This is the accessible text file for GAO report number GAO-09-996T 
entitled 'Combating Nuclear Terrorism: Preliminary Observations on 
Preparedness to Recover from Possible Attacks Using Radiological or 
Nuclear Materials' which was released on September 14, 2009. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as part 
of a longer term project to improve GAO products' accessibility. Every 
attempt has been made to maintain the structural and data integrity of 
the original printed product. Accessibility features, such as text 
descriptions of tables, consecutively numbered footnotes placed at the 
end of the file, and the text of agency comment letters, are provided 
but may not exactly duplicate the presentation or format of the printed 
version. The portable document format (PDF) file is an exact electronic 
replica of the printed version. We welcome your feedback. Please E-mail 
your comments regarding the contents or accessibility features of this 
document to 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 


Before the Subcommittee on Emerging Threats, Cybersecurity, and Science 
and Technology, Committee on Homeland Security, House of 

United States Government Accountability Office: 

For Release on Delivery: 
Expected at 9:30 a.m. EDT:
Monday, September 14, 2009: 

Combating Nuclear Terrorism: 

Preliminary Observations on Preparedness to Recover from Possible 
Attacks Using Radiological or Nuclear Materials: 

Statement of Gene Aloise, Director:
Natural Resources and Environment: 


GAO Highlights: 

Highlights of GAO-09-996T, a testimony to Subcommittee on Emerging 
Threats, Cybersecurity, and Science and Technology, Committee on 
Homeland Security, House of Representatives. 

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. The timely cleanup 
of contaminated areas, however, could speed the restoration of normal 
operations, thus reducing the adverse consequences from an incident. 

This testimony examines (1) the extent to which federal agencies are 
planning to fulfill their responsibilities to assist cities and their 
states in cleaning up areas contaminated with radioactive materials 
from RDD and IND incidents; (2) what is known about the federal 
government’s capability to effectively cleanup areas contaminated with 
radioactive materials from RDD and IND incidents, and (3) suggestions 
from government emergency management officials on ways to improve 
federal preparedness to provide assistance to recover from RDD and IND 
incidents. We also discuss recovery activities in the United Kingdom. 
This testimony is based on our ongoing review of recovery preparedness 
issues for which we examined applicable 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 large cities and their states, as well as 
FEMA and EPA regional office officials. 

What GAO Found: 

DHS, through FEMA, is responsible for developing a comprehensive 
emergency management system to respond to and recover from natural 
disasters and terrorists attacks, including RDD and IND attacks. The 
response phase would involve evacuations and providing medical 
treatment to those who were injured; the recovery phase would include 
cleaning up the radioactive contamination from an attack in order to 
permit people to return to their homes and businesses. To date, much 
federal attention has been given to developing a response framework, 
with less attention to recovery. Our survey found that almost all 
cities and states would be so overwhelmed by an RDD or IND incident 
that they would rely on the federal government to conduct almost all 
analysis and cleanup activities that are essential first steps towards 
recovery. However, we found that the federal government has not 
sufficiently planned to undertake these activities. For example, FEMA 
has not issued a national disaster recovery strategy or plans for RDD 
and IND incidents as required by law. Existing federal guidance 
provides only limited direction for federal agencies to develop their 
own recovery plans and conduct exercises to test preparedness. Out of 
over 70 RDD and IND exercises conducted in the last 5 years, only three 
have included interagency recovery discussions following a response 

Although DOE and EPA have experience in the cleanup of small-scale 
radiation-contaminated areas, their lack of knowledge and capability to 
apply approaches to address the magnitude of an RDD or an IND incident 
could increase recovery costs and delay completion. According to an 
expert at Idaho National Laboratory, experience has shown that not 
selecting the appropriate decontamination technologies 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 
thousands 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 analysis and cleanup actions to promote recovery after these 

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, our review of 
the United Kingdom’s preparedness to recover from radiological 
terrorism showed that that country has already taken actions similar to 
those suggested by our survey respondents, such as issuing national 
recovery guidance, conducting a full-scale recovery exercise, and 
publishing a national handbook for radiation incidents. 

View [hyperlink,] or key 
components. For more information, contact Gene Aloise at (202) 512-3841 

[End of section] 

Madam Chairwoman and Members of the Subcommittee: 

I am pleased to be here today to discuss preliminary observations from 
our ongoing work reviewing the federal government's preparedness to 
assist localities in recovering from a terrorist attack involving 
either a radiological dispersal device (RDD)--frequently referred to as 
a dirty bomb--or an improvised nuclear device (IND). Responding to such 
an attack would involve evacuations, providing medical treatment to 
those who were injured, and protecting property; recovery would include 
cleaning up the radioactive contamination from an attack in order to 
permit people to return to their homes and businesses.[Footnote 1] A 
terrorist's use of an RDD or IND to release radioactive materials into 
the environment could have devastating consequences. However, quickly 
analyzing and cleaning up contaminated areas after a deliberate release 
of radioactive materials could speed the recovery from such an attack 
by restoring normal operations of critical infrastructure, services, 
businesses, and public activities, and thus reducing the many adverse 
consequences from an attack. According to a recent 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 2] 
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 not 
only include 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 city block or as large as several square 
miles. An IND would create a nuclear 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. Thus, the 
consequences of RDD and IND incidents would vary in magnitude, with an 
RDD expected to cause few deaths but produce significant economic and 
psychological impacts, and an IND causing thousands of deaths and more 
extensive destruction. 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 uncomplicated way in which this material could be 
dispersed. In contrast, detonating an IND would require a terrorist 
group to obtain nuclear weapons material--which is generally heavily 
secured--and have highly sophisticated expertise and equipment to 
fabricate this material into a weapon. 

If an RDD or IND incident occurred, a number of federal, state, and 
local government departments and agencies would be involved in the 
analysis and cleanup of areas contaminated with radioactive material as 
part of the recovery process.[Footnote 3] 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 resources or when an incident is managed by 
federal agencies under their own authorities. The Department of 
Homeland Security (DHS) is the principal federal agency 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 rely on other federal agencies that have 
more experience with the analysis and cleanup of areas contaminated 
with radioactive materials. For example, in certain circumstances, the 
Department of Energy (DOE) would have primary responsibilities for the 
initial analysis of areas contaminated with radioactive materials, and 
the Environmental Protection Agency (EPA) would have primary 
responsibility for cleaning up the radiation-contaminated 
areas.[Footnote 4] The Department of Defense (DOD) would act in support 
of the primary federal agencies. Federal agencies, including EPA, DOE, 
the Nuclear Regulatory Commission, as well as state regulatory agencies 
have set various cleanup standards for decontaminating affected areas. 

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 us to obtain dangerous quantities of radioactive material. 
[Footnote 5] 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 6] 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 7] 

Our testimony today presents preliminary observations from our ongoing 
effort to examine (1) the extent to which federal agencies are planning 
to fulfill their responsibilities to assist cities and their states in 
cleaning up areas contaminated with radioactive material from RDD and 
IND incidents; (2) what is known about the federal government's 
capability to effectively cleanup areas contaminated with radioactive 
material from RDD and IND incidents; and (3) suggestions from 
government emergency management officials on ways to improve federal 
preparedness to assist state and local governments in recovering from 
RDD and IND incidents. In addition, we are providing information on our 
review of actions taken in the United Kingdom to prepare for recovering 
from RDD and IND incidents. We expect to issue our final report on this 
topic in November 2009. 

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 national 
laboratories; and conducted a survey of emergency management officials 
in 13 cities considered to be at high-or medium-risk of such attacks, 
officials in these cities' states, and similar officials in all federal 
FEMA and EPA regional offices.[Footnote 8] We also reviewed information 
on the number and type of RDD and IND response and recovery exercises 
that have been conducted in the last 5 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. 


In the aftermath of September 11, 2001, there is heightened concern 
that terrorists may try to smuggle nuclear or radiological materials 
into the United States. These materials could be used to produce either 
an IND or an RDD. An IND is a crude nuclear bomb made with highly 
enriched uranium or plutonium. Nonproliferation experts estimate that a 
successful IND could have a yield in the 10 to 20 kiloton range (the 
equivalent to 10,000 to 20,000 tons of TNT). An IND with a 20-kiloton 
yield would have the same force as the equivalent of the yield of the 
bomb that destroyed Nagasaki; it could devastate the heart of a medium- 
sized U.S. city and result in thousands of casualties and radiation 
contamination over a wide area. 

Security experts have also raised concerns that terrorists could obtain 
radioactive material 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 
radioactive source. These 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. If these sealed sources fell into the hands of 
terrorists, they could use them to produce a simple, but potentially 
dangerous weapon, by packaging explosives, such as dynamite, with the 
radioactive material, which would be dispersed when the bomb went off. 
Depending on its type, amount, and form (powder or solid), the 
dispersed radioactive material could cause radiation sickness in people 
nearby and produce serious economic costs and the psychological and 
social disruption associated with the evacuation and subsequent cleanup 
of the contaminated area. 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. 

Another form of nuclear terrorism occurred with the release of 
radioactive materials in London. In November 2006, Alexander 
Litvinenko, a former officer of the Russian Federal Security Service, 
was poisoned with a gram of polonium-210--about the size of a grain of 
salt.[Footnote 9] 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 identified, with the help of the victim, 47 sites across 
London where he had been during the few days between his poisoning and 
death. Of these locations, about 20 showed signs of this radioactive 
material. Investigators identified over 900 people who might have been 
exposed to the polonium, including some who may have been exposed while 
aboard airplanes. After a thorough examination, a few of these 
individuals turned out to have significant exposure levels. The 
decontamination activities at these sites, including a hotel room, 
spanned 19 days, involved a number of methods and technologies, and 
cost in excess of $200,000. 

Cities and States Would Likely Request Federal Assistance for Cleanup 
of Radiation-Contaminated Areas after RDD and IND Incidents, but 
Limited Federal Planning Exists for Recovering from Such Incidents: 

While state and local government responders would be expected to 
respond first to a terrorist incident within their jurisdiction, they 
would also expect that the federal government would be prepared to 
provide the necessary assistance for them to expedite the recovery from 
such an incident. Emergency management officials from 13 cities and the 
majority of their respective states indicated in our survey that they 
would rely on the federal government to conduct and fund all or almost 
all analysis and cleanup activities associated with recovering from an 
RDD or IND incident of the magnitude described in the National Planning 
Scenarios.[Footnote 10] However, when asked which federal agencies they 
would turn to for this assistance, city and state respondents replied 
inconsistently and frequently listed several federal agencies for the 
same activity. In our view, these responses indicate that there is 
confusion among city and state officials regarding federal 
responsibilities for these activities in the event of a terrorist 
incident. This confusion, if not addressed, could hamper the timely 
recovery from an RDD or IND incident. Emergency management officials 
from all the cities and most of their respective states told us they 
would rely on the federal government because their technical and 
financial resources would be overwhelmed by a large RDD incident--and 
certainly by an IND incident. Most of these officials 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. Fewer than half of the respondents from the 
cities (6 of 13), but most of those from states (8 of 10) indicated 
that it should be primarily a federal responsibility. The others 
stressed the need for shared responsibilities with the federal 

Despite the anticipated reliance by city and state governments on the 
federal government for analysis and cleanup activities following an RDD 
or IND incident, FEMA has not developed a national disaster recovery 
strategy or related plans to guide involvement of federal agencies in 
these recovery activities, as directed by federal law and executive 
guidance.[Footnote 11] To date, much federal attention has been given 
to developing a response framework, with less attention to recovery. 
The new 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 12] 
She also told us that FEMA recognizes its responsibility to prepare a 
national disaster recovery strategy but she could not provide a time 
frame for its completion. However, she stated that when a recovery 
strategy is issued it should provide guidance to revise state, local, 
and other federal agency operational plans to fulfill their respective 
responsibilities. Moreover, the FEMA official in charge of planning 
told us that the agency has put on hold issuing component plans that 
describe how federal capabilities would be integrated to support state 
and local planning for response to and recovery from RDD and IND 

Some existing federal guidance documents addressing the assets and 
responsibilities of federal agencies for both response and to a lesser 
extent recovery-related activities have been issued as annexes to the 
National Response Framework and in other documents.[Footnote 13] For 
example, there is a nuclear and radiological incident annex, which 
describes the policies, situations, concept of operations, and 
responsibilities of the federal departments and agencies for the 
immediate response and short-term recovery from incidents involving the 
release of radiological materials. There are also emergency support 
function annexes that provide a structure for coordinating federal 
interagency support in response to domestic incidents. 

In addition, two other sources of guidance have been issued that, 
according to FEMA officials, represent stop-gap measures until it can 
issue more integrated planning guidance. In 2008, FEMA issued updated 
guidance for protection and recovery following RDD and IND incidents. 
[Footnote 14] This guidance was to provide some direction to federal, 
state, and local emergency response officials in developing operational 
plans and response protocols for protection of emergency workers after 
such an incident. In regard to recovery, this document recommended a 
process to involve the affected public, state and local officials, and 
other important stakeholders in the identification of acceptable 
cleanup criteria, given the specifics of the incident. The other 
document, issued by the Homeland Security Council, pertains to 
responding to an IND in the first few days prior to the arrival of 
other necessary federal resources. This document was prepared because 
the prior FEMA guidance did not sufficiently prepare state and local 
emergency response authorities for managing the catastrophic 
consequences of a nuclear detonation.[Footnote 15] Moreover, DOE, EPA 
and DOD are developing more detailed operational guidance on their own 
based on the existing federal guidance. For example, DOE has supported 
research on operational guidelines for implementation of protective 
actions described in the FEMA guidance,[Footnote 16] EPA has drafted 
guidance for the optimization process following RDD and IND 
incidents,[Footnote 17] and DOD has established operational plans for 
consequence management following terrorist incidents, including RDD and 
IND attacks.[Footnote 18] 

Federal agencies and local jurisdictions have been using the available 
guidance as a basis for planning RDD and IND exercises to test the 
adequacy of their plans and skills in a real-time, realistic 
environment to evaluate their level of preparedness. We identified more 
than 70 RDD and IND response exercises planned and carried out by 
federal, state and local agencies since mid-2003. However, officials 
with FEMA's National Exercise Directorate told us that only three of 
the RDD response exercises had a recovery component. According to these 
officials, recovery discussions following an RDD or IND response 
exercise have typically not occurred because of the time needed to 
fully address the response objectives of the exercise, which are seen 
as a higher priority. The most recent response exercise, based in 
Albany, New York, and planned by DOE, set aside 2 days for federal, 
state, and local agencies to discuss operational recovery issues. One 
unresolved operational issue discussed during this exercise pertained 
to the transition of the leadership of the Federal Radiological 
Monitoring and Assessment Center (FRMAC) from the initial analysis of 
the contaminated area, led by DOE, to the later cleanup phase, led by 
EPA. For example, there are remaining questions regarding the level and 
quality of the monitoring data necessary for EPA to accept the 
leadership of FRMAC. While we were told that 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 pertains to the distribution of 
responsibilities for the ownership, removal, and disposal of 
radioactive debris from an RDD or IND incident. Both of these 
operational issues are to be examined again in the first full-scale RDD 
recovery exercise, planned and led by EPA, to take place April 2010. 

Insufficient Knowledge and Capability to Use Available Approaches for 
Cleanup of Radiation-Contaminated Areas Could Impede Efforts to Recover 
from RDD and IND Incidents: 

Although some federal agencies, such as DOE and EPA, have substantial 
experience using various cleanup methods and technologies to address 
radiation-contaminated areas, little is known about how these 
approaches might be applied in an RDD or IND incident. 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 in 1980, which established 
the Superfund program, EPA has undertaken significant efforts to study, 
develop, and use technologies that can address radioactive 
contamination. DOD has also played a major role in studying potential 
applications for innovative technologies for its Superfund sites. 

Not much is known, however, about the application to RDD and IND 
incidents of available cleanup methods and technologies because such an 
incident has never occurred in this country, although research is 
currently underway to gain a better understanding of potential 
applications. According to decontamination experts at 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 standard methods and technologies for cleaning up 
radiation-contaminated areas, more research is needed to develop 
standard national guidance for their application in urban environments. 
The lack of guidance for identifying cost-effective cleanup methods and 
technologies in the event of an RDD or IND incident might mean that the 
cleanup approach taken could unnecessarily increase the cost of 
recovery. According to a decontamination expert at Idaho National 
Laboratory, for example, experience has shown that not selecting the 
appropriate decontamination technologies 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. Moreover, 
he told us that without guidance and discussion early in the response 
phase, a contractor might use an approach for no other reason than it 
was used before in an unrelated situation. In addition, the Lawrence 
Livermore National Laboratory decontamination experts told us that 
decontamination costs can increase dramatically depending on the 
selection of an initial approach and the length of time before 
remediation actions are taken. For example, they said that the 
conventional use of high pressure water hosing to decontaminate a 
building is effective under normal conditions but could be the wrong 
cleanup approach for an RDD using cesium-137 because the force of the 
water would actually cause this radioactive isotope to penetrate even 
further into porous surfaces. A senior EPA official with the Office of 
Radiation and Indoor Air told us that studies are currently underway to 
determine the efficacy of pressure washing for removing contamination 
from porous urban surfaces. 

In addition to the lack of knowledge about the application of cleanup 
methods and technologies for wide-area urban contamination from an RDD 
or IND incident, there are also limitations in federal capabilities to 
handle in a timely manner the magnitude of tasks and challenges that 
would be associated with these incidents. For example, we found that 
limitations in federal capabilities to complete some analysis and 
cleanup activities might slow the recovery from an RDD or IND 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. Respondents representing most of the cities (9 of 13) and states 
(7 of 10), and respondents from most 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 cleanup activities in the event of 
an RDD or IND incident. 

City, State, and Federal Emergency Management Officials Have Several 
Suggestions to Improve Federal Recovery Preparedness for RDD and IND 

Respondents from nearly all the cities and states we surveyed expressed 
the need for a national disaster recovery strategy to address gaps and 
overlaps in current federal guidance. 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 said that sharing 
information with law enforcement agencies is necessary for appropriate 
planning for an RDD or IND incident--which they generally consider as 
low-level threats--but only half of the respondents indicated that they 
were getting sufficient intelligence information. Emergency management 
officials from FEMA and EPA regional offices generally concurred with 
these observations and suggestions of the city and state respondents. 

The United Kingdom's Handling of the 2006 Polonium Incident and 
Subsequent Actions to Better Prepare for an RDD or IND Incident: 

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 including testing 
hundreds of people who may have been exposed to radiation and a cleanup 
of numerous radiation-contaminated areas. All this activity resulted 
from an amount of radioactive material the size of a grain of salt-- 
many times smaller than the amount of radioactive material found in 
certain common medical devices that could be used in an RDD. Because of 
its experience in dealing with the cleanup from the 2006 polonium 
incident and other actions the United Kingdom has taken to prepare for 
an RDD or IND attack, we visited that country to examine its recovery 
preparedness programs. United Kingdom 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, with subsequent non- 
statutory emergency response and recovery guidance to complement this 
emergency preparedness legislation. The emergency response and recovery 
guidance describes the generic framework for multi-agency 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 of the communities. 

* Developed on-line, updatable 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. 

* Issued a national handbook for radiation incidents in 2008. This 
handbook provides scientific information, including checklists for 
planning in advance of an incident, fact sheets on decontamination 
approaches, and advice on how to select and combine management of these 

* 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 lessons learned from this exercise were 
incorporated into the United Kingdom's recovery strategy. 

* Issued updated nuclear recovery plan guidance in 2009. This guidance 
provides direction on recovery from events involving a radiological 
release from a civil or defense nuclear reactor, as well as the 
malicious use of radiological or nuclear materials. Among other things, 
it requires that all high-risk cities in the United Kingdom prepare 
recovery plans for such incidents. 

In addition to these initiatives, in 2005, the United Kingdom 
established a special Government Decontamination Service. 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 19] 

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 a larger 
RDD or IND incident. 

Madam Chairwoman, this completes my prepared statement. I would be 
happy to respond to any questions that you or other Members of the 
Subcommittee may have at this time. 

For further information about this testimony, please contact me at 
(202) 512-3841 or Individuals who made important 
contributions to this testimony were Ned Woodward (Assistant Director), 
Nancy Crothers, James Espinoza, Tracey King, Thomas Laetz, Tim Persons, 
Jay Smale, and Keo Vongvanith. 

[End of section] 


[1] For the purpose of this testimony, analysis activities include 
efforts to sample and analyze affected areas to determine the type and 
location of contamination, and cleanup activities include efforts to 
contain radioactive materials, decontaminate affected areas, and manage 
the radioactive waste. 

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

[3] The Robert T. Stafford Disaster Relief and Emergency Assistance Act 
primarily establishes the programs and processes for the federal 
government to provide major disaster and emergency assistance to state 
and local governments, as well as to tribal nations, individuals, and 
qualified nonprofit organizations. Pub. L. No. 100-107, 102 Stat. 4689 
(1988) (codified as amended at 42 U.S.C. § 5121 et. seq.) 

[4] The Federal Radiological Monitoring and Assessment Center (FRMAC) 
is a DOE-led interagency asset that is available on request to respond 
to an RDD or IND incident. The FRMAC is responsible for coordinating 
all environmental radiological monitoring, sampling, and assessment 
activities for the response. DOE leads the FRMAC for the initial 
response phase and EPA assumes leadership for the cleanup phase. 

[5] GAO, Nuclear Security: Actions Taken by NRC to Strengthen Its 
Licensing Process for Sealed Radioactive Sources Are Not Effective, 
[hyperlink,] (Washington, 
D.C.: July 12, 2007). 

[6] GAO, Nuclear Security: Action May be Needed to Reassess the 
Security of NRC-Licensed Research Reactors, [hyperlink,] (Washington, D.C.: Jan. 31, 

[7] GAO, Observations on DHS and FEMA Efforts to Prepare for and 
Respond to Major and Catastrophic Disasters and Address Related 
Recommendations and Legislation, [hyperlink,] (Washington, D.C.: July 31, 
2007); Actions Taken to Implement the Post-Katrina Emergency Management 
Reform Act of 2006, [hyperlink,] 
(Washington, D.C.: Nov. 21, 2008); and National Preparedness: FEMA Has 
Made Progress, but Needs to Complete and Integrate Planning, Exercise, 
and Assessment Efforts, [hyperlink,] (Washington, D.C.: Apr. 30, 

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

[9] Investigators believe that this pure polonium was probably produced 
in a Russian research reactor. 

[10] The National Preparedness Guidelines (Sept. 2007) developed 15 
national planning scenarios, including scenarios for RDD and IND 
incidents. The scenarios form the basis for coordinated federal 
planning, training, exercises, and grant investments to prepare for 
emergencies of all types. 

[11] The Post-Katrina Emergency Management Reform Act requires FEMA to 
report back to the Congress within 270 days of enactment of this 2006 
legislation describing the details of a national disaster recovery 
strategy. Pub. L. No. 109-295, § 682, 120 Stat. 1355, 1445-46 (2006). 
In addition, the National Security Council, National Strategy for 
Homeland Security (Washington, D.C., Oct. 2007), states that the 
federal government will prepare a framework for recovery. 

[12] In our November 21, 2008 report [hyperlink,], we found that FEMA had drafted 
a national disaster recovery strategy but that it was under review at 
the time with no timeframe for completion. 

[13] DHS, National Response Framework (Washington, D.C., Jan. 2008). 
This document provides a guide for how the nation should conduct all- 
hazards response, including the roles and responsibilities of agencies 
involved in response efforts. It does not address long-term recovery 
issues, including cleaning up areas contaminated with radioactive 

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

[15] Homeland Security Council, Planning Guidance for Response to a 
Nuclear Detonation (Washington, D.C.: Jan. 16, 2009). 

[16] C.Yu, et al. Preliminary Report on Operational Guidelines 
Developed for Use in Emergency Preparedness and Response to a 
Radiological Dispersal Device Incident, DOE/HS-0001 (Washington, D.C.: 
DOE, Office of Health Safety, and Security, February 2009). This 
document does not represent official policy, methods, or agency 

[17] EPA, EPA Guidance on the Optimization Process Following a 
Radiological Dispersal Device or Improvised Nuclear Device Incident 
(Washington, D.C.: September 2009 Draft). 

[18] We provided testimony on this DOD initiative in GAO, Homeland 
Defense: Preliminary Observations on Defense Chemical, Biological, 
Radiological, Nuclear, and High-Explosive Consequence Management Plans 
and Preparedness, [hyperlink,] 
(Washington, D.C.: July 28, 2009). 

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

[End of section] 

GAO's Mission: 

The Government Accountability Office, the audit, evaluation and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the performance 
and accountability of the federal government for the American people. 
GAO examines the use of public funds; evaluates federal programs and 
policies; and provides analyses, recommendations, and other assistance 
to help Congress make informed oversight, policy, and funding 
decisions. GAO's commitment to good government is reflected in its core 
values of accountability, integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO's Web site [hyperlink,]. Each 
weekday, GAO posts newly released reports, testimony, and 
correspondence on its Web site. To have GAO e-mail you a list of newly 
posted products every afternoon, go to [hyperlink,] 
and select "E-mail Updates." 

Order by Phone: 

The price of each GAO publication reflects GAO’s actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAO’s Web site, 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional 

To Report Fraud, Waste, and Abuse in Federal Programs: 


Web site: [hyperlink,]: 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Congressional Relations: 

Ralph Dawn, Managing Director, 
(202) 512-4400: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7125: 
Washington, D.C. 20548: 

Public Affairs: 

Chuck Young, Managing Director, 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: