and parks.

• General emergency—an actual or imminent substantial core 

degradation or melting with the potential for loss of containment of 

radiation or security events that result in an actual loss of physical 

control of the facility, with radiation releases reasonably expected to 

exceed EPA protective action guide exposure levels off-site for more 

than the immediate area. The Three Mile Island incident is the sole 

general emergency ever to have occurred in the United States. Since 

the Three Mile Island incident, in Pennsylvania, it is state policy to 

conduct a single protective action for the full 10-mile emergency 

planning zone whenever a general emergency at a nuclear power 

plant in the state is declared.

 

33EPA developed a Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents in 1980 to help local and state authorities determine when to take protective 

actions in response to an airborne plume during the early phase of an incident at a nuclear 

power plant. A protective action guide represents the projected radiation dose to 

individuals that triggers the need for protective actions from a release of radioactive 

material. EPA officials told us that protective action guides do not imply acceptable levels 

of risk or a boundary between safe and unsafe conditions, but they represent the 

approximate radiation levels at which certain protective actions are justified.
 

Page 20 GAO-13-243 Emergency Preparedness

If the situation on-site reaches a level where local and state authorities 

should consider taking protective actions, the licensee is to recommend 

the protective actions that off-site authorities should take. The authority 

responsible for decision making is to take the licensee’s recommendation 

into consideration, together with other considerations, such as 

radiological dose assessment readings. We noted that local and state 

authorities near the four power plants we visited have dose assessment 

teams that are to take radiation readings in the area during an incident 

and coordinate radiation readings with licensee dose assessment teams 

to help assess the situation and to help with overall decision making. In 

some states, the local counties and cities have the primary role in making 

protective action decisions. For example, around the St. Lucie Nuclear 

Power Plant in Florida, county officials for several counties told us that 

they develop individual emergency plans, but they work together during 

an emergency to coordinate the appropriate protective action decision for 

the area. According to local and state authorities around the San Onofre 

Nuclear Generating Station in California, two counties, three cities, one 

U.S. Marine Corps base, the California Department of Parks and 

Recreation, and the power plant licensee formed an interjurisdictional 

planning committee to coordinate an emergency plan for the area. 

Members of this committee collectively decide on the protective action to 

take during an incident, based on the licensee’s protective action 

recommendation.

NRC and FEMA require licensees and local and state authorities to 

provide emergency preparedness information annually to the public within 

the 10-mile emergency planning zone, and NRC has studied public 

awareness within the zone. A 2008 NRC study found that the public 

within the 10-mile zone is generally aware of emergency preparedness 

and likely to follow instructions, but NRC has not studied likely responses 

to an incident outside this zone. Without knowing reactions outside the 

10-mile zone, NRC cannot be confident that its estimates of shadow 

evacuations outside the 10-mile zone provide a reasonable basis for 

planning off-site protective action strategies.

NRC and FEMA 

Require That the 

Public within the 10-

Mile Zone Be 

Informed Annually 

about Preparedness, 

but NRC Has Little 

Information about 

Public Awareness 

Outside This Zone 
 

Page 21 GAO-13-243 Emergency Preparedness

NRC and FEMA’s regulations and guidance establish the framework for 

how licensees and local and state authorities are to inform the public 

about how to respond during a radiological emergency and provide 

educational information about radiation. Specifically, NRC regulations 

require that licensees annually provide basic emergency planning 

information to the public within the 10-mile emergency planning zone. 

This information may take various forms, including brochures, telephone 

book inserts, or calendars. According to NRC and FEMA guidance, these 

materials must include educational information on radiation, protective 

measure information such as evacuation routes and relocation centers, 

information relating to the special needs of the handicapped, and a 

contact for additional information. FEMA guidance also states that the 

content of these materials is generally determined through coordination 

between local and state authorities and the licensees. For example, St. 

Lucie County authorities in Florida told us that they develop the annual 

mailing in cooperation with neighboring Martin County authorities, so that 

both counties use the same materials, and then the licensee prints and 

distributes this mailing to households and businesses within the 10-mile 

emergency planning zone around the nuclear power plant in St. Lucie, 

Florida. Licensees told us that they translate these materials into nonEnglish languages and make them available to the public, depending on 

the demographic makeup of their communities, as directed by FEMA 

guidance. NRC and FEMA updated their guidance on these public 

information programs in November 2011 to provide more information 

about protective actions in public information materials. For example, the 

2011 guidance recommends that local and state authorities explain the 

purpose of staged evacuations, define expectations for those under an 

advisory, clarify expectations for those who are not at home when a 

protective action is ordered, and discourage parents from picking up their 

children from school during an event. Staged evacuation occurs when the 

population in one area is evacuated, while the population in another area 

is told to remain indoors until it is their turn to evacuate. According to 

NRC guidance, the success of staged evacuation depends on public 

compliance with sheltering in place while the population most at risk is 

evacuated. NRC’s research on the matter has suggested that the public 

requires clear and direct communication both to evacuees and to those 

near, but not within, affected areas.

FEMA guidance also instructs local and state authorities to conduct 

outreach to certain special needs populations within the 10-mile 

emergency planning zone. Specifically, FEMA’s guidance instructs 

licensees and local and state authorities to take the following actions:

NRC and FEMA Require 

Licensees and Local and 

State Authorities to 

Provide Detailed 

Information Annually to 

the Public within the 10-

Mile Planning Zone
 

Page 22 GAO-13-243 Emergency Preparedness

• Conduct outreach to transient populations. Authorities may, for 

example, issue pamphlets, stickers, or signs in hotels, motels, and 

public parks. Local and state authorities in communities around San 

Onofre Nuclear Generating Station near San Clemente, California, 

told us that they provide a card to campers when they enter state 

parks that tells them what to do and which radio stations to tune into 

in the event of an emergency at the nuclear power plant; are working 

with hotels to include emergency information in each hotel room; and 

have trained hotel managers and staff to make sure they are 

registered with the appropriate jurisdiction to receive emergency 

alerts.

• Have a plan to identify individuals who need assistance when 

evacuating. Some local and state authorities told us that they 

accomplish this by including a card inside the annual mailing that 

enables residents with special needs to identify their needs and 

complete and mail back the card to the licensee or to their local 

authorities, so that the authorities can track special needs individuals 

during an emergency.

FEMA guidance also instructs local and state authorities to establish 

coordinated arrangements for dealing with rumors and unconfirmed 

reports to provide the public with direct access to accurate information 

during an incident, as well as to provide local and state authorities with 

information about trends in public inquiries. For example, some local and 

state authorities told us that that they have established dedicated public 

information telephone numbers and assigned staff to answer questions in 

the event of an incident. Local and state authorities we spoke with varied 

in their use of social media forums to monitor and respond to rumors 

before or during an incident. Some local and state authorities near the 

four plants we visited said that they use social media to provide 

preparedness information, while others said they do not use social media. 

FEMA officials told us that they are currently studying different social 

media technologies and how information is disseminated to the public. In 

addition, local and state authorities are required to conduct annual efforts 

to brief news media on emergency plans, radiation information, and their 

points of contact in an emergency. State of Florida authorities go beyond 

these requirements and told us they conduct two media briefings 

annually, hold an annual press conference with the Lieutenant Governor, 

and provide radiological emergency preparedness information sheets to 

the press.
 

Page 23 GAO-13-243 Emergency Preparedness

Local and state authorities we spoke with told us that they conduct other 

voluntary activities to inform the public in the 10-mile emergency planning 

zone. These activities include informing residents about annual siren 

testing required in the zone, conducting presentations to community 

groups and at local events, providing information to parents at schools, 

and posting information on websites. Authorities we spoke with said that 

some of these voluntary activities may also occur outside the 10-mile 

emergency planning zone.

NRC and FEMA do not require public information efforts for radiological 

emergency preparedness outside the 10-mile emergency planning zone. 

According to NRC and FEMA guidance, for the worst incidents at 

commercial nuclear power plants, immediate life-threatening radiation 

doses would generally not occur outside the 10-mile zone and would 

probably not require protective actions outside the zone.34 In the 50-mile 

emergency planning zone, the principal exposure to radiation would be 

ingestion of contaminated food and water, and this would represent a 

longer term problem. According to FEMA guidance, the licensee and 

state authorities are to make information available to farmers and other 

members of the agricultural industry within the 50-mile emergency 

planning zone. This information is to describe recommended protective 

actions for agricultural industries to minimize contamination of the food 

supply. Some state and local authorities told us that they sometimes 

conduct public education efforts outside of the 10-mile zone that include 

radiological emergency preparedness information. However, some 

authorities also expressed concerns about the radiological awareness 

levels of residents and the potential for shadow evacuations. For 

example, Los Angeles County authorities told us that one of their greatest 

concerns in the event of an incident at the San Onofre Nuclear 

Generating Station is a rumor that results in shadow evacuations, which 

could result in clogged highways as people who are not in danger choose 

to evacuate unnecessarily.

 

34NRC and FEMA, Criteria for Preparation and Evaluation of Radiological Emergency 

Response Plans and Preparedness in Support of Nuclear Power Plants, NUREG0654/FEMA-REP-1, Rev. 1 (Washington, D.C.: November 1980).
 

Page 24 GAO-13-243 Emergency Preparedness

In 2008, NRC conducted a study with the Sandia National Laboratory to 

examine public awareness of emergency preparedness information and 

likely responses within the 10-mile emergency planning zone. The 

laboratory administered a national telephone survey to random members 

of households within each of the 63 10-mile emergency planning zones.35

According to the study results, those surveyed were generally wellinformed, with many having taken action to prepare for an emergency. 

Furthermore, most of those who responded to the survey reported that 

they believe they are likely to follow directions from local and state 

authorities in the event of an incident at the nuclear power plant.36

However, about 20 percent of those responding to the survey reported 

that they would evacuate even when told evacuation for them was not 

necessary, referred to as a shadow evacuation. NRC guidance states that 

a shadow evacuation can impede the evacuation of those under 

evacuation orders. Also, most of those who responded to the survey and 

who have children in school reported that they were likely to pick up their 

children from school in an emergency. Using the findings from this study, 

NRC updated guidance on protective action strategies and improving 

public information programs in November 2011.37

To address the potential for shadow evacuations, NRC officials told us 

that they used the study results to determine the potential shadow 

evacuation rate outside the 10-mile emergency planning zone. 

Specifically, NRC instructed licensees to consider shadow evacuations of 

20 percent of the public out to 15 miles from the nuclear power plant 

This guidance 

recommends that local and state authorities provide more information 

about the purpose of staged evacuations, in addition to simply describing 

the different types of protective action strategies.

 

35There are currently 65 nuclear power plants in the United States; however, some 

nuclear power plants are located on the same site and therefore have the same 

emergency planning zone. 

36Estimates for this survey have 95 percent confidence intervals within plus or minus 3.5 

percentage points unless otherwise noted.

37NRC and FEMA, Criteria for Preparation and Evaluation of Radiological Emergency 

Response Plans and Preparedness in Support of Nuclear Power Plants: Guidance for 

Protective Action Strategies, NUREG-0654/FEMA-REP-1, Rev. 1 Supplement 3 

(Washington, D.C.: November 2011).

NRC Has Studied 

Awareness and Likely 

Responses to an Incident 

Inside the 10-Mile 

Emergency Planning Zone 

but Not Outside of It
 

Page 25 GAO-13-243 Emergency Preparedness

when the licensee develops estimates of evacuation times.38 However, 

the study surveyed residents inside the 10-mile emergency planning 

zone, a population that is given radiological emergency preparedness 

information every year and that is therefore more familiar with the power 

plant, radiation risks, protective actions, and evacuation routes than the 

public outside the 10-mile zone.39 Without this same level of information, 

those outside the zone may not respond in a similar manner to a

radiological incident as those inside the zone. Because the survey was 

conducted on a relatively more educated and aware population, the 20-

percent rate for shadow evacuations may not accurately capture the level 

of shadow evacuations that may occur outside the 10-mile zone. 

According to NRC and FEMA officials, their agencies have not examined 

public awareness outside the 10-mile emergency planning zone and 

therefore do not know if a 20-percent estimate of shadow evacuations is 

reasonable. Therefore, licensee evacuation time estimates may not 

accurately consider the impact of shadow evacuations. Without estimates 

of evacuation times based on more solid understanding of public 

awareness outside the 10-mile zone, licensees and NRC and FEMA 

cannot be confident about the reliability of their estimates. If shadow 

evacuations are not correctly estimated, planning for a radiological 

emergency may not sufficiently consider the impact of the public outside 

the 10-mile emergency planning zone. Shadow evacuations outside this 

zone greater than the assumed 20-percent rate would put additional 

traffic on roadways, possibly delaying the evacuation of the public inside 

the emergency planning zone and potentially increasing the risk to public 

health and safety.

The Fukushima Daiichi incident raised questions about the U.S. 

government’s ability to protect its citizens if a similar incident were to 

occur here. NRC and FEMA have developed regulations and guidance to 

help licensees and local and state authorities create and test radiological 

emergency response plans that are intended to provide reasonable 

assurance that they can adequately protect public health and safety in the 

 

38NRC, Criteria for Development of Evacuation Time Estimate Studies, NUREG/CR-7002 

(Albuquerque, New Mexico: November 2011). This guidance did not include instructions 

for shadow evacuation estimates for the area beyond 15 miles.

39Some local authorities we spoke with said that they had also conducted surveys on 

preparedness for all types of emergencies, and some of these studies asked questions on 

radiological emergency awareness and likely reactions of the public.

Conclusions 
 

Page 26 GAO-13-243 Emergency Preparedness

event of a radiological incident at a nuclear power plant. NRC regulations 

and guidance also direct licensees to annually provide emergency 

preparedness information to the public within their 10-mile emergency 

planning zones. Furthermore, the 2008 NRC study by Sandia National 

Laboratory demonstrated that the public within these planning zones is 

generally likely to respond to instructions from local and state authorities 

in the event of an incident. On the basis of this study, NRC estimated that 

20 percent of the public within the zones would choose to evacuate even 

when told evacuation for them was not necessary (shadow evacuations). 

NRC then directed licensees to consider this same percentage of shadow 

evacuations for the public outside the planning zone when estimating 

evacuation times. However, communities outside the 10-mile zone 

generally do not receive the same level of information as those within the 

10-mile zone and therefore may not be as knowledgeable about 

appropriate conduct during a radiological emergency as those inside the 

zone and may not respond in a similar manner. If the public outside the 

zone evacuates unnecessarily at a greater rate than expected, these 

shadow evacuations would put additional traffic on roadways, possibly 

delaying the evacuation of the public inside the emergency planning zone 

and potentially increasing the risk to public health and safety. However, 

because neither NRC nor FEMA have examined public awareness 

outside of the 10-mile emergency planning zone, they do not know how 

the public outside this zone will respond. Specifically, they do not know if 

a 20-percent estimate of shadow evacuations is reasonable. Therefore, 

licensee evacuation time estimates may not accurately consider the 

impact of shadow evacuations. Without estimates of evacuation times 

based on more solid understanding of public awareness, licensees and 

NRC and FEMA cannot be confident about the reliability of their 

estimates. If shadow evacuations are not correctly estimated, planning for 

a radiological emergency may not sufficiently consider the impact of the 

public outside the emergency planning zone.

To better inform efforts for nuclear power plant emergency preparedness 

and planning, we recommend that NRC Commissioners obtain 

information on public awareness of radiological emergency preparedness 

for communities outside the 10-mile emergency planning zone and the 

likely response of those communities in the event of a radiological 

incident at a nuclear facility and consider how these results may affect 

estimates for shadow evacuations outside the zone.

Recommendation for 

Executive Action
 

Page 27 GAO-13-243 Emergency Preparedness

We provided a draft of this report to the NRC Commissioners and the 

Secretary of the Department of Homeland Security for their review and 

comment. DHS provided no written comments. NRC provided written 

comments on the draft report, which are reproduced in appendix II, and 

technical comments from NRC, which we incorporated into the report as 

appropriate. 

NRC found our discussion of emergency preparedness programs at 

nuclear power plants to be complete, but generally disagreed with our 

finding on shadow evacuations. Specifically, NRC did not believe that the 

report accurately captured the technical basis for the NRC’s use of 20 

percent as a reasonable estimate of shadow evacuations beyond 10 

miles. NRC explained that it has conducted considerable research on 

evacuations and has confidence that shadow evacuations generally have 

no significant impact on traffic movement. Lastly, NRC stated that the 

licensee’s current emergency planning bases continue to provide 

reasonable assurance of protection of the public’s health and safety.

We stand by our finding and the related recommendation that NRC 

should obtain information on public awareness and the likely responses of 

communities outside the 10-mile zone in the event of a radiological 

incident at a nuclear power plant. 

First, as stated in the report, NRC issued guidance in 2011 that directs 

licensees to consider shadow evacuations of 20 percent of the population 

located from 10 miles to 15 miles from a nuclear plant when estimating 

evacuation times.40

Second, NRC asserts that it has conducted considerable research on 

evacuations and has confidence that shadow evacuations generally have 

NRC told us that this shadow evacuation estimate 

came primarily from a telephone survey it conducted of the public within 

each of the 63 10-mile emergency planning zones around the country. 

However, residents inside the 10-mile zone are provided radiological 

information every year and are therefore more familiar with the power 

plant, radiation risks, protective actions, and evacuation routes than those 

outside the zone. Without this same level of information, residents outside 

the zone may not respond in a similar manner as those inside the zone, 

and the use of a 20 percent shadow evacuation estimate for the public 

outside the zone may therefore not be reliable. 

 

40NRC, Criteria for Development of Evacuation Time Estimate Studies, NUREG/CR-7002 

(Albuquerque, New Mexico: November 2011). 

Agency Comments 

and Our Evaluation
 

Page 28 GAO-13-243 Emergency Preparedness

no significant impact on traffic movement. GAO acknowledges that NRC 

has conducted research on evacuations, but these studies are generally 

based on evacuations that have resulted from non-nuclear incidents such 

as hurricanes, wildfires, and chemical spills. It is unclear whether the 

public would behave the same for a nuclear evacuation as it would for the 

incidents that NRC has studied. As we say in the report, NRC’s NearTerm Task Force established after the Fukushima incident observed gaps 

in public awareness in the United States. The task force recommended 

that, as part of a follow-on review, NRC should pursue emergency 

preparedness topics related to decision-making, radiation monitoring, and 

public education, particularly to increase education and outreach in the 

vicinity of each nuclear power plant in the areas of radiation, radiation 

safety, and the appropriate use of potassium iodide. We believe the task 

force’s finding that there are gaps in public awareness and understanding 

regarding nuclear incidents supports our recommendation that NRC 

should obtain information on public awareness and the likely responses of 

communities outside the 10-mile zone in the event of a radiological 

incident at a nuclear power plant.

Finally, with regard to NRC’s confidence that shadow evacuations 

generally have no significant impact on traffic movement, according to 

NRC’s 2011 guidance mentioned earlier, evacuation time estimate 

studies should include a shadow evacuation consideration of 20 percent 

of the population out to 15 miles away from the nuclear power plant 

because the additional traffic generated has the potential to impede an 

evacuation of the emergency planning zone. Thus, NRC has previously 

acknowledged in its guidance that traffic from shadow evacuations may 

impede the intended evacuations. For these reasons, we believe our 

recommendation to improve NRC’s understanding of the effect of shadow 

evacuations outside of the 10-mile zone is consistent with NRC’s 

guidance about the potential effects of shadow evacuations on 

evacuations within the emergency planning zone.

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 to the Chairman of the NRC, 

the Secretary of the Department of Homeland Security, the appropriate 

congressional committees, and other interested parties. In addition, this 

report will be available at no charge on the GAO website at 

http://www.gao.gov. 
 

Page 29 GAO-13-243 Emergency Preparedness

If you or your staff members have any questions about this report, please 

contact Frank Rusco at (202) 512-3841 or ruscof@gao.gov or Stephen 

Caldwell at (202) 512-9610 or caldwells@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Key contributors to this report are listed in 

appendix III. 

Frank Rusco

Director, Natural Resources and Environment

Stephen L. Caldwell

Director, Homeland Security and Justice
Appendix I: NRC and FEMA Planning 

Standards

Page 30 GAO-13-243 Emergency Preparedness

NRC and FEMA Planning Standards

1 Assignment Of Responsibility 

(Organization Control)

Primary responsibilities for emergency response by the nuclear facility licensee 

and by state and local organizations within the emergency planning zones have 

been assigned, the emergency responsibilities of the various supporting 

organizations have been specifically established, and each principal response 

organization has staff to respond and to augment its initial response on a 

continuous basis.

2 On-site Emergency Organization On-duty facility licensee responsibilities for emergency response are 

unambiguously defined, adequate staffing to provide initial facility accident 

response in key functional areas is maintained at all times, timely augmentation 

of response capabilities is available, and the interfaces among various on-site 

response activities and off-site support and response activities are specified.

3 Emergency Response Support and 

Resources

Arrangements for requesting and effectively using assistance resources have 

been made, arrangements to accommodate state and local staff at the licensee’s 

emergency operations facility have been made, and other organizations capable 

of augmenting the planned response have been identified.

4 Emergency Classification System A standard emergency classification and action level scheme, the bases of which 

include facility system and effluent parameters, is in use by the nuclear facility 

licensee, and state and local response plans call for reliance on information 

provided by facility licensees for determinations of minimum initial off-site 

response measures.

5 Notification Methods and Procedures Procedures have been established for notification, by the licensee, of state and 

local response organizations and for notification of emergency personnel by all 

organizations; the content of initial and follow up messages to response 

organizations and the public has been established; and means to provide early 

notification and clear instruction to the populace within the plume exposure 

pathway emergency planning zone have been established.

6 Emergency Communications Provisions exist for prompt communications among principal response 

organizations to emergency personnel and to the public.

7 Public Education and Information Information is made available to the public on a periodic basis on how they will 

be notified and what their initial actions should be in an emergency (e.g., 

listening to a local broadcast station and remaining indoors), the principal points 

of contact with the news media for dissemination of information during an 

emergency (including the physical location or locations) are established in 

advance, and procedures for coordinated dissemination of information to the 

public are established.

8 Emergency Facilities and Equipment Adequate emergency facilities and equipment to support the emergency 

response are provided and maintained.

9 Accident Assessment Adequate methods, systems, and equipment for assessing and monitoring actual 

or potential off-site consequences of a radiological emergency condition are in 

use.

10 Protective Response A range of protective actions has been developed for the plume exposure 

pathway emergency planning zone for emergency workers and the public. 

Guidelines for the choice of protective actions during an emergency, consistent 

with federal guidance, are developed and in place, and protective actions for the 

ingestion exposure pathway emergency planning zone appropriate to the locale 

have been developed.

Appendix I: NRC and FEMA Planning 

Standards 
Appendix I: NRC and FEMA Planning 

Standards

Page 31 GAO-13-243 Emergency Preparedness

NRC and FEMA Planning Standards

11 Radiological Exposure Control Means for controlling radiological exposures, in an emergency, are established 

for emergency workers. The means for controlling radiological exposures shall 

include exposure guidelines consistent with EPA emergency worker and 

lifesaving activity protective action guides.

12 Medical and Public Health Support Arrangements are made for medical services for contaminated injured 

individuals.

13 Recovery and Reentry Planning and PostAccident OperationsGeneral plans for recovery and reentry are developed.

14 Exercises and Drills Periodic exercises are (will be) conducted to evaluate major portions of 

emergency response capabilities, periodic drills are (will be) conducted to 

develop and maintain key skills, and deficiencies identified as a result of 

exercises or drills are (will be) corrected.

15 Radiological Emergency Response 

Training

Radiological emergency response training is provided to those who may be 

called on to assist in an emergency.

16 Responsibility for the Planning Effort: 

Development, Periodic Review, and 

Distribution of Emergency Plans

Responsibilities for plan development and review and for distribution of 

emergency plans are established, and planners are properly trained.

Sources: NRC and FEMA, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in 

Support of Nuclear Power Plants, NUREG-0654/FEMA-REP-1, Rev. 1 (Washington, D.C.: November 1980).
Appendix II: Comments from the Nuclear 

Regulatory Commission

Page 32 GAO-13-243 Emergency Preparedness

Appendix II: Comments from the Nuclear 

Regulatory Commission
Appendix III: GAO Contacts and Staff 

Acknowledgments

Page 33 GAO-13-243 Emergency Preparedness

Frank Rusco, (202) 512-3841 or ruscof@gao.gov

Stephen Caldwell, (202) 512-9610 or caldwells@gao.gov

In addition to the individuals named above, Kimberly Gianopoulos, 

Assistant Director; Nathan Gottfried; Eugene Gray; David Lysy; and David 

Messman made key contributions to this report. Important contributions 

were also made by Elizabeth Beardsley, Marcia Crosse, R. Scott 

Fletcher, Jonathan Kucskar, Steven Putansu, Dan Royer, Carol Shulman, 

and Kiki Theodoropoulos.

Appendix III: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts

Staff 

Acknowledgments 

(361382)
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