Combating Nuclear Terrorism: Actions Needed to Better Prepare to Recover from Possible Attacks Using Radiological or Nuclear Materials
Published: 2010-01-29T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: A terrorist's use of a radiological dispersal device (RDD) or improvised nuclear device (IND) to release radioactive materials into the environment could have devastating consequences. GAO was asked to examine (1) the extent to which the federal government is planning to fulfill its responsibilities to help cities and their states clean up contaminated areas from RDD and IND incidents, (2) what is known about the federal government's capability to effectively clean up these contaminated areas, and (3) suggestions for improving federal preparedness to help cities and states recover from these incidents. The report also discusses recovery activities in the United Kingdom. GAO reviewed federal laws and guidance; interviewed officials from the Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA), Department of Energy (DOE), and Environmental Protection Agency (EPA); and surveyed emergency management officials from 13 cities at high risk of attack, their 10 states, and FEMA and EPA regional offices.
section_title: What GAO Found
paragraphs: FEMA, the DHS agency responsible for developing a comprehensive emergency management system, has not developed a national disaster recovery strategy, as required by law, or issued specific guidance to coordinate federal, state, and local government recovery planning for RDD and IND incidents, as directed by executive guidance. To date, most federal attention has been given to developing a response framework, with less attention to recovery. Responding to an attack would involve evacuations and providing treatment to those injured; recovering from an attack would include cleaning up the radioactive contamination to permit people to return to their homes and businesses. Existing federal guidance provides limited direction for federal, state, and local agencies to develop recovery plans and to conduct exercises to test recovery preparedness. Of the over 90 RDD and IND exercises to test response capabilities in the last 6 years, only 3 included a recovery component. GAO's survey found that almost all 13 cities and most states believe they would need to rely heavily on the federal government to conduct and fund analysis and environmental cleanup activities. However, city and state officials were inconsistent in views on which federal agencies to turn to for help, which could hamper the recovery effort. Although DOE and EPA have experience cleaning up localized radiation-contaminated areas, it is unclear whether this federal capability is sufficient to effectively direct the clean up after RDD or IND incidents, and to efficiently address the magnitude of cleanup that would follow these incidents. According to an expert at DOE's Idaho National Laboratory, experience has shown that not selecting the appropriate decontamination technology can generate waste types that are more difficult to remove than the original material and can create more debris requiring disposal--leading to increased costs. Limitations in laboratory capacity to rapidly test potentially millions of material samples during cleanup, and uncertainty regarding where to dispose of radioactive debris could also slow the recovery process. At least two-thirds of the city, state, and federal respondents expressed concern about federal capability to provide the necessary cleanup actions after these incidents. Nearly all survey respondents had suggestions to improve federal recovery preparedness for RDD and IND incidents. For example, almost all the cities and states identified the need for a national disaster recovery strategy to address gaps and overlaps in federal guidance. All but three cities wanted additional guidance, for example, on monitoring radioactivity levels, cleanup standards, and management of radioactive waste. Most cities wanted more interaction with federal agencies and joint exercising to test recovery preparedness. Finally, GAO's review of the United Kingdom's preparedness to recover from radiological terrorism showed that it has already taken actions similar to those suggested by GAO's survey respondents, such as issuing national recovery guidance, conducting a full-scale recovery exercise, and publishing national recovery handbooks for radiation incidents.

section_title: Letter
paragraphs: A terrorist’s use of either a radiological dispersal device (RDD)— frequently referred to as a dirty bomb—or an improvised nuclear device  (IND) to release radioactive materials into the environment could have  devastating consequences. However, quickly analyzing and cleaning up  contaminated areas from such an incident, particularly from an RDD  attack, could speed up the recovery and allow restoration of normal  operations of critical infrastructure, services, businesses, and public  activities, thus reducing the many adverse consequences from an attack of  this kind. Responding to such an attack would involve evacuations,  providing medical treatment to those who were injured, and protecting  property; recovery would include cleaning up areas contaminated with  radioactive materials in order to permit people to return to their homes  and businesses. According to a 2008 report of the National Science and  Technology Council, which coordinates science and technology policy  within the Executive Office of the President, the ability of government to  quickly and decisively respond to and recover from an RDD or IND  incident is key to national resiliency. Importantly, the council noted that  being prepared to recover from these incidents may even provide an  element of deterrence if the adversary perceives less potential for long- lasting harm.
The consequences of a terrorist attack using an RDD or IND would include  not only loss of life, but also enormous psychological and economic  impacts. An RDD would disperse radioactive materials into the  environment through a conventional explosive or through other means.  Depending on the type of RDD, the area contaminated could be as small as  part of a building or a city block or as large as several square miles.  Hundreds of individuals might be killed or injured from the RDD explosion  or face the risk of later developing cancer due to exposure to radiation and  radioactive contamination. An IND is a crude nuclear bomb made with  highly enriched uranium or plutonium. It would create an explosion  producing extreme heat, powerful shockwaves, and intense radiation that  would be immediately lethal to individuals within miles of the explosion,  as well as radioactive fallout over thousands of square miles.  Nonproliferation experts estimate that a successful IND could produce the  same force as the equivalent of the yield of the bomb that destroyed  Nagasaki, Japan in 1945; it could devastate the heart of a medium-sized  U.S. city. The explosion could cause hundreds of thousands of deaths and  injuries, as well as pose long-term cancer risks to those exposed to the  radioactive fallout. An RDD is thought to be a more likely terrorist weapon  than an IND given the prevalent commercial use of radioactive source  material—for example, in some medical and industrial equipment—and  the relatively easy way in which this material could be dispersed through  conventional explosives, like dynamite, or other means.
If an RDD or IND incident occurred, as part of the recovery process, a  number of federal, state, and local government departments and agencies  would be involved in the analysis and environmental cleanup of areas  contaminated with radioactive materials. Generally, state and local  governments have primary responsibility for recovering from disasters,  but the federal government may provide assistance when an incident  exceeds state and local government resources or when an incident is  managed by federal agencies under their own authorities or occurs within  federal jurisdiction (e.g., on a military base or a federal facility or lands).
The Department of Homeland Security (DHS) is the principal federal  agency responsible for domestic incident management. The primary  mission of its Federal Emergency Management Agency (FEMA) is to  develop a comprehensive emergency management system of  preparedness, protection, response, recovery, and mitigation. For an RDD  or IND incident, DHS would be the lead agency in coordinating federal  assistance to state and local governments. For these incidents, DHS would  have responsibility for coordinating the federal response, with the support  of other federal agencies, to assist state and local governments in the  analysis and environmental cleanup of areas contaminated with  radioactive materials. For example, in certain circumstances, the  Department of Energy (DOE) would have primary responsibility for  coordinating the analysis or characterization of areas contaminated with  radioactive materials through its leadership of the interagency Federal  Radiological Monitoring and Assessment Center (FRMAC). The  Environmental Protection Agency (EPA) would take over leadership of  FRMAC for coordinating the long-term monitoring of radiological  contamination and supporting the detailed assessment of property  contamination in the affected areas to support the cleanup of these areas.  The Department of Defense (DOD), along with other agencies, would act  in support of FRMAC. Federal agencies, including EPA, DOE, and the  Nuclear Regulatory Commission (NRC), as well as state regulatory  agencies have set various cleanup standards for areas contaminated with  radioactive materials, but not specifically for RDD or IND incidents. The  national laboratories have also provided research support assessing  methods and technologies for analysis and environmental cleanup  activities.
The risk of terrorists using an RDD or IND is, in large part, determined by  their ability to gain access to the materials needed to construct these  devices. Over the past few years, we have issued a number of reports on  the security of nuclear and radiological materials and facilities that house  them. Overall, our work has shown that despite investing billions of  dollars in new technology to upgrade security procedures, gaps continue  to exist in our nation’s ability to prevent terrorists from accessing or  smuggling dangerous quantities of radioactive material into the country.  For example, in 2007, we testified before Congress that our own  investigators were able to set up phony businesses and obtain a legitimate  NRC license that would have permitted them to obtain dangerous  quantities of radioactive material. Our investigators were able to obtain  this NRC license just months after NRC had completed a lengthy process  to strengthen its licensing procedures. In 2008, we reported that NRC, in  developing its security requirements for research reactors, had not fully  considered the risks associated with terrorists attacking these facilities— many of which are located on college campuses. Such an attack could  involve terrorists sabotaging a reactor in order to disperse radioactive  material over neighboring communities—similar to an RDD. We have also  reported on DHS’s and FEMA’s preparedness for, response to, and  recovery from disasters in 2007, 2008, and 2009.
We were asked to review the federal government’s preparedness to help  cities and states recover from possible attacks using an RDD or IND.  Accordingly, this report addresses the following: (1) the extent to which  federal agencies are planning to fulfill their responsibilities to help cities  and states clean up areas contaminated with radioactive materials from  RDD and IND incidents, (2) what is known about the federal government’s  capability to effectively clean up areas contaminated with radioactive  materials from RDD and IND incidents, and (3) suggestions from  government emergency management officials for improving federal  preparedness to help cities and states recover from RDD and IND  incidents. In addition, we are providing information on actions taken in the  United Kingdom to prepare for recovering from RDD and IND incidents.
This report follows preliminary observations that we provided in  testimony at a September 14, 2009, congressional hearing.
To address these objectives, we examined pertinent federal law,  presidential directives, and other executive guidance; interviewed  cognizant officials from DHS, DOE, EPA, FEMA, NRC, and from both DOE  and EPA national laboratories; and conducted a survey of emergency  management officials in 13 cities considered to be at high or medium risk  for an RDD or IND incident, officials in these cities’ states, and federal  emergency management officials in FEMA and EPA regional offices. We  also reviewed information on the number and type of RDD and IND  response and recovery exercises that have been conducted in the last 6  years. Finally, we visited the United Kingdom to review its preparedness to  recover from RDD and IND incidents at the suggestion of EPA officials  and because it has addressed a fairly recent radiological release incident in  a large urban area. Appendix I provides more detail on our scope and  methodology.
We conducted this performance audit from October 2008 to January 2010  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: In the aftermath of the terrorist attacks on September 11, 2001, security  experts have raised concerns that terrorists may try to smuggle  radiological or nuclear materials into the United States to produce either  an RDD or IND. These experts have also raised concerns that terrorists  could obtain radioactive materials used in medicine, research, agriculture,  and industry to construct an RDD, or dirty bomb. This radioactive material  is encapsulated, or sealed, in metal, such as stainless steel, titanium, or  platinum, to prevent its dispersal and is commonly called a sealed  radiological source. Sealed sources are used throughout the United States  and other countries in equipment designed to, among other things,  diagnose and treat illnesses, preserve food, detect flaws in pipeline welds,  and determine the moisture content of soil. Depending on their use, sealed  sources contain different types of radioactive material, such as strontium- 90, cobalt-60, cesium-137, plutonium-238, and plutonium-239. While no  terrorists have detonated a dirty bomb in a city, Chechen separatists  placed a canister containing cesium-137 in a Moscow park in the mid- 1990s. Although the device was not detonated and no radioactive material  was dispersed, the incident demonstrated that terrorists have the  capability and willingness to use radiological materials as weapons of  terrorism. In contrast, detonating an IND would require a terrorist group  to obtain nuclear weapons material—which is generally heavily secured— and to have highly sophisticated expertise and equipment to fabricate this  material into a weapon.
Another form of nuclear terrorism occurred with the dispersal of  radioactive materials through a sequence of events in London during  November and December 2006. On November 23, 2006, Alexander  Litvinenko, a former officer of the Russian Federal Security Service, was  poisoned with a milligram of polonium-210—about the size of a grain of  salt. The dispersal of the polonium by the perpetrators of the crime and  the victim resulted in widespread contamination across London and even  abroad. His poisoning was detected only after he was hospitalized for a  few weeks and tested for symptoms of radiation exposure because of hair  loss. Following the poisoning, forensic investigators examined 47 sites  across London for traces of polonium, both resulting from the handling of  the polonium by his perpetrators and maybe other attempts to poison him.  Of these locations, about 12 showed signs of this radioactive material,  including a restaurant, hotel room, soccer stadium, and an eastbound  British Airways plane. British investigators also identified over 1,000  people who might have been in various ways exposed to the polonium.  Health officials tested 738 of them and found that 137 had reportable levels  of this substance, although few of these individuals turned out to have  levels that warranted medical attention. The decontamination activities at  these sites spanned 19 days, involved a number of methods and  technologies, and cost more than $200,000. However, the estimated total  cost of managing this incident, including law enforcement investigation,  testing individuals, sampling materials, and cleanup, was $4 million.
section_title: The Federal Government Has Not Completed Planning to Help Cities and States Clean up Areas Contaminated with Radioactive Materials from RDD or IND Incidents
paragraphs: FEMA has not completed planning to help cities and states recover from  RDD or IND incidents as evidenced by not (1) developing a national  disaster recovery strategy as required by law and (2) issuing specific  guidance to coordinate federal, state, and city planning to recover from  RDD or IND incidents. Moreover, federal agencies have conducted few  exercises to test recovery plans for these incidents.
subsections: section_title: FEMA Has Not Developed a National Disaster Recovery Strategy to Help Guide RDD or IND Recovery Planning
paragraphs: FEMA has not developed a national disaster recovery strategy, as required  by law and directed by executive guidance, or issued specific guidance to  coordinate federal, state, and local government recovery planning for RDD  or IND incidents. The Post-Katrina Emergency Management Reform Act of  2006 requires FEMA to develop, coordinate, and maintain a national  disaster recovery strategy. Among other things, the strategy is to clearly  define the roles, programs, authorities, and responsibilities of each agency  that may provide assistance to the recovery from a major disaster. In  addition, the National Strategy for Homeland Security also called on the  federal government to prepare a recovery strategy. The federal  government has placed a higher priority on developing a strategy to  respond to domestic incidents, including RDD and IND incidents, than it  has on developing a comparable strategy for recovering from these  incidents. For example, the response strategy, captured in the 2008  National Response Framework, does not include guidance on long-term  recovery activities. The FEMA coordinator for the development of a  national disaster recovery strategy told us that while the previous  administration had drafted a “white paper” addressing this strategy, the  new administration has decided to rethink the entire approach. The  FEMA coordinator also told us that FEMA recognizes its responsibility to  prepare a national disaster recovery strategy but could not provide a time  frame for its completion. This same official did say that in developing this  strategy, FEMA plans to seek out opinions of nonfederal stakeholders.  Once completed, the official said that the recovery strategy would provide  guidance to federal, state, and local agencies in revising their operational  plans for recovery activities, including recovery from RDD and IND  incidents.
Currently, the limited federal planning guidance related to the recovery  from RDD and IND incidents can be found in a number of documents.  There are several annexes to the National Response Framework that  address, in part, federal agency responsibilities and assets to help state  and local governments recover from these incidents. For example, a  December 2004 emergency support function annex covering long-term  community recovery and mitigation, led by FEMA, provides a framework  for federal support to localities to enable community recovery from the  long-term consequences of events of national significance. While this  annex addresses FEMA’s responsibilities to coordinate the transition from  response to recovery in field operations, it does not provide details on  recovery planning for RDD and IND incidents. The January 2003  emergency support annex covering hazardous materials, led by EPA,  provides the framework for federal support in response to an actual or  potential discharge and release of hazardous materials following a major  disaster or emergency. EPA officials informed us that this annex will give  them a significant federal role in leading cleanup efforts after RDD or IND  incidents, in coordination with affected state and local governments. The  June 2008 nuclear and radiological incident annex describes federal  responsibilities and provides some operational guidance for pertinent  response activities and, to a lesser extent, recovery activities in support of  state and local governments. DHS is identified as the technical lead for  recovery activities, but may request support from other federal agencies— for example, EPA and the United States Army Corps of Engineers—that  have cleanup and recovery experience and capabilities. According to this  annex, the federal government, upon request of state and local  governments, can assist in developing and executing recovery plans, but  such plans would not generally be developed until after the incident  occurs.
The lack of a national disaster recovery strategy that would include RDD  and IND incidents is problematic because, according to survey  respondents, most localities would count on the federal government being  prepared to carry out analysis and environmental cleanup activities  following these incidents. Specifically, emergency management officials  from almost all 13 cities and most of their 10 states indicated in our survey  that they believe they would need to rely heavily on the federal  government to conduct and fund all or almost all analysis and  environmental cleanup activities associated with recovering from an RDD  or IND incidents of the magnitude described in the national planning  scenarios. They indicated that their technical and financial resources  would be overwhelmed by a large RDD incident—and certainly by an IND  incident. Most of these officials reported that they believe they could  adequately address a smaller RDD incident, such as one that is confined to  a city block or inside a building. Despite this anticipated reliance on the  federal government, we obtained mixed responses as to whether these  RDD and IND recovery activities should be primarily a federal  responsibility. Almost half of the respondents from the cities (6 of 13), but  most of those from states (8 of 10), indicated that these activities should  be primarily a federal responsibility. The others stressed the need for  shared responsibilities with the federal government. However, when  respondents were asked in our survey to identify which federal agencies  they would turn to for help in the analysis and environmental cleanup of  areas contaminated with radioactive materials from RDD or IND incidents,  they provided inconsistent responses and frequently listed several federal  agencies for the same activity. These responses seem to indicate that there  might be some confusion among city and state emergency management  officials regarding federal agency responsibilities to provide assistance  to  them under these circumstances. In our view, this confusion, if not  addressed, could hamper the timely recovery from these incidents and  demonstrates the need for development and implementation of a national  disaster recovery strategy. In commenting on the draft report, EPA  indicated that as no single federal department or agency has the sole  requisite technical capacity and capabilities to respond to the scope of  RDD or IND incidents, it is expected that numerous federal agencies  would need to work together in a single mission, such as through FRMAC.  Nevertheless, EPA stated that our survey results underscore the  importance having clear communication and notification among federal  agencies, which if not addressed, could hamper recovery efforts.
section_title: FEMA Has Not Issued Specific Guidance to Coordinate Federal, State, and City Planning to Recover from an RDD or IND Incidents
paragraphs: FEMA has not issued specific guidance describing how federal capabilities  would be integrated into and support state and local plans for recovery  from RDD or IND incidents, as called for by presidential directive.  According to a senior FEMA official, the agency has delayed issuing this  guidance pending the reevaluation of its planning approach by the new  administration. However, a senior FEMA planning official told us that  because FEMA is already aware that its planning system does not fully  recognize the involvement of state and local governments, the agency is  developing regional support plans—including for RDD and IND  incidents—through its regional offices, which will reflect state and local  government roles and responsibilities. Moreover, according to FEMA  officials, in August 2008, DHS issued stop-gap guidance outside of FEMA’s  planning guidance framework to provide some immediate direction to  federal, state, and local emergency response officials in developing their  own operational plans and response protocols for protection of emergency  workers after RDD or IND incidents. In regard to recovery, EPA officials  informed us that FEMA and other federal agencies worked together on  this guidance in an attempt to clarify the processes for providing federal  cleanup assistance following such an incident. These officials informed us  that DHS’s guidance was intended to cover the existing operational  guidelines for implementing the protective action guides and other  response actions, and to encourage their use in developing specific  response protocols. In responding to a draft of this report, EPA informed  us that DOE had convened an interagency workgroup to address gaps in  DHS’s guidance and had issued a preliminary report, for comment by  September 30, 2009, containing additional operational guidelines to  respond to an RDD incident. Moreover, these officials indicated that EPA  has also worked with other federal agencies to examine its own 1992  protective action guides to address shortcomings and to incorporate more  recent guidance. However, according to EPA officials, much work  remains to convert the new guidance into operational guidance. In  addition, DOD has established operational plans for consequence  management following terrorist incidents, including RDD and IND  attacks.
Without federal guidance for coordinating federal, state, and local  planning for recovery from RDD or IND incidents, cities and states lack a  framework for developing their own recovery strategies. Emergency  management officials representing all 13 cities and their states in our  survey indicated that while their jurisdictions had prepared emergency  response and recovery plans for domestic incidents, few of these plans  specifically addressed RDD and IND recovery activities, particularly for  the analysis and environmental cleanup of areas contaminated with  radioactive materials. For example, few city respondents (3 of 13)  indicated that their recovery plans included preparations for an RDD  incident, although respondents from two cities indicated that their cities  were drafting these plans. In regard to IND preparation, all city  respondents informed us that recovery planning was still important  despite the magnitude of such events, but none of them had prepared such  plans. Respondents from all states in our survey indicated that they had  prepared emergency response plans for domestic incidents, and most of  them (8 of 10) indicated that these plans included a recovery component.  However, we were told that few of these recovery plans address an RDD  incident, or specific analysis and environmental cleanup activities  following such an incident, although respondents from 8 states mentioned  that they planned to prepare such plans. The lack of recovery planning for  RDD and IND incidents may be due, in part, to the relatively low priority  given to preparing for them by city and state emergency management  officials that we surveyed when compared with other types of risks facing  their jurisdictions. For example, the majority of city respondents indicated  that natural disasters, such as severe weather and infrastructure failure,  were the most significant risks facing their jurisdictions.
section_title: Federal Agencies Have Conducted Few Exercises to Test Recovery Plans for RDD or IND Incidents
paragraphs: Federal agencies and local jurisdictions have used existing federal  guidance as a basis for planning RDD and IND response exercises and, to a  much lesser extent, recovery exercises to test the adequacy of their plans  and level of preparedness. According to DHS guidance, preparedness is  the foundation of a successful national incident management system  involving all levels of government and other nongovernmental  organizations as necessary. The cycle of preparedness for prevention,  protection, response, and recovery missions ends with adequate  exercising, evaluation, and improvement. Our search of FEMA’s National  Exercise Schedule—a scheduling system for federal, state, and local  exercises—revealed 94 RDD or IND response exercises planned and  carried out by these authorities from May 2003 through September 2009.  These exercises were identified as either full-scale, tabletop, workshop,  seminar, functional, or a drill, and some locations have conducted several  of them over a period of time. While many of these exercises listed both  response and recovery objectives, as well as other exercise objectives,  officials with FEMA’s National Exercise Division told us that only three of  them actually included a recovery component that exercised activities  associated with environmental cleanup. However, our survey of city, state,  and federal regional office emergency management officials found that  many response and a few recovery exercises were conducted over the last  6 years that do not appear in FEMA’s National Exercise Schedule. We  previously reported that information in the National Exercise Schedule  database was unreliable. Nevertheless, for the purpose of this report, it is  clear that very few RDD and IND response exercises have included a  recovery component. According to National Exercise Division officials, a  recovery discussion following an RDD or IND response exercise has  typically not occurred because of the time needed to fully address the  response objectives of the exercise, which are seen as a higher priority.
While two response exercises in 2003 and 2007 included brief follow on  recovery discussions, a more recent exercise set aside more time for this  discussion. The most recent RDD response exercise, based in Albany, New  York, set aside 2 days (June 16-17, 2009) for federal, state, and local  agencies to discuss operational recovery issues. One unresolved  operational recovery issue discussed during this exercise pertained to the  transition of the leadership of FRMAC from the initial analysis of the  contaminated area, led by DOE, to the later cleanup phase, led by EPA.  For example, there are unresolved operational issues regarding the level  and quality of the monitoring data necessary for EPA to accept the  leadership of FRMAC from DOE. According to EPA officials, while this  transitional issue has been discussed in exercises dating back to the  development of the Federal Radiological Emergency Response Plan in  1984, it has only recently been discussed in RDD or IND response  exercises. Another unresolved operational recovery issue discussed during  this exercise pertained to the distribution of responsibilities for the  ownership, removal, and disposal of radioactive debris from RDD or IND  incidents. According to EPA exercise planning documents, both of these  operational issues are to be addressed again in the first full-scale RDD  recovery exercise—Liberty RadEx—set to take place April 26-30, 2010, in  Philadelphia, Pennsylvania. According to an EPA coordinator for this  event, this exercise is to focus on a few technical recovery issues involving  intergovernmental coordination, such as setting environmental cleanup  priorities and levels, as well as managing radioactive waste staging and  disposal. Appendix II contains a brief summary of three national-level  exercises, since May 2003, which contained a recovery component, along  with the exercise objectives for the planned April 2010 RDD exercise,  which is to contain a recovery component. In addition to this RDD  recovery exercise, the National Exercise Schedule has listed two planned  IND response exercises in 2010 that are to have some recovery  components.
section_title: Uncertainty about Federal Capability to Effectively Clean up Areas Contaminated with Radioactive Materials from RDD or IND Incidents
paragraphs: It is uncertain whether federal capability is sufficient to effectively clean  up from RDD or IND incidents because federal agencies have only carried  out environmental cleanup of localized areas of radioactive materials, and  some limitations exist in federal capabilities to help address the magnitude  of the cleanup that would follow these incidents.
subsections: section_title: Effectiveness of Environmental Cleanup Methods and Technologies Following RDD or IND Incidents Are Untested on a Large Scale
paragraphs: Some federal agencies, such as DOE and EPA, have substantial experience  using various analysis and environmental cleanup methods and  technologies to address localized areas contaminated with radioactive  materials, but little is known about how these methods and technologies  might be applied in recovering from the magnitude of RDD or IND  incidents. For example, DOE has invested hundreds of millions of dollars  in research, development, and testing of methods and technologies for  cleaning up and decommissioning contaminated structures and soils— legacies of the Cold War. In addition, since the passage of the  Comprehensive Environmental Response, Compensation, and Liability Act  (CERCLA), which established the Superfund program, EPA has  undertaken significant efforts to study, develop, and use technologies that  can address radioactive contamination. DOD has also played a major role  in studying potential applications for innovative technologies for its  Superfund sites.
As a result of federal agencies’ experience with radioactive materials,  there is evidence that the agencies could effectively carry out the analysis  and environmental cleanup of localized areas contaminated by these  materials. In regard to analysis, DOE’s National Nuclear Security  Administration (NNSA) has developed operational plans, orders, and  publications on how to respond to a radiological or nuclear incident.  NNSA has developed various FRMAC manuals to guide operational,  assessment and monitoring activities. In addition, EPA’s National  Decontamination Team has published guidelines that provide a framework  for how to develop sampling plans to support decontamination efforts  after a radiological release. In regard to environmental cleanup, EPA has  published inventories of radiological methods and technology guidance for  contaminated sites, surfaces, and media. The cleanup technologies are  generally grouped into chemical and physical technologies. During the  initial response phase to an incident, responders might rely on fairly  simple cleanup approaches, such as washing down exposed people and  surfaces, mowing grass, pruning trees, and sweeping up affected areas.  The latter recovery phase might require no additional action or use of  complex decontamination technologies depending on the level of desired  cleanup. EPA has also published guidance for its On-Scene Coordinators  at each regional office to aid in their response to a radiological incident.  This guidance covers the full range of radiological incidents, but its focus  is primarily on the early to intermediate phases of an RDD incident, as this  incident is expected to present a challenge for these coordinators. This  guidance addresses possible decontamination approaches for eight types  of radionuclides that experts believe are most likely to be used in an RDD.
As previously mentioned, federal agencies’ current approaches to analysis  and environmental cleanup have only been applied in localized areas, as  an RDD or IND incident has not occurred; however, decontamination  research is currently under way to gain a better understanding of potential  applications of current and experimental methods and technologies for  primarily RDD incidents. According to decontamination experts at DOE’s  Lawrence Livermore National Laboratory, current research has focused on  predicting the effects of radiation release in urban settings through  simulation, small-scale testing, and theory. In addition, researchers at  EPA’s National Homeland Security Research Center informed us that  while there are available methods that have proven successful for cleaning  up various types of contamination, more research is needed to develop  standard national guidance for their efficacious application in urban areas  and to other RDD or IND incident scenarios. According to a  decontamination expert at DOE’s Idaho National Laboratory, experience  has shown that without guidance and discussion early in the response  phase, a contractor might use a decontamination technology during this  phase for no other reason than it was used before in an unrelated  situation. The expert told us that this situation might lead to selecting  environmental cleanup technologies that generate waste types that are  more difficult to remove than the original material and that create more  debris requiring disposal—leading to increased costs. For example, the  Lawrence Livermore National Laboratory decontamination experts told us  that the conventional use of high-pressure hosing to decontaminate a  building is effective under normal conditions but could be the wrong  cleanup approach for an RDD using cesium-137. In this case, the imbibing  (absorbing) properties of some porous surfaces such as concrete would  actually cause this soluble radioactive isotope to penetrate even further  into surfaces making subsequent decontamination more difficult and  destructive. A senior EPA official with the Office of Radiation and Indoor  Air told us that the agency has studies under way to determine the efficacy  of high-pressure hosing for removing contamination from porous urban  surfaces that would result from the terrorists’ use of an RDD using certain  radioisotopes.
section_title: Limitations in Federal Capabilities to Address Magnitude of Cleanup Following RDD or IND Incidents
paragraphs: There are also limitations in federal capabilities to help address, in a  timely manner, the magnitude of cleanup that would be associated with  RDD or IND incidents. For example, we found that limitations in federal  capabilities to complete some analysis and environmental cleanup  activities might slow the recovery from an incident, including (1)  characterizing the full extent of areas contaminated with radioactive  materials, (2) completing laboratory validation of contaminated areas and  levels of cleanup after applying decontamination approaches, and (3)  removing and disposing of radioactive debris and waste.
subsections: section_title: Characterizing Areas Contaminated with Radioactive Materials
paragraphs: There are some limitations in the capability of federal agencies to  efficiently characterize the full extent of the areas contaminated with  radioactive materials in the event of RDD or IND incidents. For example,  the current predictive capability of various plume models is not sufficient,  and may never be sufficient to reduce the time necessary to fully  characterize the extent of contaminated areas after RDD or IND  incidents. According to a senior official at the Lawrence Livermore  National Laboratory’s Interagency Modeling and Atmospheric Assessment  Center (IMAAC), the predictive capabilities of existing plume models are  not at the resolution necessary to produce this added value for urban  areas, as modeling for this purpose is only theoretical at this point. This  official told us while there are data about debris dispersal from building  demolition and weapons testing, there is little research data on the likely  dispersal patterns of concrete, asphalt, and glass that would result from  use of an RDD or IND. However, some federal agency officials question  the need to improve the predictive capabilities of these plume models. For  example, the DHS IMAAC director told us that the current state-of-the-art  and plume modeling approach is sufficient for its primary purpose in  directing the protective actions of first responders. Nevertheless, NNSA  officials informed us they are working with FEMA on a multiyear program  to improve federal capabilities to model the release of material during a  radiological or nuclear incident. However, they contend that plume  modeling will never replace the need for actual measurements for  radioactive contamination. In commenting on a draft of this report, EPA  agreed that characterization of areas contaminated with radioactive  materials from RDD or IND incidents would be challenging because  existing plume models are not entirely applicable to urban areas.   Moreover, EPA added that other types of contamination, such as in the  drinking water and wastewater infrastructure, would also involve very  complex systems that would be difficult to model.
section_title: Completing Laboratory Validation of Areas Contaminated with Radioactive Materials
paragraphs: There are some limitations in federal capabilities to complete laboratory  validation of contaminated areas and levels of cleanup after applying  decontamination approaches. Moreover, FEMA’s proposed process for  determining cleanup standards during the recovery phase for RDD and  IND incidents has not been fully exercised, although there was a tabletop  discussion among government officials in a June 2009 exercise. EPA has  conducted an examination of federal, state, local, and private laboratory  capabilities to conduct environmental sampling and testing in order to  determine the nationwide laboratory capacity required to support  environmental monitoring and decontamination of chemical, biological,  and radiochemical-nuclear agents. EPA determined that there was a  significant capacity and competency gap in efficiently meeting the  laboratory evaluation needs for an RDD scenario. In addition, while EPA  did not conduct a detailed assessment of the national planning scenario  for an IND incident, it determined that such an incident could contaminate  3,000 square miles and require potentially millions of samples for  laboratory analysis. According to EPA documentation, the gap in  laboratory capacity would result in the lack of timely, reliable, and  interpretable data, which would delay national and local response and  recovery activities. EPA has documented that it is currently establishing  an all-media Environmental Response Laboratory Network, and it is also  conducting a demonstration project to enhance the capacity and capability  of public laboratories.
A related environmental cleanup issue pertains to the process for  determining the cleanup standards that would be applied to urban areas  contaminated with radioactive materials in recovering from RDD or IND  incidents. According to a decontamination expert at the Idaho National  Laboratory, an important consideration in decontamination is the starting  level of radioactivity and desired ending level. This official told us that no  technology removes all of the contamination all the time; some  technologies are more efficient than others at removing certain kinds of  contamination. The current DHS planning guidance for RDD and IND  incidents recommends a framework for incident cleanup and recovery  using a process called “site-specific optimization” for determining the level  of environmental cleanup after RDD or IND incidents. The guidance  recommends that this process include potential future land uses, technical  feasibility, costs, cost-effectiveness, and public accountability. In  commenting on a draft of this report, EPA informed us that draft guidance  intended to outline the structure of, and responsibilities for the conduct of  the optimization process as they pertain to EPA’s involvement in RDD or  IND incidents is under review by the new Administrator.  EPA added that  it looks forward to the lessons to be learned from the upcoming Liberty  RadEx exercise in 2010, which officials believe should provide significant  insights into the issues under discussion in this report.
section_title: Storing and Disposing of Waste from Areas Contaminated with Radioactive Materials
paragraphs: There are also limitations in federal capabilities to help state and local  governments address the interim storage and eventual disposal of the  radioactive waste that would arise from RDD or IND incidents. The   National Science and Technology Council’s 2008 report found gaps in our  nation’s capabilities to effectively remove and dispose of radioactive  debris in the event of an RDD or IND incident. This is due, in part, to  current restrictions on accessing possible disposal facilities for the  radioactive debris stemming from such incidents. According to NNSA  officials, DOE’s disposal sites currently can only accept low-level and  mixed low-level radioactive waste from its own and DOD facilities under  certain circumstances. Moreover, according to an EPA decontamination  expert, EPA is concerned about access to commercial radioactive waste  disposal sites in the event of such an incident. Currently, there is only one  low-level radioactive waste disposal site located in Utah that could be  used by most states for radioactive debris disposal, although a limited  number of states have access to low-level radioactive waste disposal  facilities for waste generated by users of radioactive materials in their  states. Another issue is paying for waste disposal. In the Superfund  program, EPA can bill the responsible party, if known. However, covering  the cost of waste disposal would be complicated in the case of RDD or  IND incidents. One additional complicating factor would be the mixing  and problematic separation of radioactive, biological, and chemical  materials in the debris that would stem from such incidents. According to  a recent research paper on disposal issues, the proper characterization of  the quantity, properties, and level of debris contamination and  decontamination residue from an RDD or other radiological incidents can  have significant impacts on cleanup costs and restoration timelines. In  commenting on a draft of the report, EPA officials informed us that its   Office of Research and Development is currently developing a suite of  decision support tools for the management of waste and debris from a  variety of different events, including radiological incidents.
section_title: Concerns about Federal Capabilities from Survey Respondents
paragraphs: Concerns about limitations in these federal capabilities were expressed by  many city, state, and federal regional office emergency management  officials who responded to our survey. Respondents representing most of  the cities (9 of 13), states (7 of 10), FEMA regional offices (6 of 9), and  almost all EPA regional offices (9 of 10) expressed concerns about the  capabilities of federal agencies to provide the assistance needed to  complete the necessary analysis and environmental clean up activities in  the event of RDD or IND incidents. For example, respondents from several  cities told us that they were concerned about how rapidly the federal  government could provide this assistance, despite the strengthening of  some capabilities since the terrorist attack of September 11, 2001.  Respondents from most states expressed the same expectations of the  federal government. For example, one state was particularly concerned  about current federal capabilities to handle multiple and simultaneous  RDD incidents across the country.
The National Science and Technology Council’s 2008 report also found  that cities and states would need to rely heavily on a strong federal  response to a radiological incident. This report identified similar  limitations in federal capabilities to rapidly characterize an incident site  and contaminated critical infrastructure, contain and control contaminant  migration, decontaminate and cleanup affected areas, and remove and  dispose of the waste to facilitate long-term recovery. Moreover, the report  claimed that catastrophic effects of RDD or IND incidents could be  reduced and the path to recovery shortened with more effective  decontamination, mitigation, and rapid recovery operations.
section_title: City, State, and Federal Emergency Management Officials Provided Suggestions to Improve Federal Recovery Preparedness for RDD and IND Incidents
paragraphs: City and state emergency management officials responding to our survey,  as well as emergency management officials at EPA and FEMA regional  offices across the country, provided a number of suggestions for ways to  improve federal recovery preparedness for RDD and IND incidents,  particularly with the environmental cleanup of areas that would be  contaminated with radioactive materials from such incidents. Respondents  from nearly all the cities and states expressed the need for a national  disaster recovery strategy to address gaps and overlaps in current federal  guidance in the context of RDD and IND incidents.  This is important  because, according to one city official, “recovery is what it is all about.” In  developing such a recovery strategy, respondents from the cities, like  those from their states, want the federal government to consult with them  in the initial formulation of a recovery strategy through working and focus  groups, perhaps organized on a regional basis. Respondents representing  most cities (10 of 13) and states (7 of 10) also provided specifics on the  type of planning guidance necessary, including integration and  clarification of responsibilities among federal, state, and local  governments. For example, respondents from some of the cities sought  better guidance on monitoring radioactivity levels, acceptable cleanup  standards, and management of radioactive waste. Most respondents from  cities expressed the need for greater planning interactions with the federal  government and more exercises to test recovery plans. One city  respondent cited the need for recovery exercises on a regional basis so the  cities within the region might better exchange lessons learned.  Respondents from most cities (11 of 13) and their states (7 of 10) said that  they planned to conduct RDD and IND recovery exercises in the future.  Finally, emergency management officials representing almost all cities and  states in our survey offered some opinions on the need for intelligence  information on RDD and IND threats. They generally said that sharing  information with law enforcement agencies is necessary for appropriate  planning for RDD or IND incidents and that the law enforcement fusion  centers were a step in the right direction. However, only half of the  respondents indicated that they were getting sufficient intelligence  information from law enforcement sources.
The EPA and FEMA regional office emergency management officials that  responded to our survey also offered a number of suggestions on ways to  improve federal preparedness to recover from RDD and IND incidents,  generally concurring with the suggestions of the city and state  respondents. The majority of the EPA regional offices (6 of 10) and FEMA  regional offices (7 of 9) indicated that a national disaster recovery strategy  was needed to address overlaps and gaps in current government  responsibilities in the context of RDD and IND incidents. Almost all of  them stressed the need to reach out and involve state and local  governments in developing this recovery strategy. The majority of the EPA  regional office (7 of 10) and FEMA regional office (5 of 9) respondents  indicated that additional guidance was needed on the distribution of  government responsibilities for the recovery phase of RDD or IND  incidents, including the transfer of FRMAC responsibilities and the  process for determining acceptable cleanup levels. Many of the federal  regional office respondents mentioned the need to conduct recovery  exercises that involve state and local governments. Finally, EPA and  FEMA regional office respondents differed somewhat on the need for  standard national guidance on the application of approaches for  environmental cleanup of areas contaminated with radioactive materials.  While about half of the EPA regional office respondents expressed the  need for guidance on the application of existing approaches for RDD or  IND incidents, most FEMA regional office respondents (7 of 9) indicated  that it would be beneficial to synchronize existing guidance from multiple  and disparate sources to ensure that they are complementary and not  competing.
section_title: The United Kingdom’s Handling of the 2006 Polonium Incident and Subsequent Actions Provide Information That May Help U.S. Federal Agencies Prepare for RDD and IND Incidents
paragraphs: While it was more limited in scope than what is usually envisioned as an  RDD incident, the aftermath of the 2006 polonium poisoning incident in  London had many of the characteristics of an RDD incident, including  testing hundreds of people who may have been exposed to radiation and a  cleanup of numerous radiation-contaminated areas. Because of its  experience in dealing with the cleanup from this incident and from other  actions the United Kingdom has taken to prepare for an RDD or IND  attack, we met with officials from this country to obtain a better  understanding of their approach to recovery preparedness. These officials  told us that the attention to recovery in their country is rooted in decades  of experience with the conflict in Northern Ireland, dealing with  widespread contamination from the Chernobyl nuclear power plant  accident, and a national history of resilience—that is, the ability to manage  and recover from hardship. We found that actions the United Kingdom  reported taking to prepare for recovery from RDD and IND incidents are  similar to many of the suggestions for improvement in federal  preparedness that we obtained through our survey of city, state, and  federal regional office emergency management officials in the United  States. For example, we found that the United Kingdom reported taking  the following actions:    Enacted civil protection legislation in 2004. This civil protection legislation  includes subsequent emergency response and recovery guidance, issued in  2005, to complement the legal framework established for emergency  preparedness. This guidance describes the generic framework for  multiagency response and recovery for all levels of government. The  guidance emphasizes that response and recovery are not discrete activities  and do not occur sequentially; rather, recovery should be an integral part  of response from the very beginning, as actions taken at all times can  influence longer-term outcomes for communities.
Established a Government Decontamination Service in 2005. This  organization was created out of recognition that it would not be cost- effective for each entity—national, regional, and local government—to  maintain the level of expertise needed for cleaning up chemical, biological,  radiological, and nuclear materials, given that such events are rare. The  Government Decontamination Service provides advice and guidance to  local governments, maintains and builds a framework of specialized  analysis and environmental cleanup contractors, and advises the national  government regarding response capabilities. This service implemented its  responsibilities by assisting the City of Westminster respond to the  analysis and environmental cleanup needs following the November 2006  polonium poisoning of Alexander Litvinenko.
Developed online national recovery guidance in 2007. This guidance  reinforces and updates the early emergency response and recovery  guidance by establishing, among other things, a recovery planning process  during the response phase so that the potential impacts of early advice and  actions are explored and understood for the future recovery of the  affected areas. Moreover, the guidance—reviewed every 3 months and  updated as necessary—emphasizes the need for training recovery  personnel on essential roles, responsibilities, and procedures to test  competencies, as well as to design and conduct recovery exercises.
Updated the recovery handbooks for radiation incidents in 2008 and 2009.
The handbooks are intended to aid decision makers in developing  recovery strategies for contaminated food production systems, drinking  water, and inhabited areas following the release of radioactive materials  into the environment. The handbooks were first published in 2005 in  response to the Chernobyl nuclear power plant accident. The current  handbooks include management options for application in the prerelease,  emergency and longer-term phases of an incident. Sources of  contamination considered in the handbooks include nuclear accidents,  radiological dispersion devices, and satellite accidents. The handbooks are  divided into several independent sections comprising supporting scientific  and technical information, an analysis of the factors influencing recovery,  compendia of comprehensive, state-of-the-art datasheets for around 100  management options, guidance on planning in advance, a decision-aiding  framework comprising color-coded selection tables, look-up tables and  decision trees, and several worked examples. The handbooks can also be  applied for training purposes and during emergency exercises.
Conducted a full-scale RDD recovery exercise in 2008. This exercise,  involving several hundred participants, provided a unique opportunity to  examine and test the recovery planning process within the urgency of a  compressed time frame. The exercise, which took place 6 weeks after the  response exercise, had participants address three scenarios: rural  contamination of crops and livestock, contamination of the urban transit  infrastructure, and disruption of the water supply. The lessons learned  from this exercise were incorporated into the United Kingdom’s recovery  strategy. One key lesson is the benefit of exercising the handover of  government leadership during the response phase to leadership of the  recovery phase.
Established a national risk register in 2008. This register provides  information on the risks facing the country, including malicious attacks  such as with an RDD. This threat information was previously held  confidential by the government. The government reported that the release  of this information is intended to encourage public debate on security and  help organizations, individuals, families, and communities that want to  prepare for these emergencies. This register is designed to complement  community risk registers that have been published by local emergency  planners since passage of the 2004 civil protection legislation. The  community risk registers are based on local judgments of risks, as well as  from information contained in the national risk assessment—a 5-year  planning assessment that is still a classified document. The government  has conducted this risk assessment since 2005.
Issued specific nuclear recovery planning guidance in 2009. This guidance,  the UK Nuclear Recovery Plan Template, provides a generic recovery  strategy and structures needed to address a radiological release from a  civil or defense nuclear reactor, as well as incidents involving nuclear  weapons and special nuclear materials in transit. It is also considered  applicable to recovery from RDD and IND incidents. Among other things,  it provides guidance on the formation of a Recovery Advisory Group and  Science and Technology Advisory Cell early in the response phase. The  Recovery Advisory Group would be charged with identifying immediate  and high-level strategic recovery objectives—recorded in templates to  keep the process focused and on track—for, among other activities,  cleanup levels, management of radioactive waste, compensation  arrangements, and recovery costs. This advisory group would transition  into a broader Strategic Recovery Coordinating Group during the recovery  phase. The guidance requires that all high-risk cities in the United  Kingdom prepare recovery plans.
Finally, according to United Kingdom officials, the 2006 polonium incident  in London showed the value of recovery planning. In particular, through  this incident, United Kingdom officials gained an appreciation for the need  to have an established cleanup plan, including a process for determining  cleanup levels, sufficient laboratory capacity to analyze a large quantity of  samples for radiation, and procedures for handling the radioactive waste.  Furthermore, they found that implementing cleanup plans in the polonium  poisoning incident and testing plans in the November 2008 recovery  exercise have helped the United Kingdom to better prepare for larger RDD  or IND incidents. Appendix III contains a more thorough review of the  approach to recovering from RDD and IND incidents in the United  Kingdom.
section_title: Conclusions
paragraphs: Recovering from RDD or IND incidents would likely be difficult and  lengthy. Completing the analysis and environmental cleanup of areas  contaminated with radioactive materials would be among the first steps in  the recovery process after the initial response to save lives. A faster  recovery—meaning people can return sooner to their homes and  businesses and get back to the routines of everyday life—would help  lessen the consequences of RDD and IND incidents. In fact, being fully  prepared to recover from such an incident may also serve as a deterrent to  those who would do us harm.
However, our work demonstrates that the federal government is not fully  prepared to help cities and states with the analysis and environmental  cleanup of areas contaminated with radioactive materials from RDD and  IND incidents. To date, FEMA has not developed a national disaster  recovery strategy, as required by law, which would help guide RDD and  IND recovery planning, or issued specific guidance to coordinate federal,  state, and city recovery planning for these incidents. Federal agencies have  also included only a few recovery discussions in the response exercises to  these incidents. The lack of clearly communicated guidance on federal  responsibilities and activities has left emergency management officials in  the cities and states we surveyed confused about which federal agency to  turn to for assistance, and many federal regional office officials we  surveyed were not certain about which environmental cleanup methods  and technologies would be the most successful in removing radioactive  materials from buildings and infrastructure.
As the United States moves forward in recovery preparation, some insights  might be gained from the actions already taken by the United Kingdom to  increase its preparedness to recover from acts of nuclear and radiological  terrorism, many of which are similar to those suggested by the city, state,  and federal emergency management officials we surveyed for improving  federal preparedness to recover from RDD and IND incidents.
section_title: Recommendations for Executive Action
paragraphs: To better prepare federal agencies to coordinate with state and local  governments on the analysis and environmental cleanup of areas  contaminated with radioactive materials following RDD or IND incidents,  we recommend that the Secretary of Homeland Security direct the Federal  Emergency Management Agency Administrator to prepare a national disaster recovery strategy that would clarify federal  responsibilities for assisting state and local governments with the  analysis and environmental cleanup of areas contaminated with  radioactive materials in the event of RDD or IND incidents;  issue guidance that describes how federal capabilities would be  integrated into and support state and local plans for recovery from  RDD and IND incidents; and schedule additional recovery exercises, in partnership with other  federal, state, and local governments that would, among other things,  specifically assess the preparedness of federal agencies and their  contractors to conduct effective and efficient analysis and  environmental cleanup activities associated with RDD and IND  incidents.
section_title: Agency Comments and Our Evaluation
paragraphs: GAO provided DHS, DOE, and EPA with a draft of this report for their  review and comment. DHS and FEMA concurred with the  recommendations in the report. DOE, through NNSA, generally agreed  with our report findings and provided technical comments, which we  incorporated as appropriate. EPA did not agree or disagree with the report  findings, but offered technical comments, which we incorporated as  appropriate.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date.  At that time, we will send copies of this report to the  appropriate congressional committees as well as to the Secretaries of  Homeland Security and Energy; the Administrators of NNSA and EPA; and  other interested parties. The report will also be available at no charge on  the GAO Web site at http://www.gao.gov.
If you or your staffs have any questions about this report, please contact  me at (202) 512-3841 or aloisee@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff who made key contributions to this report are  listed in appendix IV.
section_title: Appendix I: Scope and Methodology
paragraphs: In our review, we examined (1) the extent to which federal agencies are  planning to fulfill their responsibilities to help cities and states clean up  areas contaminated with radiation materials from radiological dispersal  device (RDD) and improvised nuclear device (IND) incidents, (2) what is  known about the federal government’s capability to effectively clean up  areas contaminated with radioactive materials from RDD and IND  incidents, and (3) suggestions from government emergency management  officials for improving federal preparedness to help cities and states  recover from RDD and IND incidents. In addition, we are providing  information on actions taken in the United Kingdom to prepare for  recovering from RDD and IND incidents.
To determine the extent to which federal agencies are planning to fulfill  their responsibilities to help cities and states clean up areas contaminated  with radioactive materials from RDD and IND incidents, we reviewed  pertinent federal law, presidential directives, and other executive  guidance; interviewed cognizant officials from the Department of  Homeland Security (DHS), Department of Energy (DOE), Environmental  Protection Agency (EPA), Federal Emergency Management  Administration (FEMA), and Nuclear Regulatory Commission (NRC);  conducted a survey of 13 cities considered to be at high or medium risk to  such attacks and their states, and all federal FEMA and EPA regional  offices; and reviewed information on the number and type of RDD and  IND response and recovery exercises that have been conducted from May  2003 through September 2009. More specifically, we reviewed existing  planning documents for domestic incidents to determine the extent to  which they addressed recovery issues, particularly from RDD and IND  incidents. For example, we found limited discussion of recovery planning  for these incidents in various annexes to the National Response  Framework, such as its emergency support function annexes and nuclear  and radiological incident annex, as well as other planning documents. In  addition, after speaking with emergency management officials in San  Francisco and comparable state officials near Sacramento, California, we  developed a semistructured telephone survey instrument—pretested in  Denver, Colorado—in order to obtain the perspectives of city and state  emergency management officials on government responsibilities and plans  to fulfill them. We originally selected 13 high- and medium-risk cities and  their 11 states to cover the mostly likely target cities for a terrorist attack  and to ensure that we had at least 1 city in each of the 10 EPA and FEMA  regions. The cities included Atlanta, Boston, Chicago, Dallas, Denver,  Detroit, Houston, Los Angeles, New York, Philadelphia, San Francisco,  Seattle, and St. Louis. While Washington, D.C., is considered a high-risk  city, we excluded it from our survey because it is unlike other cities in its  reliance on the federal government and the agencies that would take over  analysis and environmental remediation activities. Emergency  management officials representing these cities and their states responded  to our survey, except for Atlanta and the states of Georgia and  Massachusetts. After repeated attempts to include this city and the two  states in our survey, we decided to drop them. We replaced Atlanta and  the state of Georgia with Miami and the state of Florida, which are in the  same federal region. Because we decided to retain Boston despite  receiving no response from Massachusetts, we ended up with 10 states in  our survey. We also visited EPA regional offices in San Francisco and  Denver, and the FEMA regional office in Oakland, to develop questions to  survey all 10 EPA and FEMA regional offices in order to obtain a federal  field perspective on this issue. All EPA and FEMA regional offices  responded to our survey, except FEMA region 8. We tabulated the yes and  no responses to each pertinent question from the city, state, and federal  surveys and conducted a content analysis of the explanatory statements  accompanying many of the questions. FEMA’s National Exercise Schedule  database was used to identify the location and types of RDD and IND  response and recovery exercises—based on national planning scenarios.  Because we determined in our April 2009 report (GAO-09-369) that this  database is unreliable, we asked each city, state, and federal regional  office in our survey to list RDD and IND response and recovery exercises  that had taken place in their jurisdiction, as well as any plans for future  exercises to check the accuracy of the federal exercise database. In  addition, we attended the first full-scale recovery tabletop exercise— Empire09—based on an RDD incident scenario in Albany, New York that  was conducted on June 16-17, 2009, and an interagency planning session  held in Philadelphia on October 28-29, 2009, to prepare for the Liberty  RadEx recovery exercise scheduled for April 26-30, 2010 in Philadelphia.
To determine what is known about the federal government’s capabilities  to effectively clean up areas contaminated with radioactive materials from  RDD and IND incidents, we reviewed pertinent guidance on available  methods and technologies and obtained information from subject matter  experts at the federal agencies and national laboratories about their  potential application for RDD and IND incidents. More specifically, we  spoke with subject matter experts at the National Nuclear Security  Administration, EPA, and FEMA, as well as at DOE’s Lawrence Livermore  National Laboratory and Idaho National Laboratory and EPA’s Andrew W.  Breidenbach Environmental Research Center, National Air and Radiation  Environmental Laboratory, National Decontamination Team, National  Homeland Security Research Center, and the Radiation and Indoor  Environments National Laboratory. We also observed a demonstration of  the capabilities of the Interagency Modeling and Atmospheric Assessment  Center at Lawrence Livermore National Laboratory and some  decontamination research projects at the National Homeland Security  Research Center. In addition, we reviewed reports and documents from  these agencies, national laboratories, and research centers that addressed  methods and technologies for analysis and environmental remediation of  areas contaminated with radioactive materials as well as some that  specifically discussed their potential use for RDD or IND incidents.  Moreover, we included questions about the potential use of these  approaches in our semistructured phone survey of federal, state, and city  emergency management officials.
To identify suggestions from government emergency management officials  for improving federal preparedness to help cities and states recover from  RDD and IND incidents, we included relevant questions in our  semistructured phone survey of federal, state, and city officials. We  conducted a content analysis of these questions to identify patterns in the  responses, that is, what types of suggestions were most prevalent. We also  reviewed past GAO reports and other documents that addressed areas for  improvement in federal preparedness.
In addition, to broaden our review of potential areas for improvement in  federal involvement in planning and preparing for the recovery from RDD  and IND incidents, we included the United Kingdom in our scope. This  country has actual experience with recovery from a radiological incident  in an urban area and was suggested to us by EPA officials as a country that  is one of the leaders in recovery planning. We interviewed selected central  and regional government officials responsible for response and recovery  planning and preparation, and we visited a decontamination contractor  that performed environmental remediation activities in the aftermath of  the 2006 radioactive poisoning of Alexander Litvinenko in London. We also  reviewed documents provided by these officials and from other sources to  obtain a better understanding of this system and how it might apply to the  United States. Two officials from the United Kingdom who we interviewed  during our site visit reviewed a draft of the information contained in  appendix III for content and accuracy.
We conducted this performance audit from October 2008 to January 2010  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Recovery Exercises
paragraphs: Table 1 provides a brief summary of four RDD exercises, since May 2003,  which contained recovery objectives including a planned exercise for April  2010.
section_title: Appendix III: Radiological Recovery Experiences in the United Kingdom
paragraphs: The United Kingdom provides an example of another country’s efforts to  prepare to recover from a terrorist attack using chemical, biological,  radioactive, or nuclear materials. This country’s attention to recovery  needs is reflected in promulgating emergency response and recovery  legislation, establishing a government decontamination service, creating  online national recovery guidance, updating a recovery handbook for  radiation incidents, conducting a full-scale RDD recovery exercise,  establishing a community and national risk register system, and preparing  specific nuclear recovery planning guidance. The particular emphasis on  recovery activities in the United Kingdom has been linked to decades of  experience with the conflict in Northern Ireland, widespread  contamination from the Chernobyl nuclear power plant accident, and a  national history of resilience—that is, the ability to manage and recover  from hardship.
subsections: section_title: Emergency Response and Recovery Framework
paragraphs: The United Kingdom has established a framework for addressing the  release of radiological materials that prompted planning for the recovery  from these events. This framework was primarily established through the  2001 Radiation (Emergency Preparedness and Public Information)  Regulations and the 2004 Civil Contingencies Act, as well as guidance  issued pursuant to the Civil Contingencies Act. According to a senior  official from the United Kingdom’s Health Protection Agency, the radiation  regulations were developed in response to a European Union directive  following the 1986 Chernobyl, Ukraine, nuclear power plant accident.  These regulations require preparation of on- and off-site emergency  management plans for release of radioactive materials in the event of a  nuclear power plant accident, as well as the conduct of exercises to test  preparedness to respond to radiological releases. According to this  official, while the radiation regulations did not include directives to  prepare for recovery from such accidents, they established a Nuclear  Emergency Planning Liaison Group, which formed a Recovery Subgroup  to begin addressing this planning need.
The 2004 Civil Contingencies Act was enacted following a government  consultation exercise that concluded that previous legislation provided an  inadequate framework for civil protection against twenty-first century  risks, including terrorism. The Civil Contingencies Act established a  statutory framework of roles and responsibilities for local responders to  address the effects of the most serious emergencies facing the country.  Guidance issued pursuant to this legislation established an integrated  emergency management system, not unlike that in the United States,  comprising six related activities: anticipation, assessment, prevention,  preparation, response, and recovery. The November 2005 guidance  addressing emergency response and recovery covers the principles,  practical considerations, operational doctrine, and examples of good  practice for these activities. This guidance describes the generic  framework for multiagency response and recovery activities at all levels of  government, emphasizing that these activities are not separate activities  that occur sequentially. Instead, this guidance contends that recovery  considerations should take place early in the response phase, as initial  decisions can affect the long-term outcomes for communities. Moreover,  because the government recognized that no single approach could meet  the needs of every affected area, it did not intend this guidance to be either  prescriptive or an operational manual.
section_title: Government Decontamination Service
paragraphs: In 2005, the United Kingdom established a special Government  Decontamination Service to address issues associated with contaminated  land, buildings, open space, infrastructure, and transportation routes from  both deliberate and accidental releases of chemical, biological,  radiological, and nuclear materials. This service was established because  the national government recognized that it would not be cost-effective for  each responsible authority—national, regional, and local governments—to  maintain the level of expertise needed for the analysis and environmental  cleanup of affected areas given that the release of such material would be  a rare event. The Government Decontamination Service has no statutory  powers itself, nor does it directly provide analysis and environmental  remediation services. Instead, it provides advice and guidance to local  governments, maintains and builds a framework of specialized contractors  to conduct these activities, and advises the national government regarding  response capabilities.
In regard to advice to local governments, in November 2006, the  Government Decontamination Service was requested to respond to an  incident involving the poisoning of Alexander Litvinenko with a  milligram—about the size of a grain of salt—of polonium-210. This service  was asked to assist the City of Westminster, within greater London, given  the international nature of the event, even though the incident was  classified as a hazardous materials event rather then a terrorist incident.  According to the recovery planning process, the city selected a contractor  from the Government Decontamination Service list of specialized  contractors for the remediation work and used a model contract  developed by this service for this purpose. This model contract contains  allowable costs per unit, equipment charges, and charge out rates for the  emergency response. Under the contract, the selected specialized  contractor agrees to start off with nonaggressive, simple, and less  expensive decontamination approaches, and then apply more  sophisticated approaches, if necessary, to meet the desired cleanup level.  The actual payments for these services were made by the owners of  properties, such as a hotel where the perpetrators of the crime had stayed,  that were contaminated with polonium. However, the cleaning up of  public premises was a responsibility of the local government. The national  government has established ways to help cover the costs of such incidents.  This includes insurance coverage for damages resulting from acts of  terrorism. For large commercial concerns, the insurance industry offers  terrorist insurance that is underwritten by the government. For smaller  companies, terrorist insurance is offered for an additional 20 percent  surcharge on an existing policy. Other funding is available for local  governments if such an event would overwhelm their financial resources,  such as applying for grants from the national government or European  Union.
In regard to its framework of specialized contractors, the service has  identified three specialized contractors that have capabilities to address  various decontamination scenarios, and it certifies their capabilities  through testing. A specialized contractor is invited to visit the location,  receives a briefing on the incident scenario, and is asked to develop a  recommended decontamination strategy. The Government  Decontamination Service then assesses the contractor’s approach and  recommendations to identify issues, strengths, and weaknesses. In  addition, the service develops improvement plans, backed with exercises,  to address identified performance gaps. For example, in December 2007,  the Government Decontamination Service tested and evaluated the  capabilities of one of its specialized contractors to analyze and clean up  areas contaminated with radioactivity from an RDD event scenario in  downtown Birmingham. In Exercise Streetwise, a specialized contractor  was fully tested at the venue on its capability to detect and clean up actual  radioactive materials. According to a senior official with the Government  Decontamination Service, “you cannot get a realistic picture of recovery  needs and issues through only tabletop exercises.”
Finally, in regard to advice to national government, the Government  Decontamination Service participates in efforts to identify, prioritize, and  as necessary maintain decontamination-related research projects, and it  has established a library of the relevant knowledge and experiences drawn  from national and international sources. For example, a Government  Decontamination Service official told us that this agency is currently  engaged in learning more about how to deal with the disposal of  radioactive waste that has no known owner, which might be similar to the  radioactive waste stemming from an RDD incident. The issue is not only  ownership, but where to put the radioactive debris and how to cover the  cost of storage and disposal.  In this regard, the United Kingdom has a  clearance rule for allowing very low-level radioactive waste to be disposed  of in less expensive and more numerous solid and hazardous waste landfill  sites without specific regulatory approval or exemption. In addition, the  United Kingdom and the United States have agreed to increase the  exchange of information and personnel regarding the research,  development, testing, evaluation, and development of technical standards  and operations to address chemical, biological, radiological, and nuclear  incidents.
section_title: Online National Recovery Guidance
paragraphs: While passage of the 2004 Civil Contingencies Act was an important  legislative step to further emergency preparedness, the reaction of local  responders to several domestic incidents following passage of this act  made it clear to the national government that these responders needed  more comprehensive guidance than that contained in the 2005 guidance  for emergency response and recovery activities. One such event was the  July 2005 subway bombing in London by a terrorist group that killed 52  people. This incident, in conjunction with other events in 2005, such as the  Buncefield Fire and severe flooding, prompted the government in 2006 to  form a National Recovery Working Group to address the need for  additional recovery guidance for multiple risk scenarios. This working  group was comprised of a wide range of government departments and  agencies, as well as other stakeholders who had been involved in the  recovery phase following these events. The government charged this  working group with, among other things (1) producing national recovery  guidance for local responders, (2) identifying gaps in the country’s  recovery capability with recommendations to address them, and (3)  contributing to the ongoing review of the 2005 nonstatutory guidance for  emergency response and recovery activities. In 2007, the working group  produced a National Recovery Guidance document. This guidance  establishes a planning process for involving recovery stakeholders during  the response phase to ensure that the potential impact of early advice and  actions for the future recovery of the area are explored and understood.  This online guidance covers 14 generic issues, such as recovery structures  and processes, training and exercises, and a lessons learned process,  which are reviewed every 3 months and updated as necessary. For  example, the National Recovery Guidance addresses the need for training  recovery personnel on essential roles, responsibilities, and procedures to  test competencies, as well as the need to design and conduct recovery  exercises. While acknowledging that recovery training and exercises lag  behind those for response, the National Recovery Working Group found  that many organizations had already conducted small-scale recovery  exercises and had applied lessons learned from them. One of the lessons  identified was the need to exercise the shift from the response phase to  the recovery phase.
section_title: Updated Recovery Handbooks for Radiological Incidents
paragraphs: The 2009 version of the UK Recovery Handbooks for Radiological  Incidents is considered relevant to radiological releases—accidental and  intentional—from the nuclear and nonnuclear industry sectors. The  handbooks, first published in 2005 by the United Kingdom’s Health  Protection Agency, were developed in response to the need for further  recovery guidance following the Chernobyl nuclear power plant accident.  The development of these handbooks was sponsored by six government  departments and agencies representing national and local governments.  According to a senior official from the Health Protection Agency, the  European Union also supported the development of a series of generic  recovery handbooks for use by other countries based on the structure,  format, and content of the handbook developed for the United Kingdom.  This official told us that member countries of the European Union are  currently customizing their handbooks for use at national, regional, and  local levels. The current handbooks, updated from the 2008 version,  include management options for application in the prerelease, emergency  and longer-term phases of an incident. Sources of contamination  considered in the handbooks include nuclear accidents, radiological  dispersion devices, and satellite accidents. The handbooks are divided into  several independent sections comprising supporting scientific and  technical information, an analysis of the factors influencing recovery,  compendia of comprehensive, state-of-the-art datasheets for around 100  management options, guidance on planning in advance, a decision-aiding  framework comprising color-coded selection tables, look-up tables and  decision trees, and several worked examples. The handbooks can be  applied as part of the decision-aiding process to develop a recovery  strategy following an incident, for training purposes, and during  emergency exercises. An example of a datasheet for one of the  management options—high pressure hosing—contained in the UK  Recovery Handbooks for Radiation Incidents: 2009, is provided in figure 1.
section_title: RDD Recovery Exercises
paragraphs: In November 2008, Exercise Green Star tested government capabilities to  recover from a terrorist attack based on RDD scenarios. This was the  first time that complex recovery issues had been considered in a national- level exercise. In this exercise, several hundred participants were wholly  focused on recovery issues. About 6 weeks after an initial RDD tabletop  response exercise, which set the scene for the participants, a 2-day  recovery exercise took place involving three scenarios: rural  contamination of crops and livestock, contamination of the urban transit  infrastructure, and disruption of the water supply. On day one of the  exercise, participants looked at immediate cleanup issues, including  resource priorities and management responsibilities. On day two,  participants considered the longer-term issues of environmental  contamination, monitoring strategies, and financial considerations. The  use of a real radioactive isotope within the exercise scenario ensured that  participants were able to investigate their own and wider mechanisms for  obtaining scientific advice during an incident. A scientific advisory group  was put in place to expedite the recovery process by helping to manage  scientific input into the decision-making process. An after-action report  was prepared following this exercise to capture lessons learned. One  observation was that this exercise provided a unique opportunity to  develop remediation policies within a compressed time frame, resulting in  the development of a sound framework for recovery.
section_title: Community and National Risk Registration System
paragraphs: The United Kingdom has developed a comprehensive program to ensure  an effective response to a range of disruptive emergencies that might  affect the country. The country uses the term “resilience” as the ability of  organizations, like individuals, to withstand or recover easily and quickly  from hardships, such as major flooding or a terrorist attack. Community  risk registers have been published by local emergency management  planners since passage of the 2004 Civil Contingencies Act. These  community risk registers address specific risks identified by  representatives from local emergency services and public, private, and  voluntary organizations. Local resilience forums are required to develop  and maintain these registers that include a description of potential  outcomes, likelihoods, impacts, and ratings for various risk categories and  subcategories of events. One of the risk categories is an actual terrorist  attack using an explosive device. The national government does not  expect communities to directly track these risks, but rather to improve  their own preparedness based on information from the national risk  assessment, which is a classified document. In 2008, the government  published a national risk register, which is based on this classified  assessment and discusses the likelihood and potential impacts of a range  of risks facing the country, including attacks using chemical, biological,  radiological, and nuclear materials. This national risk register contains  information that was previously held confidential within government but  was published to encourage public debate on security and to help  organizations, individuals, families, and communities prepare for  encountering threats. The government reports that while there have been  very few examples of attacks such as the 1995 release of Sarin gas in a  Tokyo subway, it still recognizes the need to prepare and plan for them.
section_title: Specific Nuclear Recovery Planning Guidance
paragraphs: In March 2009, the Nuclear Emergency Planning Liaison group published a  UK Nuclear Recovery Plan Template based on the National Recovery  Guidance and Recovery Plan Guidance Template. This document  provides generic guidance for a recovery strategy and structures needed to  address a radiological release from a civil or defense nuclear reactor  accident, as well as from incidents involving nuclear weapons or special  nuclear materials in transit. This guidance is based on examples from  existing local government recovery plans and experiences. While not  specific to malicious use of radiological and nuclear materials, according  to a senior government official with the Health Protection Agency, this  guidance and associated monitoring templates would have potential  application for recovery from RDD or IND incidents.
The UK Nuclear Recovery Plan Template considers recovery to be more  than simply the replacement of what has been destroyed and the  rehabilitation of those affected—it is a complex social and developmental  process rather than just a remediation process. The manner in which  recovery processes are undertaken is thus critical to their success and,  therefore, best achieved when the affected community is able to exercise a  high degree of self-determination. As such, this document provides that  during the initial response phase, a Strategic Coordinating Group, which  manages this phase of the process, would receive input from a Recovery  Advisory Group and a Science and Technology Advisory Cell. The  Recovery Advisory Group would be charged with identifying immediate  and high-level strategic objectives for recovery early in the response  phase, including, among other actions, determining remediation levels and  when to stop remediation, managing radiation-contaminated waste, and  managing compensation arrangements and recovery costs. These  objectives would be accompanied by targets and milestones that the  community would use as a basis to track recovery progress—for example,  cleanup activities—with the aid of various predesigned templates. The  Science and Technology Advisory Cell would include experts to advise on  health and welfare, environment and infrastructure, and monitoring  response and recovery activities. On transition to the recovery phase of an  incident, the Strategic Coordinating Group would be replaced by a  Strategic Recovery Coordinating Group.
The Strategic Recovery Coordinating Group would be supported by  specific subgroups. These subgroups would include ones for finance and  legal, communications, business and economic recovery, health and  welfare, environment and infrastructure, and monitoring. For example, the  subgroup on environment and infrastructure would identify viable options  for remediation of food production systems, drinking water, and inhabited  areas, including identifying options for the restoration and cleanup of the  physical infrastructure and natural environment. The guidance suggests  that this subgroup consider forming task groups to, among other things,  address waste management and disposal, criteria to determine when  remediation can cease, evaluate feasibility, and recommend remediation  options for defined affected areas. The templates would be referred to  throughout the recovery to ensure that the work of the Strategic Recovery  Coordinating Group is focused and on track.
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the person named above, individuals who made important  contributions to this report were Dr. Timothy Persons (Chief Scientist),  Ned Woodward (Assistant Director), Nancy Crothers, James Espinoza,  Tracey King, Thomas Laetz, Jay Smale, Vasiliki Theodoropoulos, and Keo  Vongvanith.