Emergency Preparedness: NRC Needs to Better Understand Likely Public Response to Radiological Incidents at Nuclear Power Plants
Published: 2013-03-11T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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.
section_title: What GAO Recommends
paragraphs: 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.

section_title: Letter
paragraphs: 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. NRC officials said that this  recommendation was a conservative estimate based on limited and often  conflicting information about the exact conditions of the reactors and  spent fuel pools at the power plant.
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. plant; in total, these zones include at least 490 local and state authorities,  according to NRC and FEMA officials. 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.
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  each plant must conduct once every 2 years.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.
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.
subsections: section_title: Background
paragraphs: 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).
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.
subsections: section_title: Emergency Planning Zones
paragraphs: In 1978, a joint NRC and EPA task force issued guidance that provided a  planning basis for off-site preparedness around commercial nuclear  power plants 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.this emergency planning zone guidance should be incorporated into  emergency preparedness documents and planning. The 1978 guidance  established the following two emergency planning zones:   In 1980, NRC and FEMA directed that
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.
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,as well as public health impacts from the March 1979 incident at Three  Mile Island in Pennsylvania and the 2011 Fukushima incident.
According 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. 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.
section_title: NRC and FEMA Framework for Radiological Emergency Preparedness
paragraphs: 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 off- site emergency planning and preparedness activities from NRC to  FEMA 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.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   This memorandum  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. 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.
section_title: NRC Task Force Established after Fukushima
paragraphs: In the aftermath of the Fukushima incident, NRC established the Near- Term 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  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.
section_title: NRC and FEMA Guide Licensees and Local and State Authorities in Radiological Emergency Preparedness
paragraphs: 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.
subsections: section_title: NRC and FEMA’s Regulations and Guidance Establish the Framework for On-site and Off-site Radiological Emergency Preparedness
paragraphs: 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.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  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. 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.
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.
section_title: Licensees Manage Emergency Preparedness On-site
paragraphs: 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 off- site 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.
section_title: Local and State Authorities Manage Emergency Preparedness Off-site
paragraphs: 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  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. 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  regional, interjurisdictional planning committee to jointly develop plans  and policies and to decide on radiological emergency preparedness.
section_title: NRC and FEMA Oversee Radiological Emergency Preparedness by Reviewing Plans and Exercises
paragraphs: 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.
subsections: section_title: NRC Reviews Licensees’ Emergency Plans, and FEMA Evaluates Local and State Plans
paragraphs: 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. 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.
NRC officials told us that they also review license conditions for the facility. 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. 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  evacuation area.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.
Specifically, the guidance states that these evacuation  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. 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. FEMA then communicates this approval or  disapproval to the state and to NRC for consideration in the licensing  process.
To 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.
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. 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  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 off- site 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.
section_title: NRC and FEMA Oversee and Evaluate Radiological Emergency Preparedness Exercises
paragraphs: NRC and FEMA also oversee radiological emergency preparedness by  reviewing the biennial exercises conducted by licensees and local and  state authorities. 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.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   In addition, NRC inspectors are to evaluate  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. 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.
FEMA officials told us that FEMA and NRC also participate in some aspects of scenario  development. 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.
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.
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.
section_title: 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
paragraphs: 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.
subsections: section_title: NRC and FEMA Require Licensees and Local and State Authorities to Provide Detailed Information Annually to the Public within the 10- Mile Planning Zone
paragraphs: 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 non- English 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:
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.
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. 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.
section_title: NRC Has Studied Awareness and Likely Responses to an Incident Inside the 10-Mile Emergency Planning Zone but Not Outside of It
paragraphs: 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.  According to the study results, those surveyed were generally well- informed, 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.  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. 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.
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  when the licensee develops estimates of evacuation times. 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. 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.
section_title: Conclusions
paragraphs: 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  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.
section_title: Recommendation for Executive Action
paragraphs: 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.
section_title: Agency Comments and Our Evaluation
paragraphs: 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. 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.
Second, NRC asserts that it has conducted considerable research on  evacuations and has confidence that shadow evacuations generally have  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 Near- Term 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.
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.
section_title: Appendix I: NRC and FEMA Planning Standards
paragraphs: 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.
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.
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.
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.
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.
Provisions exist for prompt communications among principal response  organizations to emergency personnel and to the public.
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.
Adequate emergency facilities and equipment to support the emergency  response are provided and maintained.
Adequate methods, systems, and equipment for assessing and monitoring actual  or potential off-site consequences of a radiological emergency condition are in  use.
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.
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.
Arrangements are made for medical services for contaminated injured  individuals.
General plans for recovery and reentry are developed.
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.
Radiological emergency response training is provided to those who may be  called on to assist in an emergency.
Responsibilities for plan development and review and for distribution of  emergency plans are established, and planners are properly trained.
section_title: Appendix II: Comments from the Nuclear Regulatory Commission
section_title: Appendix III: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: 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.