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entitled 'Combating Nuclear Terrorism: Actions Needed to Better 
Prepare to Recover from Possible Attacks Using Radiological or Nuclear 
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Report to Congressional Committees: 

United States Government Accountability Office: 
GAO: 

January 2010: 

Combating Nuclear Terrorism: 

Actions Needed to Better Prepare to Recover from Possible Attacks 
Using Radiological or Nuclear Materials: 

GAO-10-204: 

GAO Highlights: 

Highlights of GAO-10-204, a report to congressional committees. 

Why GAO Did This Study: 

A terrorist’s use of a radiological dispersal device (RDD) or 
improvised nuclear device (IND) to release radioactive materials into 
the environment could have devastating consequences. GAO was asked to 
examine (1) the extent to which the federal government is planning to 
fulfill its responsibilities to help cities and their states clean up 
contaminated areas from RDD and IND incidents, (2) what is known about 
the federal government’s capability to effectively clean up these 
contaminated areas, and (3) suggestions for improving federal 
preparedness to help cities and states recover from these incidents. 
The report also discusses recovery activities in the United Kingdom. 
GAO reviewed federal laws and guidance; interviewed officials from the 
Department of Homeland Security (DHS), Federal Emergency Management 
Agency (FEMA), Department of Energy (DOE), and Environmental 
Protection Agency (EPA); and surveyed emergency management officials 
from 13 cities at high risk of attack, their 10 states, and FEMA and 
EPA regional offices. 

What GAO Found: 

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. 

What GAO Recommends: 

GAO recommends that, among other things, FEMA prepare a national 
recovery strategy that clarifies federal roles for cleaning up areas 
contaminated by attacks using RDDs or INDs, and schedule additional 
exercises to assess recovery preparedness. DHS and DOE agreed with our 
recommendations, and EPA did not agree or disagree with them. 

View [hyperlink, http://www.gao.gov/products/GAO-10-204] or key 
components. For more information, contact Gene Aloise at (202) 512-
3841 or aloisee@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

The Federal Government Has Not Completed Planning to Help Cities and 
States Clean up Areas Contaminated with Radioactive Materials from RDD 
or IND Incidents: 

Uncertainty about Federal Capability to Effectively Clean up Areas 
Contaminated with Radioactive Materials from an RDD or IND Incident: 

City, State, and Federal Emergency Management Officials Provided 
Suggestions to Improve Federal Recovery Preparedness for RDD and IND 
Incidents: 

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: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Recovery Exercises: 

Appendix III: Radiological Recovery Experiences in the United Kingdom: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Table: 

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

Figure: 

Figure 1: Example of a Datasheet on High Pressure Hosing for Cleaning 
Contaminated Surfaces in the UK Recovery Handbooks for Radiation 
Incidents: 2009: 

Abbreviations: 

CERCLA: Comprehensive Environmental Response, Compensation, and 
Liability Act: 

DHS: Department of Homeland Security: 

DOD: Department of Defense: 

DOE: Department of Energy: 

EPA: Environmental Protection Agency: 

FEMA: Federal Emergency Management Agency: 

FRMAC: Federal Radiological Monitoring and Assessment Center: 

IMAAC: Interagency Modeling and Atmospheric Assessment Center: 

IND: improvised nuclear device: 

NNSA: National Nuclear Security Administration: 

NRC: Nuclear Regulatory Commission: 

RDD: radiological dispersal device: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

January 29, 2010: 

The Honorable Bennie G. Thompson:
Chairman:
The Honorable Peter T. King:
Ranking Member:
Committee on Homeland Security:
House of Representatives: 

The Honorable Yvette D. Clarke:
Chairwoman:
The Honorable Daniel E. Lungren:
Ranking Member:
Subcommittee on Emerging Threats, Cybersecurity, and Science and 
Technology:
Committee on Homeland Security:
House of Representatives: 

The Honorable Michael T. McCaul:
Ranking Member:
Subcommittee on Intelligence, Information Sharing, and Terrorism Risk 
Assessment:
Committee on Homeland Security:
House of Representatives: 

A terrorist's use of either a radiological dispersal device (RDD)-- 
frequently referred to as a dirty bomb--or an improvised nuclear 
device (IND) to release radioactive materials into the environment 
could have devastating consequences. However, quickly analyzing and 
cleaning up contaminated areas from such an incident, particularly 
from an RDD attack, could speed up the recovery and allow restoration 
of normal operations of critical infrastructure, services, businesses, 
and public activities, thus reducing the many adverse consequences 
from an attack of this kind. Responding to such an attack would 
involve evacuations, providing medical treatment to those who were 
injured, and protecting property; recovery would include cleaning up 
areas contaminated with radioactive materials in order to permit 
people to return to their homes and businesses. According to a 2008 
report of the National Science and Technology Council, which 
coordinates science and technology policy within the Executive Office 
of the President, the ability of government to quickly and decisively 
respond to and recover from an RDD or IND incident is key to national 
resiliency.[Footnote 1] Importantly, the council noted that being 
prepared to recover from these incidents may even provide an element 
of deterrence if the adversary perceives less potential for 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).[Footnote 2] The 
Environmental Protection Agency (EPA) would take over leadership of 
FRMAC for coordinating the long-term monitoring of radiological 
contamination and supporting the detailed assessment of property 
contamination in the affected areas to support the cleanup of these 
areas. The Department of Defense (DOD), along with other agencies, 
would act in support of FRMAC. Federal agencies, including EPA, DOE, 
and the Nuclear Regulatory Commission (NRC), as well as state 
regulatory agencies have set various cleanup standards for areas 
contaminated with radioactive materials, but not specifically for RDD 
or IND incidents. The national laboratories have also provided 
research support assessing methods and technologies for analysis and 
environmental cleanup activities. 

The risk of terrorists using an RDD or IND is, in large part, 
determined by their ability to gain access to the materials needed to 
construct these devices. Over the past few years, we have issued a 
number of reports on the security of nuclear and radiological 
materials and facilities that house them. Overall, our work has shown 
that despite investing billions of dollars in new technology to 
upgrade security procedures, gaps continue to exist in our nation's 
ability to prevent terrorists from accessing or smuggling dangerous 
quantities of radioactive material into the country. For example, in 
2007, we testified before Congress that our own 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.[Footnote 3] Our investigators were able to 
obtain this NRC license just months after NRC had completed a lengthy 
process to strengthen its licensing procedures. In 2008, we reported 
that NRC, in developing its security requirements for research 
reactors, had not fully considered the risks associated with 
terrorists attacking these facilities--many of which are located on 
college campuses.[Footnote 4] Such an attack could involve terrorists 
sabotaging a reactor in order to disperse radioactive material over 
neighboring communities--similar to an RDD. We have also reported on 
DHS's and FEMA's preparedness for, response to, and recovery from 
disasters in 2007, 2008, and 2009.[Footnote 5] 

We were asked to review the federal government's preparedness to help 
cities and states recover from possible attacks using an RDD or IND. 
Accordingly, this report addresses the following: (1) the extent to 
which federal agencies are planning to fulfill their responsibilities 
to help cities and states clean up areas contaminated with radioactive 
materials from RDD and IND incidents, (2) what is known about the 
federal government's capability to effectively clean up areas 
contaminated with radioactive materials from RDD and IND incidents, 
and (3) suggestions from government emergency management officials for 
improving federal preparedness to help cities and states recover from 
RDD and IND incidents. In addition, we are providing information on 
actions taken in the United Kingdom to prepare for recovering from RDD 
and IND incidents. This report follows preliminary observations that 
we provided in testimony at a September 14, 2009, congressional 
hearing.[Footnote 6] 

To address these objectives, we examined pertinent federal law, 
presidential directives, and other executive guidance; interviewed 
cognizant officials from DHS, DOE, EPA, FEMA, NRC, and from both DOE 
and EPA national laboratories; and conducted a survey of emergency 
management officials in 13 cities considered to be at high or medium 
risk for an RDD or IND incident, officials in these cities' states, 
and federal emergency management officials in FEMA and EPA regional 
offices.[Footnote 7] We also reviewed information on the number and 
type of RDD and IND response and recovery exercises that have been 
conducted in the last 6 years. Finally, we visited the United Kingdom 
to review its preparedness to recover from RDD and IND incidents at 
the suggestion of EPA officials and because it has addressed a fairly 
recent radiological release incident in a large urban area. Appendix I 
provides more detail on our scope and methodology. 

We conducted this performance audit from October 2008 to January 2010 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

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.[Footnote 8] The dispersal of the polonium by the 
perpetrators of the crime and the victim resulted in widespread 
contamination across London and even abroad. His poisoning was 
detected only after he was hospitalized for a few weeks and tested for 
symptoms of radiation exposure because of hair loss. Following the 
poisoning, forensic investigators examined 47 sites across London for 
traces of polonium, both resulting from the handling of the polonium 
by his perpetrators and maybe other attempts to poison him. Of these 
locations, about 12 showed signs of this radioactive material, 
including a restaurant, hotel room, soccer stadium, and an eastbound 
British Airways plane. British investigators also identified over 
1,000 people who might have been in various ways exposed to the 
polonium. Health officials tested 738 of them and found that 137 had 
reportable levels of this substance, although few of these individuals 
turned out to have levels that warranted medical attention. The 
decontamination activities at these sites spanned 19 days, involved a 
number of methods and 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.[Footnote 9] 

The Federal Government Has Not Completed Planning to Help Cities and 
States Clean up Areas Contaminated with Radioactive Materials from RDD 
or IND Incidents: 

FEMA has not 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. 

FEMA Has Not Developed a National Disaster Recovery Strategy to Help 
Guide RDD or IND Recovery Planning: 

FEMA has not developed a national disaster recovery strategy, as 
required by law and directed by executive guidance, or issued specific 
guidance to coordinate federal, state, and local government recovery 
planning for RDD or IND incidents. The Post-Katrina Emergency 
Management Reform Act of 2006 requires FEMA to develop, coordinate, 
and maintain a national disaster recovery strategy.[Footnote 10] Among 
other things, the strategy is to clearly define the roles, programs, 
authorities, and responsibilities of each agency that may provide 
assistance to the recovery from a major disaster. In addition, the 
National Strategy for Homeland Security also called on the federal 
government to prepare a recovery strategy.[Footnote 11] The federal 
government has placed a higher priority on developing a strategy to 
respond to domestic incidents, including RDD and IND incidents, than 
it has on developing a comparable strategy for recovering from these 
incidents. For example, the response strategy, captured in the 2008 
National Response Framework, does not include guidance on long-term 
recovery activities.[Footnote 12] The FEMA coordinator for the 
development of a national disaster recovery strategy told us that 
while the previous administration had drafted a "white paper" 
addressing this strategy, the new administration has decided to 
rethink the entire approach.[Footnote 13] The FEMA coordinator also 
told us that FEMA recognizes its responsibility to prepare a national 
disaster recovery strategy but could not provide a time frame for its 
completion. This same official did say that in developing this 
strategy, FEMA plans to seek out opinions of nonfederal stakeholders. 
Once completed, the official said that the recovery strategy would 
provide guidance to federal, state, and local agencies in revising 
their operational plans for recovery activities, including recovery 
from RDD and IND incidents. 

Currently, the limited federal planning guidance related to the 
recovery from RDD and IND incidents can be found in a number of 
documents. There are several annexes to the National Response 
Framework that address, in part, federal agency responsibilities and 
assets to help state and local governments recover from these 
incidents. For example, a December 2004 emergency support function 
annex covering long-term community recovery and mitigation, led by 
FEMA, provides a framework for federal support to localities to enable 
community recovery from the long-term consequences of events of 
national significance. While this annex addresses FEMA's 
responsibilities to coordinate the transition from response to 
recovery in field operations, it does not provide details on recovery 
planning for RDD and IND incidents. The January 2003 emergency support 
annex covering hazardous materials, led by EPA, provides the framework 
for federal support in response to an actual or potential discharge 
and release of hazardous materials following a major disaster or 
emergency. EPA officials informed us that this annex will give them a 
significant federal role in leading cleanup efforts after RDD or IND 
incidents, in coordination with affected state and local governments. 
The June 2008 nuclear and radiological incident annex describes 
federal 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. 

FEMA Has Not Issued Specific Guidance to Coordinate Federal, State, 
and City Planning to Recover from an RDD or IND Incidents: 

FEMA has not issued specific guidance describing how federal 
capabilities would be integrated into and support state and local 
plans for recovery from RDD or IND incidents,[Footnote 14] as called 
for by presidential directive.[Footnote 15] According to a senior FEMA 
official, the agency has delayed issuing this guidance pending the 
reevaluation of its planning approach by the new administration. 
However, a senior FEMA planning official told us that because FEMA is 
already aware that its planning system does not fully recognize the 
involvement of state and local governments, the agency is developing 
regional support plans--including for RDD and IND incidents--through 
its regional offices, which will reflect state and local government 
roles and responsibilities. Moreover, according to FEMA officials, in 
August 2008, DHS issued stop-gap guidance outside of FEMA's planning 
guidance framework to provide some immediate direction to federal, 
state, and local emergency response officials in developing their own 
operational plans and response protocols for protection of emergency 
workers after RDD or IND incidents.[Footnote 16] In regard to 
recovery, EPA officials informed us that FEMA and other federal 
agencies worked together on this guidance in an attempt to clarify the 
processes for providing federal cleanup assistance following such an 
incident. These officials informed us that DHS's guidance was intended 
to cover the existing operational 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. 
[Footnote 17] Moreover, these officials indicated that EPA has also 
worked with other federal agencies to examine its own 1992 protective 
action guides to address shortcomings and to incorporate more recent 
guidance.[Footnote 18] However, according to EPA officials, much work 
remains to convert the new guidance into operational guidance. In 
addition, DOD has established operational plans for consequence 
management following terrorist incidents, including RDD and IND 
attacks.[Footnote 19] 

Without federal guidance for coordinating federal, state, and local 
planning for recovery from RDD or IND incidents, cities and states 
lack a framework for developing their own recovery strategies. 
Emergency management officials representing all 13 cities and their 
states in our survey indicated that while their jurisdictions had 
prepared emergency response and recovery plans for domestic incidents, 
few of these plans specifically addressed RDD and IND recovery 
activities, particularly for the analysis and environmental cleanup of 
areas contaminated with radioactive materials. For example, few city 
respondents (3 of 13) indicated that their recovery plans included 
preparations for an RDD incident, although respondents from two cities 
indicated that their cities were drafting these plans. In regard to 
IND preparation, all city respondents informed us that recovery 
planning was still important despite the magnitude of such events, but 
none of them had prepared such plans. Respondents from all states in 
our survey indicated that they had prepared emergency response plans 
for domestic incidents, and most of them (8 of 10) indicated that 
these plans included a recovery component. However, we were told that 
few of these recovery plans address an RDD incident, or specific 
analysis and environmental cleanup activities following such an 
incident, although respondents from 8 states mentioned that they 
planned to prepare such plans. The lack of recovery planning for RDD 
and IND incidents may be due, in part, to the relatively low priority 
given to preparing for them by city and state emergency management 
officials that we surveyed when compared with other types of risks 
facing their jurisdictions. For example, the majority of city 
respondents indicated that natural disasters, such as severe weather 
and infrastructure failure, were the most significant risks facing 
their jurisdictions. 

Federal Agencies Have Conducted Few Exercises to Test Recovery Plans 
for RDD or IND Incidents: 

Federal agencies and local jurisdictions have used existing federal 
guidance as a basis for planning RDD and IND response exercises and, 
to a much lesser extent, recovery exercises to test the adequacy of 
their plans and level of preparedness. According to DHS guidance, 
preparedness is the foundation of a successful national incident 
management system involving all levels of government and other 
nongovernmental organizations as necessary.[Footnote 20] The cycle of 
preparedness for prevention, protection, response, and recovery 
missions ends with adequate exercising, evaluation, and improvement. 
Our search of FEMA's National Exercise Schedule--a scheduling system 
for federal, state, and local exercises--revealed 94 RDD or IND 
response exercises planned and carried out by these authorities from 
May 2003 through September 2009. These exercises were identified as 
either full-scale, tabletop, workshop, seminar, functional, or a 
drill, and some locations have conducted several of them over a period 
of time. While many of these exercises listed both response and 
recovery objectives, as well as other exercise objectives, officials 
with FEMA's National Exercise Division told us that only three of them 
actually included a recovery component that exercised activities 
associated with environmental cleanup. However, our survey of city, 
state, and federal regional office emergency management officials 
found that many response and a few recovery exercises were conducted 
over the last 6 years that do not appear in FEMA's National Exercise 
Schedule. We previously reported that information in the National 
Exercise Schedule database was unreliable.[Footnote 21] 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. 

Uncertainty about Federal Capability to Effectively Clean up Areas 
Contaminated with Radioactive Materials from RDD or IND Incidents: 

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. 

Effectiveness of Environmental Cleanup Methods and Technologies 
Following RDD or IND Incidents Are Untested on a Large Scale: 

Some federal agencies, such as DOE and EPA, have substantial 
experience using various analysis and environmental cleanup methods 
and technologies to address localized areas contaminated with 
radioactive materials, but little is known about how these methods and 
technologies might be applied in recovering from the magnitude of RDD 
or IND incidents. For example, DOE has invested hundreds of millions 
of dollars in research, development, and testing of methods and 
technologies for cleaning up and decommissioning contaminated 
structures and soils--legacies of the Cold War. In addition, since the 
passage of the Comprehensive Environmental Response, Compensation, and 
Liability Act (CERCLA), which established the Superfund program, 
[Footnote 22] EPA has undertaken significant efforts to study, 
develop, and use technologies that can address radioactive 
contamination. DOD has also played a major role in studying potential 
applications for innovative technologies for its Superfund sites. 

As a result of federal agencies' experience with radioactive 
materials, there is evidence that the agencies could effectively carry 
out the analysis and environmental cleanup of localized areas 
contaminated by these materials. In regard to analysis, DOE's National 
Nuclear Security Administration (NNSA) has developed operational 
plans, orders, and publications on how to respond to a radiological or 
nuclear incident. NNSA has developed various FRMAC manuals to guide 
operational, assessment and monitoring activities. In addition, EPA's 
National Decontamination Team has published guidelines that provide a 
framework 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. 
[Footnote 23] The cleanup technologies are generally grouped into 
chemical and physical technologies. During the initial response phase 
to an incident, responders might rely on fairly simple cleanup 
approaches, such as washing down exposed people and surfaces, mowing 
grass, pruning trees, and sweeping up affected areas. The latter 
recovery phase might require no additional action or use of complex 
decontamination technologies depending on the level of desired 
cleanup. EPA has also published guidance for its On-Scene Coordinators 
at each regional office to aid in their response to a radiological 
incident.[Footnote 24] This guidance covers the full range of 
radiological incidents, but its focus is primarily on the early to 
intermediate phases of an RDD incident, as this incident is expected 
to present a challenge for these coordinators. This guidance addresses 
possible decontamination approaches for eight types of radionuclides 
that experts believe are most likely to be used in an RDD. 

As previously mentioned, federal agencies' current approaches to 
analysis and environmental cleanup have only been applied in localized 
areas, as an RDD or IND incident has not occurred; however, 
decontamination research is currently under way to gain a better 
understanding of potential applications of current and experimental 
methods and technologies for primarily RDD incidents. According to 
decontamination experts at DOE's Lawrence Livermore National 
Laboratory, current research has focused on predicting the effects of 
radiation release in urban settings through simulation, small-scale 
testing, and theory. In addition, researchers at EPA's National 
Homeland Security Research Center informed us that while there are 
available methods that have proven successful for cleaning up various 
types of contamination, more research is needed to develop standard 
national guidance for their efficacious application in urban areas 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.[Footnote 25] A senior 
EPA official with the Office of Radiation and Indoor Air told us that 
the agency has studies under way to determine the efficacy of high-
pressure hosing for removing contamination from porous urban surfaces 
that would result from the terrorists' use of an RDD using certain 
radioisotopes. 

Limitations in Federal Capabilities to Address Magnitude of Cleanup 
Following RDD or IND Incidents: 

There are also limitations in federal capabilities to help address, in 
a timely manner, the magnitude of cleanup that would be associated 
with RDD or IND incidents. For example, we found that limitations in 
federal capabilities to complete some analysis and environmental 
cleanup activities might slow the recovery from an incident, including 
(1) characterizing the full extent of areas contaminated with 
radioactive materials, (2) completing laboratory validation of 
contaminated areas and levels of cleanup after applying 
decontamination approaches, and (3) removing and disposing of 
radioactive debris and waste. 

Characterizing Areas Contaminated with Radioactive Materials: 

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.[Footnote 26] According to a senior official at 
the Lawrence Livermore National Laboratory's Interagency Modeling and 
Atmospheric Assessment Center (IMAAC), the predictive capabilities of 
existing plume models are not at the resolution necessary to produce 
this added value for urban areas, as modeling for this purpose is only 
theoretical at this point. This official told us while there are data 
about debris dispersal from building demolition and weapons testing, 
there is little research data on the likely dispersal patterns of 
concrete, asphalt, and glass that would result from use of an RDD or 
IND. However, some federal agency officials question the need to 
improve the predictive capabilities of these plume models. For 
example, the DHS IMAAC director told us that the current state-of-the-
art and plume modeling approach is sufficient for its primary purpose 
in directing the protective actions of first responders. Nevertheless, 
NNSA officials informed us they are working with FEMA on a multiyear 
program to improve federal capabilities to model the release of 
material during a radiological or nuclear incident. However, they 
contend that plume modeling will never replace the need for actual 
measurements for radioactive contamination. In commenting on a draft 
of this report, EPA agreed that characterization of areas contaminated 
with radioactive materials from RDD or IND incidents would be 
challenging because existing plume models are not entirely applicable 
to urban areas. Moreover, EPA added that other types of contamination, 
such as in the drinking water and wastewater infrastructure, would 
also involve very complex systems that would be difficult to model. 

Completing Laboratory Validation of Areas Contaminated with 
Radioactive Materials: 

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.[Footnote 27] 
EPA added that it looks forward to the lessons to be learned from the 
upcoming Liberty RadEx exercise in 2010, which officials believe 
should provide significant insights into the issues under discussion 
in this report. 

Storing and Disposing of Waste from Areas Contaminated with 
Radioactive Materials: 

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.[Footnote 28] In commenting on a draft of 
the report, EPA officials informed us that its Office of Research and 
Development is currently developing a suite of decision support tools 
for the management of waste and debris from a variety of different 
events, including radiological incidents. 

Concerns about Federal Capabilities from Survey Respondents: 

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. 

City, State, and Federal Emergency Management Officials Provided 
Suggestions to Improve Federal Recovery Preparedness for RDD and IND 
Incidents: 

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. 

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: 

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.[Footnote 29] The Government Decontamination Service 
provides advice and guidance to local governments, maintains and 
builds a framework of specialized analysis and environmental cleanup 
contractors, and advises the national 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. 

Conclusions: 

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. 

Recommendations for Executive Action: 

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. 

Agency Comments and Our Evaluation: 

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 [hyperlink, 
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. 

Signed by: 

Gene Aloise: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Scope and Methodology: 

In our review, we examined (1) the extent to which federal agencies 
are planning to fulfill their responsibilities to help cities and 
states clean up areas contaminated with radiation materials from 
radiological dispersal device (RDD) and improvised nuclear device 
(IND) incidents, (2) what is known about the federal government's 
capability to effectively clean up areas contaminated with radioactive 
materials from RDD and IND incidents, and (3) suggestions from 
government emergency management officials for improving federal 
preparedness to help cities and states recover from RDD and IND 
incidents. In addition, we are providing information on actions taken 
in the United Kingdom to prepare for recovering from RDD and IND 
incidents. 

To determine the extent to which federal agencies are planning to 
fulfill their responsibilities to help cities and states clean up 
areas contaminated with radioactive materials from RDD and IND 
incidents, we reviewed pertinent federal law, presidential directives, 
and other executive guidance; interviewed cognizant officials from the 
Department of Homeland Security (DHS), Department of Energy (DOE), 
Environmental Protection Agency (EPA), Federal Emergency Management 
Administration (FEMA), and Nuclear Regulatory Commission (NRC); 
conducted a survey of 13 cities considered to be at high or medium 
risk to such attacks and their states,[Footnote 30] 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. 

[End of section] 

Appendix II: Recovery Exercises: 

Table 1 provides a brief summary of four RDD exercises, since May 
2003, which contained recovery objectives including a planned exercise 
for April 2010. 

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

Name of exercise: National-level exercise; (TOPOFF 2); 
Dates of exercise: May 12-16, 2003: RDD response exercise included a 
large-scale game involving recovery issues; 
Lead agency: DHS and State Department; 
Locations of exercise: Seattle, Wash. and Chicago, Ill.; 
Objectives of recovery exercise: 
* To improve incident management capabilities; 
* To collect and coordinate distribution of RDD plume modeling data; 
Issues discussed at recovery exercise: 
* Data collection and coordination; 
* Coordinating the distribution of plume model analysis products; 
* Federal Radiological Monitoring and Assessment Center (FRMAC) 
transition. 

Name of exercise: National-level exercise; (TOPOFF 4); 
Dates of exercise: October 15-19, 2007: RDD response exercise was 
followed by a long-term recovery tabletop exercise on December 4, 2007; 
Lead agency: DHS; 
Locations of exercise: Phoenix, Ariz., Portland, Ore, and Guam; 
Objectives of recovery exercise: 
* To identify gaps in role definitions, authorities, standards, 
capabilities, etc., for key recovery measures; 
* To determine cost-benefit tradeoffs in defining acceptable risk for 
long-term exposures as a guide to cleanup and recovery activity; 
* To identify measures and communication strategies for maintaining 
public confidence; 
Issues discussed at recovery exercise: 
* Sampling and laboratory capacity; 
* Decontamination technologies; 
* Radioactive waste disposal and management; 
* FRMAC leadership transition. 

Name of exercise: Empire 2009; 
Dates of exercise: June 1-5, 2009: RDD response exercise was followed 
by a facilitated discussion recovery exercise on June 16-17, 2009; 
Lead agency: DOE; 
Locations of exercise: Albany, N.Y.; 
Objectives of recovery exercise: 
* To establish criteria for the release of public areas; 
* To establish cleanup values, and long-term monitoring, sampling and 
community recovery plans; 
* To discuss the transfer of FRMAC leadership responsibility; 
Issues discussed at recovery exercise: 
* Cleanup planning and guidance; 
* Implementation of cleanup and optimization process for determining 
cleanup levels; 
* Data management optimization; 
* Waste disposal; 
* FRMAC leadership transition. 

Name of exercise: Liberty RadEx 2010; 
Dates of exercise: April 26-30, 2010: RDD response exercise is to 
include recovery related issues; 
Lead agency: EPA; 
Locations of exercise: Philadelphia, Penn.; 
Objectives of recovery exercise: 
* To exercise roles for hazardous materials assessment, mitigation, 
cleanup and FRMAC leadership transition; 
* To apply guidelines for mitigation and short-term cleanup; 
* To review community recovery activities for contamination and long-
term cleanup; 
* To utilize the optimization process to prioritize mitigation and 
cleanup activities in post-emergency phase and to develop long-term 
cleanup standards; 
Issues discussed at recovery exercise: 
* Coordination between cleanup and public health; 
* Community/stakeholder involvement; 
* Long-term cleanup planning and prioritization; 
* Involvement and coordination with FEMA on long-term community 
recovery in cleanup planning; 
* Long-term relocation decision making; 
* Waste disposal. 

Source: GAO analysis of federal agency documents. 

[End of table] 

[End of section] 

Appendix III: Radiological Recovery Experiences in the United Kingdom: 

The United Kingdom provides an example of another country's efforts to 
prepare to recover from a terrorist attack using chemical, biological, 
radioactive, or nuclear materials. This country's attention to 
recovery needs is reflected in promulgating emergency response and 
recovery legislation, establishing a government decontamination 
service, creating online national recovery guidance, updating a 
recovery handbook for radiation incidents, conducting a full-scale RDD 
recovery exercise, establishing a community and national risk register 
system, and preparing specific nuclear recovery planning guidance. The 
particular emphasis on recovery activities in the United Kingdom has 
been linked to decades of experience with the conflict in Northern 
Ireland, widespread contamination from the Chernobyl nuclear power 
plant accident, and a national history of resilience--that is, the 
ability to manage and recover from hardship. 

Emergency Response and Recovery Framework: 

The United Kingdom has established a framework for addressing the 
release of radiological materials that prompted planning for the 
recovery from these events. This framework was primarily established 
through the 2001 Radiation (Emergency Preparedness and Public 
Information) Regulations[Footnote 31] and the 2004 Civil Contingencies 
Act, as well as guidance issued pursuant to the Civil Contingencies 
Act.[Footnote 32] 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.[Footnote 33] 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,[Footnote 34] 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.[Footnote 35] This guidance describes the generic 
framework for multiagency response and recovery activities at all 
levels of government, emphasizing that these activities are not 
separate activities that occur sequentially. Instead, this guidance 
contends that recovery considerations should take place early in the 
response phase, as initial decisions can affect the long-term outcomes 
for communities. Moreover, because the government recognized that no 
single approach could meet the needs of every affected area, it did 
not intend this guidance to be either prescriptive or an operational 
manual. 

Government Decontamination Service: 

In 2005, the United Kingdom established a special Government 
Decontamination Service to address issues associated with contaminated 
land, buildings, open space, infrastructure, and transportation routes 
from both deliberate and accidental releases of chemical, biological, 
radiological, and nuclear materials.[Footnote 36] 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.[Footnote 37] 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.[Footnote 38] 

Online National Recovery Guidance: 

While passage of the 2004 Civil Contingencies Act was an important 
legislative step to further emergency preparedness, the reaction of 
local responders to several domestic incidents following passage of 
this act made it clear to the national government that these 
responders needed more comprehensive guidance than that contained in 
the 2005 guidance for emergency response and recovery activities. One 
such event was the July 2005 subway bombing in London by a terrorist 
group that killed 52 people. This incident, in conjunction with other 
events in 2005, such as the Buncefield Fire and severe flooding, 
prompted the government in 2006 to form a National Recovery Working 
Group to address the need for additional recovery guidance for 
multiple risk scenarios. This working group was comprised of a wide 
range of government departments and agencies, as well as other 
stakeholders who had been involved in the recovery phase following 
these events. The government charged this working group with, among 
other things (1) producing national recovery guidance for local 
responders, (2) identifying gaps in the country's recovery capability 
with recommendations to address them, and (3) contributing to the 
ongoing review of the 2005 nonstatutory guidance for emergency 
response and recovery activities. In 2007, the working group produced 
a National Recovery Guidance document.[Footnote 39] 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.[Footnote 40] 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. 

Updated Recovery Handbooks for Radiological Incidents: 

The 2009 version of the UK Recovery Handbooks for Radiological 
Incidents is considered relevant to radiological releases--accidental 
and intentional--from the nuclear and nonnuclear industry sectors. 
[Footnote 41] 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. 

Figure 1: Example of a Datasheet on High Pressure Hosing for Cleaning 
Contaminated Surfaces in the UK Recovery Handbooks for Radiation 
Incidents: 2009: 

[Refer to PDF for image: illustration] 

Datasheets Of Management Options: 

7: High pressure hosing: 

Likely Category: Objective; 
To reduce external gamma and beta doses and inhalation doses from 
contamination on external walls and roofs of buildings within 
inhabited areas. 

Likely Category: Other benefits; 
Will remove contamination from external building surfaces. 

Likely Category: Management option description; 
Pressure-washing equipment can be used to loosen contamination from a 
surface and wash it off. A continuous water flow is applied at high 
pressure of about 150 bar (2000 psi). Washing must start at the top of 
walls and roofs and it is particularly important to avoid lifting roof 
tiles by forcing water upwards. A pump is mounted on the ground and 
hoses are fed to a platform or scaffolding. Use of high pressure jets 
at pressures significantly above 150—200 bar is not advisable on roofs 
as this may lead to lifting of the tiles. 
Roofs: it should be practicable to collect the water used for high 
pressure hosing. Collection of water from roofs can be aided by 
modifying guttering and drainpipes, so that the collected waste is fed 
into collection tanks, where it may be filtered (most of radioactivity 
will be associated with the solid phase). If no active means are 
adopted to collect the water, some of the waste water may soak into 
the ground and the rest will pass directly into the drains or to soak-
aways via gutters and drainpipes. It may be necessary to apply a 
surface treatment to roofs to ensure protection against future water 
penetration. 
Walls: it is unlikely to be practicable to collect the waste water and 
associated contamination. 
Ground: The implementation of options to the surrounding ground 
surfaces should also be considered after high pressure hosing has been 
implemented, if run-off to ground surfaces has occurred. If the 
implementation of any other options to the surrounding ground surfaces 
is planned, high pressure hosing of walls and roofs should be 
implemented first. 

Likely Category: Target; 
External walls and roofs of buildings (highly contaminated). 

Likely Category: Targeted radionuclides; 
All long-lived radionuclide. Not short-lived radionuclides. 

Likely Category: Scale of application; 
Any size building. 

Likely Category: Time of application; 
Maximum benefit if carried out soon after deposition when maximum 
contamination is still on the surfaces. However, high pressure hosing 
of external walls and roofs of buildings can be effective up to 10 
years after deposition. 

Constraints: 

Likely Category: Legal constraints; 
* Liabilities for possible damage to property (e.g flooding). 
* Ownership and access to property. 
* Disposal of contaminated water via public sewer system. 
* Use on listed and other historical buildings. 

Likely Category: Environmental constraints; 
* Severe cold weather (water would need to be heated). 
* Walls must be waterproof. 
* Roof constructions must resist water at high pressure. 

Effectiveness: 

Likely Category: Reduction in contamination on the surface; 
A decontamination factor (DF) of between 1.5 and 5 can be achieved if 
it is implemented soon after deposition. A higher DF can be achieved 
following dry deposition rather than wet deposition. In the case of 
plutonium, a DF of between of 10 and 2 can be achieved. For elemental 
iodine and tritium, thorough hosing of impermeable surfaces will lead 
to virtually full removal of contamination. The effectiveness of high 
pressure hosing decreases with time elapsed since contamination 
occurred, especially in areas with high rainfall rates. Repeated 
application is unlikely to provide any significant increase in DF. 

Likely Category: Reduction in surface dose rates; 
External gamma and beta dose rates from decontaminated external walls 
and roofs of buildings will be reduced by a factor similar to the DF. 
Reductions in external doses received by a member of public living in 
the area will depend on the number of buildings in the area and the 
time spent by individuals close to these buildings (see below). 

Likely Category: Reduction in resuspension; 
Resuspended activity in air will be reduced by the value of the DF. 

Likely Category: Technical factors influencing effectiveness; 
* Water pressure. 
* Type, evenness & condition of surface, including the amount of moss 
on roofs. 
* Time of operation: the longer the time between deposition and 
implementation of the option the less effective it will be due to 
fixing of the contamination to the surface. 
* Consistent application of water over the contaminated area (i.e. 
operator skill). 
* Care in application: care needed to wash contamination from walls 
and roofs and not just move the contamination around the surface; 
lower part of walls need to be cleaned very carefully as this is the 
surface that will provide the greatest dose to an individual in the 
vicinity of the building; special cam needed to clean roof gutters and 
drain pipes. 
* Whether the ground surrounding the building and other surfaces onto 
which run-off may have occurred have been decontaminated after 
treating the building (if waste was not collected). 
* Number of buildings in the area. 
* Time of implementation: weathering will reduce contamination over 
time so quick implementation will improve 
effectiveness.			
				
Likely Category: Social factors influencing effectiveness; 
Public acceptability of waste treatment and storage routes. 

Feasibility: 

Likely Category: Equipment; 
The equipment used will depend on whether the waste water is filtered 
prior to disposal. The equipment used for high pressure hosing can 
include: 
* 2000 psi pressure washer; 
* 7.5kW generator; 
* Filter; 
* Spate pump; 
* Gully sucker; 
* Scaffolding with roof ladders for additional roof access; 
* Transportation vehicles for equipment and waste. 

Likely Category: Utilities and infrastructure; 
* Roads for transport of equipment and waste. 
* Water supply. 
* Public sewer system. 

Likely Category: Consumables; 
* Fuel and parts for generators and transport vehicles. 
* Surface treatment for roofs (if required). 

Likely Category: Skills; 
* Skilled personnel essential to operate high pressure hoses and gully 
suckers. 

Likely Category: Safety precautions; 
* For tall buildings: lifeline and safety helmets. 
* Water-resistant clothing should be recommended, particularly in 
highly contaminated areas. 
* Personal protective equipment (PPE) should be considered to protect 
workers from contaminated water spray. 
* Precautions are needed to ensure that people making connections to 
mains water supplies do not inadvertently contaminate the water 
supply, e.g. by back-flow from vessels containing radioactivity or 
other contaminants, or operate hydrants in a way that disturbs settled 
deposits within the water main system. 

Waste: 

Likely Category: Amount; 
2 10-1 — 4 10-1 kg m-2 solid and 20 l m2 water. 

Likely Category: Type; 
Dust and water.	 

Doses: 

Likely Category: Averted dose; 
Cs-137 (% reduction in external dose): 
Over 1st year: 
Dry: <5; 
Wet: <5. 
Over 50 years: 
Dry: <5; 
Wet: <5. 

Pu-239 (% reduction in resuspension dose): 
Over 1st year: 
Dry: 0; 
Wet: <5. 
Over 50 years: 
Dry: <5; 
Wet: <5. 

The dose reductions are for illustrative purposes only and are for a 
person living in a typical inhabited area. The estimated dose 
reductions do not include any potential future doses that may arise if 
contaminated water enters the drainage system and subsequently the 
wider environment (see Appendix C for further information). 

Likely Category: Factors influencing averted dose; 
Likely Category: Consistency in effective implementation of option 
over a large area. 
Likely Category: Care in application. Care needed to wash 
contamination from walls and roofs and not just move the contamination 
around the surface; lower part of walls need to be cleaned very 
carefully as this is the surface that will provide the greatest dose 
to an individual in the vicinity of the building; special care needed 
to clean roof gutters and drain pipes. Whether the ground surrounding 
the building and other surfaces onto which run-off may have occurred 
have been decontaminated after treating the building (if waste was not 
collected). 
Likely Category: Population behaviour in the area. 
Likely Category: Number of buildings in the area, i.e. environment 
type/land use. 
Likely Category: Time of implementation. The impact of cleaning the 
surfaces on the overall doses will be reduced with time as there will 
be less contamination on the surfaces due to natural weathering. 

Likely Category: Additional doses; 
Relevant exposure pathways for workers are: 
* external exposure from radionuclides in the environment and 
contaminated equipment; 
* inhalation of radioactive material resuspended from the ground and 
other surfaces (may be enhanced over normal levels); 
* inhalation of dust and water spray generated; 
* inadvertent ingestion of dust from workers' hands. 
Contributions from pathways in italics are will not be significant and 
doses from these pathways can be controlled by using PPE. Exposure 
routes from transport and disposal of waste are not included. No 
illustrative doses are provided as they will be very specific to the 
type of contamination, environmental conditions, the tasks undertaken 
by an individual, controls placed on working and the use of PPE. 
	
Intervention costs: 

Likely Category: Operator time; 
Work rate (rW/team.hr):	30—60 (excludes setting up scaffolding, if 
required); 
Team size (people): Up to 3 (depends on equipment used for access to 
buildings. More people needed if water is collected and filtered prior 
to disposal). 

Likely Category: Factors influencing costs; 
Likely Category: Weather; 
Likely Category: Building size; 
Likely Category: Type of equipment used; 
Likely Category: Access; 
Likely Category: Proximity of water supplies; 
Likely Category: Use of personal protective equipment (PPE). 

Side effects: 

Likely Category: Environmental impact; 
High pressure hosing will create contaminated waste water. However, 
this should be minimized through the control of any disposal route and 
relevant authorizations. If waste water is not collected, some of it 
will run onto other surfaces (roads, soil, grass etc), resulting in a 
transfer of contamination which may require subsequent clean-up, 
generating more waste. It is important that high pressure hosing of 
buildings is implemented before the implementation of any recovery 
options to surrounding ground surfaces.	 

Likely Category: Social impact; 
Acceptability of active disposal of contaminated waste water into the 
public sewer system. High pressure hosing of buildings will make an 
area look clean; implementation may give public reassurance. Repair 
work on some walls and roofs may be required. 
	
Likely Category: Practical experience; 
Tested on realistic scale on selected walls and roofs in the Former 
Soviet Union and Europe after the Chernobyl accident. 
	
Likely Category: Key references; 
Andersson KG (1996). Evaluation of early phase nuclear accident clean-
up procedures for Nordic residential area. NKS Report NKS/EKO-5 (96) 
18, ISBN 87-550-2250-2. 

Andersson KG, Roed J, Eged K, Kis Z, Voigt G, Meckbach R, Oughton DH, 
Hunt J, Lee R, Beresford NA and Sandalls FJ (2003). Physical 
countermeasures to sustain acceptable living and working conditions in 
radioactively contaminated residential areas. Riso-R1396(EN), Rise 
National Laboratory, Roskilde, Denmark.	 

Andersson KG and Roed J (1999). A Nordic preparedness guide for early 
clean-up in radioactively contaminated residential areas. Journal of 
Environmental Radioactivity, 46, (2), 207-223. 

Brown J and Jones AL (2000). Review of decontamination and remediation 
techniques for plutonium and application for CONDO version 1.0. NRPB, 
Chilton, NRPB-R315. 

Brown J, Charnock T and Morrey M (2003). DEWAR — Effectiveness of 
decontamination options, waste arising and other practical aspects of 
recovery countermeasures in inhabited areas. Environment Agency R&D 
Technical Report P3-072/TR. 

Hubert P, Annisomova L, Antsipov G, Ramsaev V and Sobotovitch V 
(1996). Strategies of decontamination. Experimental Collaboration 
Project 4, European Commission, EUR 16530 EN, ISBN 92-827-5195-3. 

Roed J and Andersson KG (1996). Clean-up of urban areas in the CIS 
countries contaminated by Chernobyl fallout. Journal of Environmental 
Radioactivity, 33 (2), 107-116. Roed J, Andersson KG and Prip H (ed.) 
(1995). Practical means for decontamination 9 years after a nuclear 
accident. Rise-R-828(EN), ISBN 87-550-2080-1, ISSN 0106-2840, 82p. 

Likely Category: Version; 
2	 

Likely Category: Document history; 
See Table 3.2.	 

Source: A. Nisbet et. al., UK Recovery Handbooks for Radiation 
Incidents 2009, version 3, prepared for the Radiation Protection 
Division, Centre for Radiation, Chemical and Environmental Hazards, 
Health Protection Agency (Chilton, Didcot, Oxfordshire, U.K., December 
2009). 

[End of figure] 

RDD Recovery Exercises: 

In November 2008, Exercise Green Star tested government capabilities 
to recover from a terrorist attack based on RDD scenarios.[Footnote 
42] 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.[Footnote 
43] 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. 

Community and National Risk Registration System: 

The United Kingdom has developed a comprehensive program to ensure an 
effective response to a range of disruptive emergencies that might 
affect the country. The country uses the term "resilience" as the 
ability of organizations, like individuals, to withstand or recover 
easily and quickly from hardships, such as major flooding or a 
terrorist attack. Community risk registers have been published by 
local emergency management planners since passage of the 2004 Civil 
Contingencies Act. These community risk registers address specific 
risks identified by representatives from local emergency services and 
public, private, and voluntary organizations. Local resilience forums 
are required to develop and maintain these registers that include a 
description of potential outcomes, likelihoods, impacts, and ratings 
for various risk categories and subcategories of events. One of the 
risk categories is an actual terrorist attack using an explosive 
device. The national government does not expect communities to 
directly track these risks, but rather to improve their own 
preparedness based on information from the national risk assessment, 
which is a classified document. In 2008, the government published a 
national risk register, which is based on this classified assessment 
and discusses the likelihood and potential impacts of a range of risks 
facing the country, including attacks using chemical, biological, 
radiological, and nuclear materials. This national risk register 
contains information that was previously held confidential within 
government but was published to encourage public debate on security 
and to help organizations, individuals, families, and communities 
prepare for encountering threats. The government reports that while 
there have been very few examples of attacks such as the 1995 release 
of Sarin gas in a Tokyo subway, it still recognizes the need to 
prepare and plan for them. 

Specific Nuclear Recovery Planning Guidance: 

In March 2009, the Nuclear Emergency Planning Liaison group published 
a UK Nuclear Recovery Plan Template based on the National Recovery 
Guidance and Recovery Plan Guidance Template.[Footnote 44] 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.[Footnote 45] 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. 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Gene Aloise (202) 512-3841 or at aloisee@gao.gov: 

Staff Acknowledgments: 

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. 

[End of section] 

Footnotes: 

[1] National Science and Technology Council, Roadmap for Nuclear 
Defense Research and Development: Fiscal Years 2010-2014 (Washington, 
D.C., July 2008). 

[2] FRMAC is responsible for coordinating all environmental 
radiological monitoring, sampling, and assessment activities for the 
federal response to a radiological release into the environment. 

[3] GAO, Nuclear Security: Actions Taken by NRC to Strengthen Its 
Licensing Process for Sealed Radioactive Sources Are Not Effective, 
[hyperlink, http://www.gao.gov/products/GAO-07-1038T] (Washington, 
D.C.: July 12, 2007). 

[4] GAO, Nuclear Security: Action May Be Needed to Reassess the 
Security of NRC-Licensed Research Reactors, [hyperlink, 
http://www.gao.gov/products/GAO-08-403] (Washington, D.C.: Jan. 31, 
2008). 

[5] GAO, Observations on DHS and FEMA Efforts to Prepare for and 
Respond to Major and Catastrophic Disasters and Address Related 
Recommendations and Legislation, [hyperlink, 
http://www.gao.gov/products/GAO-07-1143T] (Washington, D.C.: July 31, 
2007); Actions Taken to Implement the Post-Katrina Emergency 
Management Reform Act of 2006, [hyperlink, 
http://www.gao.gov/products/GAO-09-59R] (Washington, D.C.: Nov. 21, 
2008); and National Preparedness: FEMA Has Made Progress, but Needs to 
Complete and Integrate Planning, Exercise, and Assessment Efforts, 
[hyperlink, http://www.gao.gov/products/GAO-09-369] (Washington, D.C.: 
Apr. 30, 2009). 

[6] GAO, Combating Nuclear Terrorism: Preliminary Observations on 
Preparedness to Recover from Possible Attacks Using Radiological or 
Nuclear Materials, [hyperlink, 
http://www.gao.gov/products/GAO-09-996T] (Washington, D.C.: Sept. 14, 
2009). 

[7] The high-and medium-risk cities are Boston, Chicago, Dallas, 
Denver, Detroit, Houston, Los Angeles, Miami, New York, Philadelphia, 
San Francisco, Seattle, and St. Louis. While Washington, D.C., is 
considered a high-risk city, we excluded it from our survey because it 
is unlike other cities in its reliance on the federal government and 
the federal agencies that would take over analysis and environmental 
cleanup activities. 

[8] British investigators believe that this pure polonium was probably 
produced in a Russian research reactor. 

[9] A.C. Perkins, "The London Polonium Poisoning: Events and Medical 
Implications," World Journal of Nuclear Medicine, Vol. 6, No. 2, 
(April 2007) 102-106. 

[10] The Post-Katrina Emergency Management Reform Act, Pub. L. No. 109-
295, § 682, 120 Stat. 1355, 1445-46 (2006). The act also requires FEMA 
to submit a report to Congress within 270 days of enactment describing 
the strategy in detail. 

[11] Homeland Security Council, National Strategy for Homeland 
Security (Washington, D.C., October 2007). 

[12] In January 2008, DHS issued the National Response Framework, as 
an update of the 2004 and the 2006 National Response Plan. The 
framework provides a guide for how the nation should conduct all-
hazard response, including the roles and responsibilities of federal 
agencies involved in response efforts. 

[13] In our November 21, 2008 report [hyperlink, 
http://www.gao.gov/products/GAO-09-59R], we found that FEMA had 
drafted a national disaster recovery strategy but that it was under 
review at the time with no timeframe for completion. 

[14] The planning for RDD and IND incidents is based on a national 
planning scenario for each incident. Scenario 11 represents a 
radiological attack using an RDD spreading contamination over 36 city 
blocks, causing hundreds of fatalities, costing billions of dollars in 
economic impacts, and taking months to years for recovery. Scenario 1 
represents a nuclear detonation using a 10-kiloton IND spreading 
contamination over approximately 3,000 square miles, causing hundreds 
of thousands deaths, hundreds of billions of dollars in economic 
impacts, and taking years for recovery. 

[15] Homeland Security Presidential Directive 8, Annex 1 (December 
2007), titled National Planning, is intended to further enhance the 
preparedness of the United States by formally establishing, 
developing, and maintaining a standard and comprehensive approach to 
national planning. 

[16] DHS, Planning Guidance for Protection and Recovery Following 
Radiological Dispersal Device (RDD) and Improvised Nuclear Device 
(IND) Incidents, 73 Fed. Reg. 45,029 (Aug. 1, 2008). 

[17] C. Yu et al., Preliminary Report on Operational Guidelines 
Developed for Use in Emergency Preparedness and Response to a 
Radiological Dispersal Device Incident, DOE/HS-0001, prepared for DOE, 
Office of Health Safety, and Security, February 2009. 

[18] EPA, EPA Guidance on the Optimization Process Following a 
Radiological Dispersal Device or Improvised Nuclear Device Incident 
(Draft), and Revisions to the Protective Action Guides Manual for 
Radiological Incidents (Draft). 

[19] We provided testimony on this DOD initiative in GAO, Homeland 
Defense: Preliminary Observations on Defense Chemical, Biological, 
Radiological, Nuclear, and High-Explosive Consequence Management Plans 
and Preparedness, [hyperlink, http://www.gao.gov/products/GAO-09-927T] 
(Washington, D.C.: July 28, 2009). 

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

[21] [hyperlink, http://www.gao.gov/products/GAO-09-369]. 

[22] Comprehensive Environmental Response, Compensation, and Liability 
Act, 42 U.S.C. §§ 9601-9675. CERCLA gives the federal government the 
authority to respond to releases or threatened releases of hazardous 
substances (including radionuclides) that may endanger public health 
or the environment. 

[23] EPA, Inventory of Radiological Methodologies for Sites 
Contaminated with Radioactive Materials, EPA-402-R-06-007 (Washington, 
D.C., October 2006); Technology Screening Guide for Radioactively 
Contaminated Sites, EPA-402-R-96-017 (Washington, D.C., November 
1996); Technology Reference Guide for Radiologically Contaminated 
Surfaces, EPA-402-R-06-003 (Washington, D.C., March 2006); and 
Technology Reference Guide for Radioactively Contaminated Media, EPA- 
402-R-07-004 (Washington, D.C., October 2007). 

[24] EPA, OSC Radiological Response Guidelines (Washington, D.C., 
October 2006). The EPA On-Scene Coordinators direct and coordinate the 
agency's response at the scene of an incident through the local 
incident command system in accordance with the National Oil and 
Hazardous Substances Pollution Contingency Plan and the National 
Response Framework. 

[25] The experts also said that decontamination costs can dramatically 
increase depending on the selection of an initial approach and the 
length of time before remediation actions are taken. 

[26] Information from plume models--mathematical or computer 
equations--is intended to provide first responders with early 
estimates of potentially contaminated areas to help guide field 
sampling of sites, that data from which will in turn be used to update 
plume predictions in a cyclical process until the affected area has 
been accurately characterized. 

[27] EPA, EPA Guidance on the Optimization Process Following a 
Radiological Dispersal Device or Improvised Nuclear Device Incident 
(Draft). 

[28] P. Lemieux et al., "Updated Decision Support Tool for the 
Management of Waste and Debris from Radiological Incidents," 
(conference paper presented at Waste Management 2009 Conference, 
Phoenix, Ariz., March 1-5, 2009). 

[29] The Government Decontamination Service is similar in size and 
responsibilities to EPA's National Decontamination Team, which became 
fully operational in August 2007. 

[30] The high-and medium-risk cities came from a list compiled by an 
advisory group to the insurance industry that conducts catastrophe 
event modeling. DHS also maintains a list of high-risk cities. 
However, DHS considers its list to be sensitive information. 
Nonetheless, DHS officials agreed that using the insurance industry 
list for our survey was reasonable. 

[31] The Radiation (Emergency Preparedness and Public Information) 
Regulations 2001, 2001 No. 2975, August 27, 2001. 

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

[33] The Radiation (Emergency Preparedness and Public Information) 
Regulations 2001, implemented Council Directive 96/29/Euratom on 
laying down basic safety standards for the protection of the health of 
workers and the general public against the dangers arising from 
ionizing radiation. 

[34] In 2004, the United States established its National Incident 
Management System to provide a consistent nationwide approach for 
government, private sector, and nongovernmental organizations to 
prepare for, respond to, and recover from domestic incidents. 

[35] HM Government, Emergency Response and Recovery: Non-Statutory 
Guidance to Complement Emergency Preparedness (York: Easingwold, 
Library and Information Centre, Emergency Planning College, November 
2005). 

[36] The Government Decontamination Service has been compared to EPA's 
National Decontamination Team, which became fully operational in 
August 2007. Both organizations are similar in size and have similar 
advisory missions to local authorities, but the EPA team does not 
itself maintain a framework of contractors. 

[37] The United States does not have a clearance rule to allow very 
low-level radioactive waste to be disposed of at more conventional 
landfill sites. Rather, the Nuclear Regulatory Commission takes a case-
by-case approach, which has also been implemented by some Agreement 
States. 

[38] Agreement Between the Government of the United States of America 
and the Government of the United Kingdom of Great Britain and Northern 
Ireland on Cooperation in Science and Technology for Critical 
Infrastructure Protection and Other Homeland/Civil Security Matters. 
There are also 10 annexes attached to this agreement, including joint 
exercises and training on decontamination approaches. 

[39] The National Recovery Guidance is a guide to emergency response 
and recovery maintained by the national government. 

[40] The U.S. administration and Congress directed the preparation of 
a national disaster recovery strategy or framework in The National 
Strategy for Homeland Security of 2007 and the Post Katrina Emergency 
Management Reform Act of 2006, but no action has been taken to date. 

[41] A. Nisbet et. al., UK Recovery Handbooks for Radiation Incidents 
2009, version 3, prepared for the Radiation Protection Division, 
Centre for Radiation, Chemical and Environmental Hazards, Health 
Protection Agency (Chilton, Didcot, Oxfordshire, U.K., December 2009). 

[42] The United States plans to conduct its first full-scale recovery 
exercise, Liberty RadEx, in April 2010. 

[43] In the United States, the implementation plan for the national 
exercise program provides that after-action reports should be 
completed in 6 months or less following an exercise. In our April 2009 
report (GAO-09-369), we found that FEMA had not ensured that after-
action reports for Tier 1 exercises were completed in a prompt manner. 

[44] Nuclear Emergency Planning Liaison Group, UK Nuclear Recovery 
Plan Template (United Kingdom, March 10, 2009). 

[45] In the United States, DHS's Planning Guidance for Protection and 
Recovery Following Radiological Dispersal Device (RDD) and Improvised 
Nuclear Device (IND) Incidents (August 2008) describes a process for 
establishing late-phase cleanup criteria through a site-specific 
optimization process that should include potential future land uses, 
technical feasibility, costs, cost-effectiveness, and public 
acceptability. 

[End of section] 

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