Combating Nuclear Terrorism
Actions Needed to Better Prepare to Recover from Possible Attacks Using Radiological or Nuclear Materials Gao ID: GAO-10-204 January 29, 2010A 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.
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.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-10-204, Combating Nuclear Terrorism: Actions Needed to Better Prepare to Recover from Possible Attacks Using Radiological or Nuclear Materials
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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:
