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United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

March 2013: 

Emergency Preparedness: 

NRC Needs to Better Understand Likely Public Response to Radiological 
Incidents at Nuclear Power Plants: 

GAO-13-243: 

GAO Highlights: 

Highlights of GAO-13-243, a report to congressional requesters. 

Why GAO Did This Study: 

On March 11, 2011, a tsunami severely damaged the Fukushima Daiichi 
nuclear power plant in Japan and led to the largest release of 
radiation since the 1986 Chernobyl disaster. Japanese authorities 
evacuated citizens within 19 miles of the plant. GAO was asked to 
examine issues related to emergency preparedness at nuclear power 
plants. This report examines (1) federal, licensees’, and local and 
state authorities’ responsibilities in radiological emergency 
preparedness, (2) the activities NRC and FEMA take to oversee licensee 
and local and state radiological emergency preparedness, and (3) NRC 
and FEMA requirements for informing the public on preparedness and NRC’
s understanding of public awareness. GAO reviewed laws, regulations, 
and guidance; examined emergency plans from licensees and local and 
state authorities; visited four nuclear power plants; and interviewed 
federal, local and state, and industry officials. 

What GAO Found: 

The U.S. Nuclear Regulatory Commission (NRC) and the Federal Emergency 
Management Agency (FEMA) are collectively responsible for providing 
radiological emergency preparedness oversight and guidance to 
commercial nuclear power plant licensees and local and state 
authorities around the plants. In general, NRC is responsible for 
overseeing licensees’ emergency preparedness at the plant (on-site), 
and FEMA is responsible for overseeing preparedness by local and state 
authorities around the plant (off-site). NRC and FEMA have also 
established a 10-mile emergency planning zone around nuclear power 
plants. Licensees are responsible for managing on-site radiological 
emergency preparedness and developing and maintaining plans that 
define activities that the nuclear power plant must take to prepare 
for and respond to a potential incident at the plant. Participating 
local and state authorities within the 10-mile zone must develop 
protective actions for responding to a radiological incident, 
including plans for evacuations and sheltering in place. A recent NRC 
task force considered the adequacy of the zone size and concluded that 
no change was currently needed but will be re-evaluated as part of its 
lessons learned efforts for the Fukushima incident. 

NRC and FEMA conduct activities to ensure that licensees and local and 
state authorities have adequate plans and capabilities to respond to a 
radiological incident. For example, NRC and FEMA review emergency 
plans developed by licensees and local and state authorities to ensure 
that planning standards are met. In addition, NRC and FEMA observe 
exercises for each plant that licensees and local and state 
authorities conduct every 2 years to demonstrate their ability to 
respond to an incident. NRC also requires licensees to develop 
estimates of how long it would take for those inside the 10-mile zone 
to evacuate under various conditions. Licensees are to provide these 
evacuation time estimates to local and state authorities to use when 
planning protective action strategies. 

NRC and FEMA require licensees and local and state authorities, 
respectively, to provide information annually on radiation and 
protective actions for the public only inside the 10-mile zone. Those 
in the 10-mile zone have been shown to be generally well informed 
about these emergency preparedness procedures and are likely to follow 
directions from local and state authorities in the event of a 
radiological emergency. In contrast, the agencies do not require 
similar information to be provided to the public outside of the 10-
mile zone and have not studied public awareness in this area. 
Therefore, it is unknown to what extent the public in these areas is 
aware of these emergency preparedness procedures, and how they would 
respond in the event of a radiological emergency. Without better 
information on the public’s awareness and potential response in areas 
outside the 10-mile zone, NRC may not be providing the best planning 
guidance to licensees and state and local authorities. 

What GAO Recommends: 

To better inform radiological emergency preparedness efforts, GAO 
recommends that NRC obtain information on public awareness and likely 
public response outside the 10-mile zone, and incorporate insights 
into guidance, as appropriate. NRC generally disagreed with GAO’s 
finding, stating that its research shows public response outside the 
zone would generally have no significant impact on evacuations. GAO 
continues to believe that its recommendation could improve 
radiological emergency preparedness efforts and is consistent with NRC 
guidance. 

View [hyperlink, http://www.gao.gov/products/GAO-13-243]. For more 
information, contact Frank Rusco at (202) 512-3841 or ruscof@gao.gov 
or Stephen Caldwell at (202) 512-9610 or caldwells@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

NRC and FEMA Guide Licensees and Local and State Authorities in 
Radiological Emergency Preparedness: 

NRC and FEMA Oversee Radiological Emergency Preparedness by Reviewing 
Plans and Exercises: 

NRC and FEMA Require That the Public within the 10-Mile Zone Be 
Informed Annually about Preparedness, but NRC Has Little Information 
about Public Awareness Outside This Zone: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: NRC and FEMA Planning Standards: 

Appendix II: Comments from the Nuclear Regulatory Commission: 

Appendix III: GAO Contacts and Staff Acknowledgments: 

Abbreviations: 

EPA: Environmental Protection Agency: 

FEMA: Federal Emergency Management Agency: 

KI: Potassium Iodide: 

NRC: Nuclear Regulatory Commission: 

REP: Radiological Emergency Preparedness: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

March 11, 2013: 

The Honorable Barbara Boxer: 
Chairman: 
Committee on Environment and Public Works: 
United States Senate: 

The Honorable Sheldon Whitehouse: 
Chairman: 
Subcommittee on Oversight: 
Committee on Environment and Public Works: 
United States Senate: 

The Honorable Robert P. Casey, Jr. 
United States Senate: 

The Honorable Bernard Sanders: 
United States Senate: 

In March 11, 2011, a 9.0-magnitude earthquake and subsequent tsunami 
devastated northeastern Japan and severely damaged the Fukushima 
Daiichi nuclear power plant. The resulting radiological emergency 
involved the most extensive release of radioactive material at a 
nuclear power plant since the 1986 Chernobyl disaster. Following this 
release, the Japanese government evacuated people within 12 miles of 
the plant, and later extended the evacuation to 19 miles. In total, 
almost 150,000 people were evacuated. On March 16, 2011, the U.S. 
Nuclear Regulatory Commission (NRC)--an independent federal agency 
that licenses the 104 U.S. commercial nuclear power reactors and 
regulates their safe operation and security--recommended that U.S. 
citizens within 50 miles of the Fukushima Daiichi plant evacuate. 
[Footnote 1] NRC officials said that this recommendation was a 
conservative estimate based on limited and often conflicting 
information about the exact conditions of the reactors and spent fuel 
pools at the power plant.[Footnote 2] 

The Japanese experience raised questions in the United States about 
radiological emergency preparedness for commercial nuclear power 
plants,[Footnote 3] particularly as populations near plants have 
grown. NRC and the Federal Emergency Management Agency (FEMA), within 
the Department of Homeland Security (DHS), are the two primary federal 
agencies responsible for radiological emergency preparedness for U.S. 
nuclear power plants and their surrounding areas. The Atomic Energy 
Act of 1954, as amended, requires that NRC grant licenses only when 
assured that the public's health and safety are adequately protected. 
In carrying out this requirement, NRC makes radiological health and 
safety determinations on the overall state of emergency preparedness 
for a commercial nuclear power plant site--both at the plant (on-site) 
and in the area surrounding the plant (off-site). FEMA is responsible 
for leading the nation's disaster preparedness activities. In the 
context of radiological preparedness, FEMA is responsible for 
assessing off-site preparedness and providing guidance and assistance 
to local and state authorities through its Radiological Emergency 
Preparedness (REP) program. In making its overall determinations about 
radiological public health and safety for a commercial nuclear power 
plant, NRC reviews FEMA's assessments of off-site emergency 
preparedness as part of NRC's licensing and regulatory requirements. 

Federal preparedness guidance generally states that planning for 
evacuations should extend to 10 miles from the plant because NRC 
studies have shown that health risks to the public outside of 10 miles 
would be low in a radiological incident. NRC and FEMA officials told 
us that if conditions warranted, current planning would allow 
evacuation to occur beyond 10 miles. Nationwide, each of the 65 
operating commercial nuclear power plants has a 10-mile emergency 
planning zone around the plant; in total, these zones include at least 
490 local and state authorities, according to NRC and FEMA officials. 
[Footnote 4],[Footnote 5] These plants and surrounding local and state 
authorities develop plans for evacuations and other protective 
actions, such as sheltering in place, to protect public health and 
safety during an incident in which there is a potential for 
radiological release.[Footnote 6] 

In this context, you asked us to review radiological emergency 
preparedness for commercial nuclear power plants. The objectives of 
this report were to (1) describe the roles and responsibilities of NRC 
and FEMA, the licensees, and local and state authorities for 
radiological emergency preparedness; (2) describe the actions NRC and 
FEMA take to oversee licensee and local and state radiological 
emergency preparedness; and (3) examine NRC and FEMA requirements for 
informing the public about preparedness and NRC's understanding of 
public awareness. This report focuses on NRC, FEMA, and local and 
state efforts inside the 10-mile emergency planning zone, where the 
majority of radiological emergency preparedness planning takes place. 

To address these three objectives, we reviewed relevant federal laws 
and regulations and NRC and FEMA guidance documents, and local and 
state authorities' radiological emergency response plans associated 
with the four commercial nuclear power plants we visited including 
Indian Point Energy Center in New York, St. Lucie Nuclear Power Plant 
in Florida, and Limerick Generating Station in Pennsylvania. We 
selected this nonprobability sample of nuclear power plants based on 
multiple criteria. These criteria included plants that (1) had over 1 
million people within 50 miles and over 200,000 people within 10 miles 
and (2) were located in different FEMA regions. In addition, we wanted 
to observe a plant conducting a radiological emergency preparedness 
exercise, which each plant must conduct once every 2 years.[Footnote 
7] Congressional requesters also expressed interest that we increase 
our regional sample by visiting a plant outside of the East Coast. As 
a result, we selected the San Onofre Nuclear Generating Station 
because it was the only plant outside the East Coast that met some of 
our criteria, including that it has the second highest population in 
the country within 50 miles of a plant. We interviewed NRC and FEMA 
officials from headquarters and the regional offices in which the 
plants were located, the Environmental Protection Agency (EPA), 
licensee officials for the four plants we visited, and local and state 
authorities responsible for emergency preparedness in areas around the 
plants. We observed a radiological emergency preparedness exercise to 
determine how the licensee and federal, local, and state stakeholders 
conduct and evaluate preparedness exercises. We also reviewed the four 
power plants' studies of estimated times for evacuation from the area 
around the plants to understand how these studies inform updates to 
local and state radiological emergency response plans. To determine 
how radiological emergency preparedness information is to be 
communicated to the public, we reviewed NRC and FEMA guidance on how 
licensees and local and state authorities should provide information 
to the public. We also interviewed federal, state, and local officials 
to understand how the public is informed of evacuation planning and 
radiological emergency preparedness. 

We conducted this performance audit from February 2012 to March 2013 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

The key federal agencies involved in emergency preparedness at 
commercial nuclear power plants include NRC and FEMA. NRC makes 
radiological health and safety determinations on the overall state of 
emergency preparedness for a commercial nuclear power plant site--both 
at the plant (on-site) and in the area surrounding the plant (off-
site). In addition, FEMA is responsible for providing guidance and 
assistance to local and state authorities and for assessing off-site 
radiological emergency preparedness and communicating those 
assessments to NRC. EPA also supports radiological emergency 
preparedness by developing a radiation guide that helps licensee 
officials and local and state authorities make decisions during a 
radiological incident at a commercial nuclear power plant. 

Emergency Planning Zones: 

In 1978, a joint NRC and EPA task force issued guidance that provided 
a planning basis for off-site preparedness around commercial nuclear 
power plants[Footnote 8] and, in this guidance, the agencies 
established two emergency planning zones. NRC defines emergency 
planning zones as areas for which planning is needed to ensure that 
prompt and effective actions can be taken to protect the public in the 
event of a radiological incident at a nuclear power plant.[Footnote 9] 
In 1980, NRC and FEMA directed that this emergency planning zone 
guidance should be incorporated into emergency preparedness documents 
and planning. The 1978 guidance established the following two 
emergency planning zones: 

* 10-Mile Plume Exposure Pathway Emergency Planning Zone. According to 
the guidance, the principal health risks in this zone include direct 
exposure to radiation and inhalation exposure from the passing 
radioactive plume. For the plume exposure pathway, evacuation or 
shelter in place should be the primary protective actions. The radius 
for the emergency planning zone implies a circular area, but the 
actual shape can depend upon the characteristics of a particular site. 
For example, local authorities around the Limerick Generating Station 
in Pennsylvania told us that the Pennsylvania Turnpike was used as a 
boundary for part of the 10-mile zone. This road established a well-
known landmark as a boundary that could be referenced when 
communicating instructions to the public about a radiological incident. 

* 50-Mile Ingestion Exposure Pathway Emergency Planning Zone. 
According to the guidance, the principal health risk in this zone is 
exposure from ingesting contaminated water or foodstuffs such as milk, 
fresh vegetables, or fish. In this pathway, health risks would come 
from longer term problems associated with contaminated food and water. 
Early actions to prevent contamination should include removing cows 
from pasture and putting them on stored feed. 

[Side bar] 

Figure: Limerick Generating Station - Limerick, PA: 

[Refer to PDF for image: photograph] 

Sources: GAO and Exelon Corporation. 

[End of figure] 

* Population in 10-mile emergency planning zone: 252,000
* Location: 21 miles NW of Philadelphia, PA
* Generation: Two reactors generate about 2,345 megawatts total, which 
is enough to power more than 2 million homes, according to the licensee.
* Licenses issued: Unit 1 - 8/08/1985; Unit 2 - 8/25/1989; 
* Licenses' expiration: Unit 1 - 10/26/2024; Unit 2 - 6/22/2029. 

Note: Pennsylvania policy calls for a single protective action for the 
entire 10-mile planning zone upon a General Emergency event 
classification. 

Figure: 10-mile Emergency planning zone: 

[Refer to PDF for image: illustrated map] 

10-mile radius from plant; 
10-mile emergency planning zone. 

Source: GAO. 

[End of figure] 

[End of side bar] 

According to NRC officials, the 10-mile and 50-mile emergency planning 
zones established in 1978 remain adequate, as indicated by recent NRC 
studies examining potential consequences at two nuclear power plants, 
[Footnote 10] as well as public health impacts from the March 1979 
incident at Three Mile Island in Pennsylvania and the 2011 Fukushima 
incident. 

Protective actions are designed to decrease the time of exposure to 
radiation so that the benefits of the action offset any undesirable 
consequences, increase the distance from a radioactive source, provide 
shielding from the radiation plume, or limit ingestion of contaminated 
foodstuffs. Local and state authorities can implement a number of 
protective actions within the 10-mile emergency planning zone, 
including evacuating the public from areas that the projected plume is 
expected to cover, sheltering the public in homes or other structures, 
and providing potassium iodide to the public and emergency workers, if 
necessary, to provide some protection from an internal radiation 
exposure of radioactive iodine.[Footnote 11] Further, for any given 
radiological incident, the same protective action may not necessarily 
be appropriate for all areas within the 10-mile zone. For example, the 
public in areas of the zone closest to the plant may be instructed to 
evacuate, while the public in other parts of the zone may be told to 
shelter in place. The appropriate protective action will depend on a 
number of factors, including the projected beginning and duration of 
the radiological release, composition and direction of the release, 
weather conditions, and time of day. According to FEMA guidance, 
certain weather conditions, plume direction, or an event caused by a 
terrorist attack may pose an undue risk to evacuation and could make 
sheltering in place the preferred protective action.[Footnote 12] 

NRC and FEMA Framework for Radiological Emergency Preparedness: 

The incident at the Three Mile Island nuclear power plant near 
Middletown, Pennsylvania, on March 28, 1979, was the most serious in 
U.S. commercial nuclear power plant operating history, even though it 
led to no deaths or injuries to plant workers or members of the nearby 
community. In the incident, equipment malfunctions, design-related 
problems, and worker errors led to a partial meltdown of the core of 
one reactor and small off-site releases of radioactivity. Following 
the March 1979 incident, the White House transferred the federal lead 
role for off-site emergency planning and preparedness activities from 
NRC to FEMA[Footnote 13] and, in 1980, NRC and FEMA entered into a 
memorandum of understanding to establish a framework of cooperation in 
matters of planning of radiological emergency preparedness.[Footnote 
14] This memorandum created a joint NRC and FEMA Steering Committee to 
implement and maintain these efforts. FEMA was directed to coordinate 
all federal planning for the off-site impact of radiological incidents 
and take the lead for assessing local and state authorities' 
radiological emergency response plans, make findings and 
determinations on the adequacy and capability of implementing off-site 
emergency plans, and communicate those findings and determinations to 
NRC. NRC agreed to review those FEMA findings and, in conjunction with 
NRC findings for licensees' emergency plans, determine the overall 
state of emergency preparedness. NRC uses these overall determinations 
to make radiological health and safety decisions when it issues 
licenses to nuclear power plants and during continuous monitoring of 
the overall state of radiological preparedness. 

To manage its new responsibility for off-site emergency planning and 
preparedness in areas around commercial nuclear power plants, FEMA 
established the REP program. The REP program coordinates FEMA's effort 
to provide policies and guidance to local and state authorities to 
ensure that they have adequate capabilities to respond and recover 
from a radiological incident at a commercial nuclear power plant. The 
REP program has two funding sources: (1) a flat fee paid by licensees 
that is the same for each power plant and (2) variable fees paid by 
licensees to cover the cost of REP program activities associated with 
biennial exercises that each nuclear power plant and relevant local 
and state authorities must conduct every 2 years demonstrating the 
capabilities in their radiological emergency response plans. Local and 
state participation in off-site radiological emergency preparedness is 
voluntary, but participation in the program necessitates that local 
and state authorities adhere to the program's requirements set forth 
in federal regulations and guidance.[Footnote 15] FEMA officials told 
us that all local and state governments that have a 10-or 50-mile 
commercial nuclear power plant emergency planning zone within their 
boundaries participate in the REP program. If local and state 
authorities opted not to participate in the REP program, licensees 
would have to demonstrate sufficient capabilities to fulfill off-site 
emergency response responsibilities.[Footnote 16] 

NRC Task Force Established after Fukushima: 

In the aftermath of the Fukushima incident, NRC established the Near-
Term Task Force in March 2011. The goal of the task force was to 
review NRC processes and regulations to determine whether additional 
improvements were needed to NRC's regulatory system and to make 
recommendations for these improvements. The task force review resulted 
in 12 recommendations to NRC, including 3 related to strengthening 
radiological emergency preparedness. For example, the task force 
observed gaps in public awareness in the United States following the 
incident at Fukushima. It recommended that, as part of a follow-on 
review, NRC should pursue emergency preparedness topics related to 
decision making, radiation monitoring, and public education, 
particularly to increase education and outreach in the vicinity of 
each nuclear power plant in the areas of radiation, radiation safety, 
and the appropriate use of potassium iodide. With regard to the size 
of the emergency planning zones, NRC officials told us that the task 
force considered the existing planning structure, including the 10-
mile plume exposure pathway and 50-mile ingestion exposure pathway 
emergency planning zones, and found no basis for recommending a 
change.[Footnote 17] 

NRC and FEMA Guide Licensees and Local and State Authorities in 
Radiological Emergency Preparedness: 

NRC and FEMA are responsible for guiding licensees and local and state 
authorities in radiological emergency preparedness. Specifically, NRC 
and FEMA's regulations and guidance establish the framework for on-
site and off-site radiological emergency preparedness. Licensees 
manage preparedness on-site, and local and state authorities manage 
preparedness off-site. 

NRC and FEMA's Regulations and Guidance Establish the Framework for On-
site and Off-site Radiological Emergency Preparedness: 

NRC and FEMA's regulations for radiological emergency preparedness, 
originally issued in 1980 and 1983, respectively, are based upon 1980 
guidance developed by a joint NRC and FEMA Steering Committee. 
[Footnote 18],[Footnote 19] The regulations include 16 planning 
standards that nuclear power plants and local and state authorities 
are to address in their radiological emergency response plans. The 
standards require such actions as assigning responsibilities for the 
licensee and local and state authorities within the 10-mile emergency 
planning zone; establishing procedures on when and how the licensee is 
to notify local and state authorities and the public; developing a 
range of protective actions for emergency workers and the public 
within this emergency planning zone, such as evacuations or 
recommendations that the public remain indoors; and providing and 
maintaining adequate emergency facilities and equipment to support the 
emergency response. (App. I lists the 16 planning standards.) NRC and 
FEMA have published four supplements that support and expand on the 
1980 guidance, including a 2011 supplement that provides guidance to 
(1) licensees on how to develop site-specific procedures for 
protective action recommendations and (2) local and state authorities 
on how to prepare for protective actions.[Footnote 20] NRC and FEMA 
officials told us that they are in the early stages of developing new 
guidance to update the planning standards and associated guidance 
originally developed in 1980--an effort that they expect will take 4 
to 5 years. 

FEMA has issued guidance for local and state authorities that includes 
a 2012 update to the REP program manual, the principal source of 
policy and guidance relating to off-site radiological emergency 
preparedness. The manual interprets the planning standards established 
in 1980 and provides additional detail to local and state authorities 
on what FEMA expects them to include in their radiological emergency 
response plans. In addition, the manual provides criteria that FEMA 
uses to evaluate the ability of local and state governments to 
implement their emergency plans. Numerous FEMA and local officials we 
spoke with said that counties that participate in REP planning are 
much better prepared for other nonradiological emergencies, like 
hurricanes, because of the planning and exercises required by the REP 
program. 

[Side bar] 

Figure: Indian Point Energy Center — Buchanan, NY: 

[Refer to PDF for image: photograph] 

Sources: GAO and Entergy Nuclear. 

[End of figure] 

* Population in 10-mile emergency planning zone: 273,000; 
* Location: 24 miles N of New York City, NY; 
* Generation: Two reactors generate about 2,000 megawatts total, which 
is enough to power about 2 million homes, according to the licensee; 
* Licenses issued: Unit 2 — 9/28/1973; Unit 3 — 12/12/1975; 
* Licenses' expiration: Unit 2 — 9/28/2013; Unit 3 — 12/12/2015 

Note: This plant has the largest populations within both the 10-mile 
and 50-mile emergency planning zones in the country. 

Figure: 10-Mile Emergency Planning Zone: 

[Refer to PDF for image: illustrated map] 

10-mile radius from plant; 
10-mile emergency planning zone. 

Source: GAO. 

[End of figure] 

[End of side bar] 

Licensees Manage Emergency Preparedness On-site: 

Licensees are responsible for managing on-site radiological emergency 
preparedness and developing and maintaining radiological emergency 
response plans that define specific actions and activities that the 
nuclear power plant must take to prepare for and respond to a 
potential incident at the plant. For example, according to the NRC 
regulations, the licensee must have met certain requirements, 
including the following: 

* defined on-site emergency response staff responsibilities and 
maintained adequate staffing in key areas at all times, 

* developed a standard emergency classification and action level 
scheme to help local and state authorities in determining initial off-
site response measures, 

* established notification procedures for the licensee to communicate 
emergency information to off-site local and state emergency 
organizations, and: 

* provided adequate methods and systems for assessing and monitoring 
actual or potential off-site consequences from a radiological incident. 

Under the NRC regulations, the licensee is also responsible for 
recommending protective actions during a radiological incident 
generally to be implemented by the local and state authorities 
responsible for off-site radiological emergency preparedness--for 
example, recommending which communities should evacuate, and which 
should shelter in place--to minimize and/or avoid exposure to a 
radiological release. The licensee is to make these protective action 
recommendations based on specific plant conditions during the 
emergency, and the potential for, or actual amounts of, radiation 
being released into the atmosphere. For example, the representatives 
of the licensee at the San Onofre Nuclear Generating Station in San 
Clemente, California, told us that they consider wind direction, 
evacuation impediments, and information about how long the 
radiological release would occur and its projected dose when making 
protective action recommendations. 

Local and State Authorities Manage Emergency Preparedness Off-site: 

FEMA regulations and guidance apply where local and state authorities 
take responsibility for managing off-site radiological emergency 
preparedness efforts for the public near nuclear power plants. 
Specifically, local and state authorities develop radiological 
emergency response plans for their jurisdictions using the planning 
standards and guidance detailed in the REP program manual. These off-
site plans are to define specific actions and activities that local 
and state emergency response organizations should take to protect the 
public from a potential incident at the nearby nuclear power plant. 
For example, according to FEMA regulations and guidance, appropriate 
local and state organizations are to take a number of planning 
actions, including the following: 

* identifying and assigning the principal roles, such as the 
responsibilities for the emergency management and law enforcement 
personnel who lead the emergency planning, preparedness, and response 
functions, and the support roles for federal agencies (e.g., FEMA) and 
volunteer organizations (e.g., the American Red Cross); 

* coordinating classifications for different levels of emergencies and 
protective action strategies that are consistent with those 
established by the nearby nuclear power plant; 

* establishing and describing the methods, both primary and backup, 
that are to be used to communicate between all local and state 
governments within the emergency planning zone and with the public; 
and: 

* establishing and describing an emergency operations center for use 
in directing and controlling response functions. 

[Side bar] 

Figure: San Onofre Nuclear Generating Station (SONGS) — San Clemente, 
CA: 

[Refer to PDF for image: photograph] 

Sources: GAO and Southern California Edison. 

[End of figure] 

* Population in 10-mile emergency planning zone: 93,000; 
* Location: 46 miles SE of Long Beach, CA; 
* Generation: Two reactors generate about 2,200 megawatts total, which 
serve about 1.4 million homes and businesses when operating, according 
to the licensee; 
* Licenses issued: Unit 2 — 2/16/1982; Unit 3 — 11/15/1982; 
* Licenses' expiration: Unit 2 — 2/16/2022; Unit 3 — 11/15/2022. 

Note: Not currently operating. 

Figure: 10-Mile Emergency Planning Zone: 

[Refer to PDF for image: illustrated map] 

10-mile radius from plant; 
10-mile emergency planning zone. 

Source: GAO. 

[End of figure] 

[End of side bar] 

Differences in state laws and governing structures, as well as 
differences in FEMA's regional offices, can result in off-site 
emergency plans that meet FEMA regulations in different ways.[Footnote 
21] In some states, local officials lead off-site radiological 
emergency preparedness activities, with support from state emergency 
officials; in other states, radiological emergency preparedness 
activities are directed at a regional or state level. For example, the 
municipal, county, and school district jurisdictions near the Limerick 
Generating Station in Limerick, Pennsylvania, lead their own 
jurisdictions' activities for radiological emergency preparedness with 
state support, whereas the jurisdictions near the San Onofre Nuclear 
Generating Station in San Clemente, California, work together on a 
regional, interjurisdictional planning committee to jointly develop 
plans and policies and to decide on radiological emergency 
preparedness. 

NRC and FEMA Oversee Radiological Emergency Preparedness by Reviewing 
Plans and Exercises: 

NRC and FEMA oversee licensees' and local and state authorities' 
radiological emergency preparedness, respectively, by reviewing 
emergency plans. The two agencies also oversee licensees and local and 
state authorities by assessing their respective capabilities during 
biennial emergency preparedness exercises. These oversight efforts are 
intended to provide reasonable assurance that adequate measures can 
and will be taken in the event of a radiological emergency. 

NRC Reviews Licensees' Emergency Plans, and FEMA Evaluates Local and 
State Plans: 

Under its responsibilities to protect the radiological health and 
safety of the public, NRC must find that there is reasonable assurance 
that adequate protective measures can and will be taken in the event 
of a radiological emergency before it issues an operating license for 
a nuclear power reactor.[Footnote 22] NRC is to base its overall 
finding of reasonable assurance on (1) its assessment of the adequacy 
of a licensee's on-site emergency plans and (2) a review of FEMA 
findings about whether local and state off-site emergency plans are 
adequate and whether there is reasonable assurance they can be 
implemented. 

NRC Reviews: 

NRC bases its assessment of a licensee's emergency planning adequacy 
on its review of the licensee's plans to ensure that they meet the 
planning standards established in NRC regulations.[Footnote 23] 
According to the memorandum of understanding between NRC and FEMA, 
once it grants an operating license, NRC maintains its finding of 
reasonable assurance by overseeing the licensee's on-site preparedness 
and communicating with FEMA about off-site preparedness. A licensee 
may make changes to its emergency plans without NRC approval if the 
licensee conducts and retains an analysis of the changes and its 
determination that the changes do not reduce the plan's effectiveness. 
If an emergency plan change is expected to result in a reduction in 
effectiveness, the licensee must provide the plan changes and 
supporting documentation to NRC for review and approval to ensure the 
plan continues to meet the required planning standards. For example, 
if an off-site fire department is identified and relied upon in the 
licensee's emergency plan, but is no longer able to respond to the 
site because of conflicting responsibilities assigned in local 
emergency plans, then the licensee must identify plan changes that 
ensure that the original capability exists in some form. To help 
maintain its finding of reasonable assurance on-site, NRC has 
established a reactor oversight process that describes the agency's 
program to inspect, measure, and assess the safety performance of 
commercial nuclear power plants and to respond to any decline in 
performance. One of the cornerstones of this process is emergency 
preparedness, and NRC measures the effectiveness of power plant staff 
in carrying out emergency plans and testing licensee emergency plans 
during biennial exercises. NRC's resident inspectors, who are 
permanently located at the plant, as well as inspectors from its 
regional offices, are to ensure that the licensee is effectively 
implementing and reviewing emergency preparedness, according to NRC's 
reactor oversight process. 

As part of the licensing process, NRC also requires nuclear power 
plants to develop studies of estimated evacuation times in order to 
identify potential challenges to efficient evacuation in the event of 
a nuclear power plant incident. These studies are to include an 
analysis of the time required to evacuate different portions of a 
nuclear power plant's 10-mile planning zone.[Footnote 24] Licensees 
are to (1) use these evacuation time estimates in formulating 
protective action recommendations and (2) provide the estimates to 
local and state authorities for use in developing off-site protective 
action strategies. To account for demographic changes around 
commercial nuclear power plants, NRC revised regulations, effective 
December 2011, to require that these evacuation time estimates be 
updated (1) after every decennial census and (2) any time an increase 
in the permanent population results in an evacuation time increase of 
25 percent or 30 minutes, whichever is less for one of the potential 
evacuation areas. In addition, 2011 NRC guidance directs that 
evacuation time estimates include a consideration of shadow 
evacuations, defined as an evacuation of the public in areas outside 
an officially declared evacuation area.[Footnote 25] Specifically, the 
guidance states that these evacuation time estimate studies should 
include a shadow evacuation consideration of 20 percent of the 
population out to 15 miles away from the nuclear power plant. In 
addition, NRC guidance states that the shadow population consideration 
is to account for the extent to which this population's evacuation 
would impede the evacuation of those under evacuation orders. 

FEMA Reviews: 

As stated above, NRC considers FEMA's reviews of each local and state 
authority's emergency plan for off-site preparedness during the 
initial licensing process. In reviewing these plans, FEMA uses the 
planning standards and evaluation criteria collectively identified in 
its regulations and guidance to determine whether these off-site plans 
are adequate to protect public health and safety by providing 
reasonable assurance that appropriate protective measures can be taken 
off-site in the event of a radiological emergency. In addition, the 
local and state authorities must participate in an initial full-scale 
exercise with the licensee.[Footnote 26] FEMA approves the 
authorities' plans as being adequate if the plans and the exercise 
provide reasonable assurance that the plans are adequate and can be 
implemented.[Footnote 27] FEMA then communicates this approval or 
disapproval to the state and to NRC for consideration in the licensing 
process. 

After the initial FEMA finding that the off-site emergency plans and 
their capabilities provide reasonable assurance about off-site 
radiological emergency preparedness, FEMA relies on a combination of 
other activities to ensure that local and state authorities maintain 
this reasonable assurance. In particular, FEMA relies on the following: 

* Biennial exercises. Each nuclear power plant and its relevant local 
and state authorities must conduct an exercise every 2 years that 
demonstrates their abilities to implement their respective emergency 
plans.[Footnote 28] Local and state authorities that participate in 
the biennial exercises submit their emergency plans to FEMA staff 
before the exercises, and FEMA evaluators review the plans and assess 
off-site performance based on the activities identified in those plans. 

* Annual letter of certification. To help FEMA determine whether local 
and state authorities' plans and implementation activities provide 
reasonable assurance about off-site radiological preparedness, states 
that participate in the REP program annually submit a letter of 
certification to FEMA providing assurance that all required activities 
have been undertaken as appropriate by local and state authorities. 
Among other things, the state is asked to certify that the plans have 
been reviewed for accuracy and completeness and provide documentation 
that supports off-site planning, such as the information that 
authorities are required to provide annually to those in the 10-mile 
emergency planning zone (e.g., establishing classifications for 
different levels of emergencies and protective action instructions): 

* Staff assistance visits. FEMA assigns a representative to serve as 
the primary advisor for the local and state authorities near each 
nuclear power plant, and the FEMA representatives are to visit local 
and state authorities to answer questions and assist in planning and 
exercise preparation. Local authorities near the Limerick Generating 
Station in Limerick, Pennsylvania, told us that they are in contact 
with FEMA representatives several times a month, including during site 
assistance visits, and feel they have a well-established relationship 
with FEMA. 

FEMA may also review off-site emergency preparedness following events 
such as electric grid blackouts, intentional harm, or natural 
disasters in the vicinity of commercial nuclear power plants, which 
can result in infrastructure damage that can degrade the capabilities 
of local and state authorities to respond to a radiological incident. 
For example, natural disasters that destroy roads or bridges around a 
plant could affect the ability of local and state authorities to 
effectively conduct evacuations. According to the memorandum of 
understanding between NRC and FEMA, FEMA is to (1) inform NRC promptly 
if FEMA questions the continued adequacy of off-site emergency 
preparedness, (2) review off-site radiological emergency preparedness 
if it believes that a review is necessary to determine whether off-
site preparedness remains adequate, and (3) inform NRC in writing 
about the results of its review. NRC is to consider the information 
FEMA provides, in addition to its assessment of the licensee's 
facility, in deciding to allow the restart or continued operation of 
an affected operating nuclear power plant. For example, after 
Hurricane Katrina in 2005, the Waterford Nuclear Generating Station in 
Killona, Louisiana, was shut down for about 2 weeks. FEMA conducted a 
review of local and state authorities' ability to respond to a 
radiological incident and concluded that off-site radiological 
preparedness was adequate to justify restarting the plant. 

NRC and FEMA Oversee and Evaluate Radiological Emergency Preparedness 
Exercises: 

NRC and FEMA also oversee radiological emergency preparedness by 
reviewing the biennial exercises conducted by licensees and local and 
state authorities.[Footnote 29] According to NRC and FEMA guidance, 
these exercises simulate incidents at nuclear power plants that 
require coordination between licensees, local and state authorities, 
and federal entities, and provide the opportunity for NRC and FEMA 
officials to evaluate the emergency plans in action. According to NRC 
guidance, NRC's inspectors are to observe these biennial exercises to 
evaluate the adequacy of the licensee's performance, including the 
operation of the alert and notification system and the individual 
performance of the emergency response staff.[Footnote 30] In addition, 
NRC inspectors are to evaluate the licensee's ability to assess and 
critique its own performance to identify and correct weaknesses 
observed during the exercise. For example, one NRC inspector told us 
that he observes how the licensee responds to an escalation of events, 
prepares and issues protective action recommendations, and makes 
assessments of radiological doses during an exercise. The inspector 
also said that he observes whether the licensee is able to identify 
its own performance problems and then takes the necessary corrective 
actions. 

[Side bar] 

Figure: St. Lucie Nuclear Power Plant — Jensen Beach, FL: 

[Refer to PDF for image: photograph] 

Sources. GAO and Florida Power & Light. 

[End of figure] 

* Population in 10-mile emergency planning zone: 207,000; 
* Location: 10 miles SE of Fort Pierce, FL; 
* Generation: Two reactors generate about 1,700 megawatts total, which 
is enough to supply the annual needs of more than 500,000 homes, 
according to the licensee; 
* Licenses issued: Unit 1 — 3/01/1976; Unit 2 — 6/10/1983; 
* Licenses' expiration: Unit 1 — 3/01/2036; Unit 2 — 4/06/2043 

Note: This plant has the fifth largest population within the 10-mile 
emergency planning zone of all U.S. commercial nuclear power plants, 
as well as one of the highest population growth rates over the last 10 
years. 

Figure: 10-Mile Emergency Planning Zone: 

[Refer to PDF for image: illustrated map] 

10-mile radius from plant; 
10-mile emergency planning zone. 

Source: GAO. 

[End of figure] 

[End of side bar] 

With respect to off-site evaluation, under agency guidance, FEMA 
evaluators are to observe the conduct of local and state authorities 
and write detailed after-action reports that identify planning and 
performance problems, if any. FEMA is also to work with the local and 
state authorities to develop an improvement plan that contains 
information on how the authorities will improve performance or correct 
problems identified in the after-action report, the personnel 
responsible for specific actions, and an anticipated timeline for 
improvement or correction. Local and state authorities are expected to 
correct the problem or redemonstrate a capability within a specified 
time frame.[Footnote 31] If the local and state authorities do not 
address the problems, FEMA officials told us that they would notify 
NRC that off-site preparedness was insufficient to protect public 
health and safety. Furthermore, NRC officials told us that they could 
require the plant to shut down until the off-site problems were 
addressed but that they have never required such a shutdown. 

Licensees develop exercise scenarios ahead of biennial exercises with 
input from local and state authorities to provide the maximum training 
opportunities for all the entities involved.[Footnote 32] However, 
those who participate in the exercises, including power plant staff, 
do not know about the contents of the exercise scenario beforehand. In 
addition, an official with one local authority near the St. Lucie 
Nuclear Power Plant told us that they have injected certain incidents 
into an ongoing exercise, such as a disabled truck on a freeway, to 
test elements of their emergency plans that may not otherwise be 
included in the initial scenario. Exercises begin when an initiating 
event is simulated at the nuclear power plant in accordance with the 
scenario the licensee developed. Plants must be able to assess, 
classify, and declare an emergency condition within 15 minutes after 
plant operators have information indicating that an emergency 
condition exists. Plants are then to provide local and state 
authorities with an emergency classification level that identifies the 
severity of the event and the actions that could be taken. The 
classification levels are considered trigger points for surrounding 
authorities, so that when a certain level is set, a series of actions 
must be performed. The classification levels are the following: 

* Notification of unusual event--a potential degradation of safety or 
indication of a security threat that involves no expected release of 
radiation unless further degradation occurs. 

* Alert--an actual or potential substantial degradation of safety at 
the plant or a security event that involves probable life threatening 
risk to site personnel or damage to site equipment, and any release is 
expected to be limited to small fractions of EPA protective action 
guide exposure levels.[Footnote 33] 

* Site area emergency--an actual or likely major failure of plant 
protection equipment that protects the public or a security event that 
could lead to the likely failure of or prevents access to plant 
protection equipment. Any radiation releases are not expected to 
exceed exposure levels from the EPA protective action guides beyond 
the site boundary. A site area emergency may, for example, trigger 
precautionary evacuations of schools and parks. 

* General emergency--an actual or imminent substantial core 
degradation or melting with the potential for loss of containment of 
radiation or security events that result in an actual loss of physical 
control of the facility, with radiation releases reasonably expected 
to exceed EPA protective action guide exposure levels off-site for 
more than the immediate area. The Three Mile Island incident is the 
sole general emergency ever to have occurred in the United States. 
Since the Three Mile Island incident, in Pennsylvania, it is state 
policy to conduct a single protective action for the full 10-mile 
emergency planning zone whenever a general emergency at a nuclear 
power plant in the state is declared. 

If the situation on-site reaches a level where local and state 
authorities should consider taking protective actions, the licensee is 
to recommend the protective actions that off-site authorities should 
take. The authority responsible for decision making is to take the 
licensee's recommendation into consideration, together with other 
considerations, such as radiological dose assessment readings. We 
noted that local and state authorities near the four power plants we 
visited have dose assessment teams that are to take radiation readings 
in the area during an incident and coordinate radiation readings with 
licensee dose assessment teams to help assess the situation and to 
help with overall decision making. In some states, the local counties 
and cities have the primary role in making protective action 
decisions. For example, around the St. Lucie Nuclear Power Plant in 
Florida, county officials for several counties told us that they 
develop individual emergency plans, but they work together during an 
emergency to coordinate the appropriate protective action decision for 
the area. According to local and state authorities around the San 
Onofre Nuclear Generating Station in California, two counties, three 
cities, one U.S. Marine Corps base, the California Department of Parks 
and Recreation, and the power plant licensee formed an 
interjurisdictional planning committee to coordinate an emergency plan 
for the area. Members of this committee collectively decide on the 
protective action to take during an incident, based on the licensee's 
protective action recommendation. 

NRC and FEMA Require That the Public within the 10-Mile Zone Be 
Informed Annually about Preparedness, but NRC Has Little Information 
about Public Awareness Outside This Zone: 

NRC and FEMA require licensees and local and state authorities to 
provide emergency preparedness information annually to the public 
within the 10-mile emergency planning zone, and NRC has studied public 
awareness within the zone. A 2008 NRC study found that the public 
within the 10-mile zone is generally aware of emergency preparedness 
and likely to follow instructions, but NRC has not studied likely 
responses to an incident outside this zone. Without knowing reactions 
outside the 10-mile zone, NRC cannot be confident that its estimates 
of shadow evacuations outside the 10-mile zone provide a reasonable 
basis for planning off-site protective action strategies. 

NRC and FEMA Require Licensees and Local and State Authorities to 
Provide Detailed Information Annually to the Public within the 10-Mile 
Planning Zone: 

NRC and FEMA's regulations and guidance establish the framework for 
how licensees and local and state authorities are to inform the public 
about how to respond during a radiological emergency and provide 
educational information about radiation. Specifically, NRC regulations 
require that licensees annually provide basic emergency planning 
information to the public within the 10-mile emergency planning zone. 
This information may take various forms, including brochures, 
telephone book inserts, or calendars. According to NRC and FEMA 
guidance, these materials must include educational information on 
radiation, protective measure information such as evacuation routes 
and relocation centers, information relating to the special needs of 
the handicapped, and a contact for additional information. FEMA 
guidance also states that the content of these materials is generally 
determined through coordination between local and state authorities 
and the licensees. For example, St. Lucie County authorities in 
Florida told us that they develop the annual mailing in cooperation 
with neighboring Martin County authorities, so that both counties use 
the same materials, and then the licensee prints and distributes this 
mailing to households and businesses within the 10-mile emergency 
planning zone around the nuclear power plant in St. Lucie, Florida. 
Licensees told us that they translate these materials into non-English 
languages and make them available to the public, depending on the 
demographic makeup of their communities, as directed by FEMA guidance. 
NRC and FEMA updated their guidance on these public information 
programs in November 2011 to provide more information about protective 
actions in public information materials. For example, the 2011 
guidance recommends that local and state authorities explain the 
purpose of staged evacuations, define expectations for those under an 
advisory, clarify expectations for those who are not at home when a 
protective action is ordered, and discourage parents from picking up 
their children from school during an event. Staged evacuation occurs 
when the population in one area is evacuated, while the population in 
another area is told to remain indoors until it is their turn to 
evacuate. According to NRC guidance, the success of staged evacuation 
depends on public compliance with sheltering in place while the 
population most at risk is evacuated. NRC's research on the matter has 
suggested that the public requires clear and direct communication both 
to evacuees and to those near, but not within, affected areas. 

FEMA guidance also instructs local and state authorities to conduct 
outreach to certain special needs populations within the 10-mile 
emergency planning zone. Specifically, FEMA's guidance instructs 
licensees and local and state authorities to take the following 
actions: 

* Conduct outreach to transient populations. Authorities may, for 
example, issue pamphlets, stickers, or signs in hotels, motels, and 
public parks. Local and state authorities in communities around San 
Onofre Nuclear Generating Station near San Clemente, California, told 
us that they provide a card to campers when they enter state parks 
that tells them what to do and which radio stations to tune into in 
the event of an emergency at the nuclear power plant; are working with 
hotels to include emergency information in each hotel room; and have 
trained hotel managers and staff to make sure they are registered with 
the appropriate jurisdiction to receive emergency alerts. 

* Have a plan to identify individuals who need assistance when 
evacuating. Some local and state authorities told us that they 
accomplish this by including a card inside the annual mailing that 
enables residents with special needs to identify their needs and 
complete and mail back the card to the licensee or to their local 
authorities, so that the authorities can track special needs 
individuals during an emergency. 

FEMA guidance also instructs local and state authorities to establish 
coordinated arrangements for dealing with rumors and unconfirmed 
reports to provide the public with direct access to accurate 
information during an incident, as well as to provide local and state 
authorities with information about trends in public inquiries. For 
example, some local and state authorities told us that they have 
established dedicated public information telephone numbers and 
assigned staff to answer questions in the event of an incident. Local 
and state authorities we spoke with varied in their use of social 
media forums to monitor and respond to rumors before or during an 
incident. Some local and state authorities near the four plants we 
visited said that they use social media to provide preparedness 
information, while others said they do not use social media. FEMA 
officials told us that they are currently studying different social 
media technologies and how information is disseminated to the public. 
In addition, local and state authorities are required to conduct 
annual efforts to brief news media on emergency plans, radiation 
information, and their points of contact in an emergency. State of 
Florida authorities go beyond these requirements and told us they 
conduct two media briefings annually, hold an annual press conference 
with the Lieutenant Governor, and provide radiological emergency 
preparedness information sheets to the press. 

Local and state authorities we spoke with told us that they conduct 
other voluntary activities to inform the public in the 10-mile 
emergency planning zone. These activities include informing residents 
about annual siren testing required in the zone, conducting 
presentations to community groups and at local events, providing 
information to parents at schools, and posting information on 
websites. Authorities we spoke with said that some of these voluntary 
activities may also occur outside the 10-mile emergency planning zone. 

NRC and FEMA do not require public information efforts for 
radiological emergency preparedness outside the 10-mile emergency 
planning zone. According to NRC and FEMA guidance, for the worst 
incidents at commercial nuclear power plants, immediate life-
threatening radiation doses would generally not occur outside the 10-
mile zone and would probably not require protective actions outside 
the zone.[Footnote 34] In the 50-mile emergency planning zone, the 
principal exposure to radiation would be ingestion of contaminated 
food and water, and this would represent a longer term problem. 
According to FEMA guidance, the licensee and state authorities are to 
make information available to farmers and other members of the 
agricultural industry within the 50-mile emergency planning zone. This 
information is to describe recommended protective actions for 
agricultural industries to minimize contamination of the food supply. 
Some state and local authorities told us that they sometimes conduct 
public education efforts outside of the 10-mile zone that include 
radiological emergency preparedness information. However, some 
authorities also expressed concerns about the radiological awareness 
levels of residents and the potential for shadow evacuations. For 
example, Los Angeles County authorities told us that one of their 
greatest concerns in the event of an incident at the San Onofre 
Nuclear Generating Station is a rumor that results in shadow 
evacuations, which could result in clogged highways as people who are 
not in danger choose to evacuate unnecessarily. 

NRC Has Studied Awareness and Likely Responses to an Incident Inside 
the 10-Mile Emergency Planning Zone but Not Outside of It: 

In 2008, NRC conducted a study with the Sandia National Laboratory to 
examine public awareness of emergency preparedness information and 
likely responses within the 10-mile emergency planning zone. The 
laboratory administered a national telephone survey to random members 
of households within each of the 63 10-mile emergency planning zones. 
[Footnote 35] According to the study results, those surveyed were 
generally well-informed, with many having taken action to prepare for 
an emergency. Furthermore, most of those who responded to the survey 
reported that they believe they are likely to follow directions from 
local and state authorities in the event of an incident at the nuclear 
power plant.[Footnote 36] However, about 20 percent of those 
responding to the survey reported that they would evacuate even when 
told evacuation for them was not necessary, referred to as a shadow 
evacuation. NRC guidance states that a shadow evacuation can impede 
the evacuation of those under evacuation orders. Also, most of those 
who responded to the survey and who have children in school reported 
that they were likely to pick up their children from school in an 
emergency. Using the findings from this study, NRC updated guidance on 
protective action strategies and improving public information programs 
in November 2011.[Footnote 37] This guidance recommends that local and 
state authorities provide more information about the purpose of staged 
evacuations, in addition to simply describing the different types of 
protective action strategies. 

To address the potential for shadow evacuations, NRC officials told us 
that they used the study results to determine the potential shadow 
evacuation rate outside the 10-mile emergency planning zone. 
Specifically, NRC instructed licensees to consider shadow evacuations 
of 20 percent of the public out to 15 miles from the nuclear power 
plant when the licensee develops estimates of evacuation times. 
[Footnote 38] However, the study surveyed residents inside the 10-mile 
emergency planning zone, a population that is given radiological 
emergency preparedness information every year and that is therefore 
more familiar with the power plant, radiation risks, protective 
actions, and evacuation routes than the public outside the 10-mile 
zone.[Footnote 39] Without this same level of information, those 
outside the zone may not respond in a similar manner to a radiological 
incident as those inside the zone. Because the survey was conducted on 
a relatively more educated and aware population, the 20-percent rate 
for shadow evacuations may not accurately capture the level of shadow 
evacuations that may occur outside the 10-mile zone. According to NRC 
and FEMA officials, their agencies have not examined public awareness 
outside the 10-mile emergency planning zone and therefore do not know 
if a 20-percent estimate of shadow evacuations is reasonable. 
Therefore, licensee evacuation time estimates may not accurately 
consider the impact of shadow evacuations. Without estimates of 
evacuation times based on more solid understanding of public awareness 
outside the 10-mile zone, licensees and NRC and FEMA cannot be 
confident about the reliability of their estimates. If shadow 
evacuations are not correctly estimated, planning for a radiological 
emergency may not sufficiently consider the impact of the public 
outside the 10-mile emergency planning zone. Shadow evacuations 
outside this zone greater than the assumed 20-percent rate would put 
additional traffic on roadways, possibly delaying the evacuation of 
the public inside the emergency planning zone and potentially 
increasing the risk to public health and safety. 

Conclusions: 

The Fukushima Daiichi incident raised questions about the U.S. 
government's ability to protect its citizens if a similar incident 
were to occur here. NRC and FEMA have developed regulations and 
guidance to help licensees and local and state authorities create and 
test radiological emergency response plans that are intended to 
provide reasonable assurance that they can adequately protect public 
health and safety in the event of a radiological incident at a nuclear 
power plant. NRC regulations and guidance also direct licensees to 
annually provide emergency preparedness information to the public 
within their 10-mile emergency planning zones. Furthermore, the 2008 
NRC study by Sandia National Laboratory demonstrated that the public 
within these planning zones is generally likely to respond to 
instructions from local and state authorities in the event of an 
incident. On the basis of this study, NRC estimated that 20 percent of 
the public within the zones would choose to evacuate even when told 
evacuation for them was not necessary (shadow evacuations). NRC then 
directed licensees to consider this same percentage of shadow 
evacuations for the public outside the planning zone when estimating 
evacuation times. However, communities outside the 10-mile zone 
generally do not receive the same level of information as those within 
the 10-mile zone and therefore may not be as knowledgeable about 
appropriate conduct during a radiological emergency as those inside 
the zone and may not respond in a similar manner. If the public 
outside the zone evacuates unnecessarily at a greater rate than 
expected, these shadow evacuations would put additional traffic on 
roadways, possibly delaying the evacuation of the public inside the 
emergency planning zone and potentially increasing the risk to public 
health and safety. However, because neither NRC nor FEMA have examined 
public awareness outside of the 10-mile emergency planning zone, they 
do not know how the public outside this zone will respond. 
Specifically, they do not know if a 20-percent estimate of shadow 
evacuations is reasonable. Therefore, licensee evacuation time 
estimates may not accurately consider the impact of shadow 
evacuations. Without estimates of evacuation times based on more solid 
understanding of public awareness, licensees and NRC and FEMA cannot 
be confident about the reliability of their estimates. If shadow 
evacuations are not correctly estimated, planning for a radiological 
emergency may not sufficiently consider the impact of the public 
outside the emergency planning zone. 

Recommendation for Executive Action: 

To better inform efforts for nuclear power plant emergency 
preparedness and planning, we recommend that NRC Commissioners obtain 
information on public awareness of radiological emergency preparedness 
for communities outside the 10-mile emergency planning zone and the 
likely response of those communities in the event of a radiological 
incident at a nuclear facility and consider how these results may 
affect estimates for shadow evacuations outside the zone. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the NRC Commissioners and the 
Secretary of the Department of Homeland Security for their review and 
comment. DHS provided no written comments. NRC provided written 
comments on the draft report, which are reproduced in appendix II, and 
technical comments from NRC, which we incorporated into the report as 
appropriate. 

NRC found our discussion of emergency preparedness programs at nuclear 
power plants to be complete, but generally disagreed with our finding 
on shadow evacuations. Specifically, NRC did not believe that the 
report accurately captured the technical basis for the NRC's use of 20 
percent as a reasonable estimate of shadow evacuations beyond 10 
miles. NRC explained that it has conducted considerable research on 
evacuations and has confidence that shadow evacuations generally have 
no significant impact on traffic movement. Lastly, NRC stated that the 
licensee's current emergency planning bases continue to provide 
reasonable assurance of protection of the public's health and safety. 

We stand by our finding and the related recommendation that NRC should 
obtain information on public awareness and the likely responses of 
communities outside the 10-mile zone in the event of a radiological 
incident at a nuclear power plant. 

First, as stated in the report, NRC issued guidance in 2011 that 
directs licensees to consider shadow evacuations of 20 percent of the 
population located from 10 miles to 15 miles from a nuclear plant when 
estimating evacuation times.[Footnote 40] NRC told us that this shadow 
evacuation estimate came primarily from a telephone survey it 
conducted of the public within each of the 63 10-mile emergency 
planning zones around the country. However, residents inside the 10-
mile zone are provided radiological information every year and are 
therefore more familiar with the power plant, radiation risks, 
protective actions, and evacuation routes than those outside the zone. 
Without this same level of information, residents outside the zone may 
not respond in a similar manner as those inside the zone, and the use 
of a 20 percent shadow evacuation estimate for the public outside the 
zone may therefore not be reliable. 

Second, NRC asserts that it has conducted considerable research on 
evacuations and has confidence that shadow evacuations generally have 
no significant impact on traffic movement. GAO acknowledges that NRC 
has conducted research on evacuations, but these studies are generally 
based on evacuations that have resulted from non-nuclear incidents 
such as hurricanes, wildfires, and chemical spills. It is unclear 
whether the public would behave the same for a nuclear evacuation as 
it would for the incidents that NRC has studied. As we say in the 
report, NRC's Near-Term Task Force established after the Fukushima 
incident observed gaps in public awareness in the United States. The 
task force recommended that, as part of a follow-on review, NRC should 
pursue emergency preparedness topics related to decision-making, 
radiation monitoring, and public education, particularly to increase 
education and outreach in the vicinity of each nuclear power plant in 
the areas of radiation, radiation safety, and the appropriate use of 
potassium iodide. We believe the task force's finding that there are 
gaps in public awareness and understanding regarding nuclear incidents 
supports our recommendation that NRC should obtain information on 
public awareness and the likely responses of communities outside the 
10-mile zone in the event of a radiological incident at a nuclear 
power plant. 

Finally, with regard to NRC's confidence that shadow evacuations 
generally have no significant impact on traffic movement, according to 
NRC's 2011 guidance mentioned earlier, evacuation time estimate 
studies should include a shadow evacuation consideration of 20 percent 
of the population out to 15 miles away from the nuclear power plant 
because the additional traffic generated has the potential to impede 
an evacuation of the emergency planning zone. Thus, NRC has previously 
acknowledged in its guidance that traffic from shadow evacuations may 
impede the intended evacuations. For these reasons, we believe our 
recommendation to improve NRC's understanding of the effect of shadow 
evacuations outside of the 10-mile zone is consistent with NRC's 
guidance about the potential effects of shadow evacuations on 
evacuations within the emergency planning zone. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to the 
Chairman of the NRC, the Secretary of the Department of Homeland 
Security, the appropriate congressional committees, and other 
interested parties. In addition, this report will be available at no 
charge on the GAO website at [hyperlink, http://www.gao.gov]. 

If you or your staff members have any questions about this report, 
please contact Frank Rusco at (202) 512-3841 or ruscof@gao.gov or 
Stephen Caldwell at (202) 512-9610 or caldwells@gao.gov. Contact 
points for our Offices of Congressional Relations and Public Affairs 
may be found on the last page of this report. Key contributors to this 
report are listed in appendix III. 

Signed by: 

Frank Rusco: 
Director, Natural Resources and Environment: 

Signed by: 

Stephen L. Caldwell: 
Director, Homeland Security and Justice: 

[End of section] 

Appendix I: NRC and FEMA Planning Standards: 

NRC and FEMA Planning Standards: 1; Assignment Of Responsibility 
(Organization Control); 
Primary responsibilities for emergency response by the nuclear 
facility licensee and by state and local organizations within the 
emergency planning zones have been assigned, the emergency 
responsibilities of the various supporting organizations have been 
specifically established, and each principal response organization has 
staff to respond and to augment its initial response on a continuous 
basis. 

NRC and FEMA Planning Standards: 2; On-site Emergency Organization; 
On-duty facility licensee responsibilities for emergency response are 
unambiguously defined, adequate staffing to provide initial facility 
accident response in key functional areas is maintained at all times, 
timely augmentation of response capabilities is available, and the 
interfaces among various on-site response activities and off-site 
support and response activities are specified. 

NRC and FEMA Planning Standards: 3; Emergency Response Support and 
Resources; 
Arrangements for requesting and effectively using assistance resources 
have been made, arrangements to accommodate state and local staff at 
the licensee's emergency operations facility have been made, and other 
organizations capable of augmenting the planned response have been 
identified. 

NRC and FEMA Planning Standards: 4; Emergency Classification System; 
A standard emergency classification and action level scheme, the bases 
of which include facility system and effluent parameters, is in use by 
the nuclear facility licensee, and state and local response plans call 
for reliance on information provided by facility licensees for 
determinations of minimum initial off-site response measures. 

NRC and FEMA Planning Standards: 5; Notification Methods and 
Procedures; 
Procedures have been established for notification, by the licensee, of 
state and local response organizations and for notification of 
emergency personnel by all organizations; the content of initial and 
follow up messages to response organizations and the public has been 
established; and means to provide early notification and clear 
instruction to the populace within the plume exposure pathway 
emergency planning zone have been established. 

NRC and FEMA Planning Standards: 6; Emergency Communications; 
Provisions exist for prompt communications among principal response 
organizations to emergency personnel and to the public. 

NRC and FEMA Planning Standards: 7; Public Education and Information; 
Information is made available to the public on a periodic basis on how 
they will be notified and what their initial actions should be in an 
emergency (e.g., listening to a local broadcast station and remaining 
indoors), the principal points of contact with the news media for 
dissemination of information during an emergency (including the 
physical location or locations) are established in advance, and 
procedures for coordinated dissemination of information to the public 
are established. 

NRC and FEMA Planning Standards: 8; Emergency Facilities and Equipment; 
Adequate emergency facilities and equipment to support the emergency 
response are provided and maintained. 

NRC and FEMA Planning Standards: 9; Accident Assessment; 
Adequate methods, systems, and equipment for assessing and monitoring 
actual or potential off-site consequences of a radiological emergency 
condition are in use. 

NRC and FEMA Planning Standards: 10; Protective Response; 
A range of protective actions has been developed for the plume 
exposure pathway emergency planning zone for emergency workers and the 
public. Guidelines for the choice of protective actions during an 
emergency, consistent with federal guidance, are developed and in 
place, and protective actions for the ingestion exposure pathway 
emergency planning zone appropriate to the locale have been developed. 

NRC and FEMA Planning Standards: 11; Radiological Exposure Control; 
Means for controlling radiological exposures, in an emergency, are 
established for emergency workers. The means for controlling 
radiological exposures shall include exposure guidelines consistent 
with EPA emergency worker and lifesaving activity protective action 
guides. 

NRC and FEMA Planning Standards: 12; Medical and Public Health Support; 
Arrangements are made for medical services for contaminated injured 
individuals. 

NRC and FEMA Planning Standards: 13; Recovery and Reentry Planning and 
Post-Accident Operations; 
General plans for recovery and reentry are developed. 

NRC and FEMA Planning Standards: 14; Exercises and Drills; 
Periodic exercises are (will be) conducted to evaluate major portions 
of emergency response capabilities, periodic drills are (will be) 
conducted to develop and maintain key skills, and deficiencies 
identified as a result of exercises or drills are (will be) corrected. 

NRC and FEMA Planning Standards: 15; Radiological Emergency Response 
Training; 
Radiological emergency response training is provided to those who may 
be called on to assist in an emergency. 

NRC and FEMA Planning Standards: 16; Responsibility for the Planning 
Effort: Development, Periodic Review, and Distribution of Emergency 
Plans; 
Responsibilities for plan development and review and for distribution 
of emergency plans are established, and planners are properly trained. 

Sources: NRC and FEMA, Criteria for Preparation and Evaluation of 
Radiological Emergency Response Plans and Preparedness in Support of 
Nuclear Power Plants, NUREG-0654/FEMA-REP-1, Rev. 1 (Washington, D.C.: 
November 1980). 

[End of table] 

[End of section] 

Appendix II: Comments from the Nuclear Regulatory Commission: 

United States Nuclear Regulatory Commission: 
Washington, D.C. 20555-0001: 

February 11, 2013: 

Mr. Franklin Rusco, Director: 
Natural Resources and Environment: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Rusco: 

Thank you for providing the' .S. Nuclear Regulatory Commission (NRC) 
the opportunity to review and comment on the U.S. Government 
Accountability Office's (GAO's) draft report GA0-13-243, "Emergency 
Preparedness: NRC Needs to Better Understand Likely Public Response to 
Radiological Incidents." The NRC staff reviewed the draft report and 
found the discussion on the emergency preparedness programs at nuclear 
power plants to be complete. However, the NRC staff does not believe 
that the report accurately captured the technical basis for the NRC's 
use of 20 percent as a reasonable estimate of shadow evacuation in the 
population beyond 10 miles. The NRC staff has conducted considerable 
research into evacuations, including the impact of shadow evacuations 
on evacuation outcomes. Based on this research, NRC has confidence 
that shadow evacuations generally have no significant impact on 
traffic movement, and concludes that the licensee's current emergency 
planning bases continue to provide reasonable assurance of protection 
of the public's health and safety. The NRC staff has provided its 
technical basis for shadow evacuations in the enclosure to this letter 
along with a few additional comments. 

If you have any questions regarding this response, please contact 
Jesse Arildsen. Mr. Arildsen can be reached by telephone at (301) 415-
1785. 

Signed by: 

R.W. Borchardt: 
Executive Director for Operations: 

Enclosure: U.S. Nuclear Regulatory Commission Staff Comments: 

[End of section] 

Appendix III: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Frank Rusco, (202) 512-3841 or ruscof@gao.gov: 

Stephen Caldwell, (202) 512-9610 or caldwells@gao.gov: 

Staff Acknowledgments: 

In addition to the individuals named above, Kimberly Gianopoulos, 
Assistant Director; Nathan Gottfried; Eugene Gray; David Lysy; and 
David Messman made key contributions to this report. Important 
contributions were also made by Elizabeth Beardsley, Marcia Crosse, R. 
Scott Fletcher, Jonathan Kucskar, Steven Putansu, Dan Royer, Carol 
Shulman, and Kiki Theodoropoulos. 

[End of section] 

Footnotes: 

[1] NRC grants licenses to companies that may operate more than one 
commercial nuclear power plant. For purposes of this report, we refer 
to both licensed companies and the physical power plants as licensees. 

[2] In this report, when we use the term power plant, we are referring 
to an entire site, and nuclear power reactors are the individual units 
at each site. Some nuclear plants store spent nuclear fuel in 
specially designed pools of water, and a fire at a spent fuel pool 
could result in the widespread release of radiation. 

[3] For the purposes of this report, radiological emergency 
preparedness involves a combination of planning, resources, training, 
conducting exercises, and organizing to build, sustain, and improve 
operational capabilities for responding to an incident at a commercial 
nuclear power plant. 

[4] For the purposes of this report, local and state authorities 
include any local, state, or tribal government; supporting private 
industry and voluntary organizations; and any other off-site response 
organization responsible for carrying out emergency functions in the 
area surrounding the plant during a radiological emergency. 

[5] There are 104 operating reactors at the 65 operating commercial 
power plants. 

[6] Protective actions include measures to avoid or reduce the 
public's exposure to radiation from a release of radioactive material, 
such as sheltering in place, evacuation, and/or use of potassium 
iodide (KI) in pill or liquid form. 

[7] Because this was a nonprobability sample, the information 
collected during these site visits cannot be generalized to all 65 
commercial nuclear power plants but provides illustrative information. 

[8] NRC and EPA, Planning Basis For the Development of State and Local 
Government Radiological Emergency Response Plans in Support of Light 
Water Nuclear Power Plants, NUREG-0396/EPA 520/1-78-016 (Washington, 
D.C.: December 1978). 

[9] NRC guidance uses the term "incident" instead of "accident" in 
discussing radiological planning and preparedness because an 
intentional hostile action directed at a nuclear site could become the 
direct cause of a radiological emergency. 

[10] NRC, State of the Art Reactor Consequence Analyses Project Volume 
I: Peach Bottom Integrated Analysis, NUREG/CR-7110 (Albuquerque, New 
Mexico: January 2012). The Peach Bottom Atomic Power Station is 
located in Peach Bottom Township, Pennsylvania. NRC, State of the Art 
Reactor Consequence Analysis Project Volume 2: Surry Integrated 
Analysis NUREG/CR-7110 (Albuquerque, New Mexico: January 2012). The 
Surry Power Station is located in Surry County, Virginia. 

[11] According to NRC officials, the use of iodine to protect against 
the effects of radiation is recognized as an effective supplement to 
evacuation for situations involving radiation releases when evacuation 
cannot be implemented, or if exposure were to occur as a result of 
evacuation. Potassium iodide's usefulness as a protective measure is 
limited and only affords protection for the thyroid gland from an 
internal radiation exposure of radioactive iodine. It does not protect 
the body from radiation exposure or radiation dose. 

[12] FEMA, Radiological Emergency Preparedness Program Manual (April 
2012). 

[13] See 44 C.F.R. § 350.3(a) (2012), NRC and FEMA, Memorandum of 
Understanding Between NRC and FEMA To Accomplish a Prompt Improvement 
in Radiological Emergency Planning and Preparedness, 45 Fed. Reg. 5847 
(Jan. 24, 1980) (referencing directive). 

[14] 44 C.F.R. pt. 353 app. A "Memorandum of Understanding Between 
Federal Emergency Management Agency and Nuclear Regulatory 
Commission." (2012) (codifying current memorandum of understanding, as 
last revised 2003). 

[15] 44 C.F.R. pt. 350 (2012); FEMA, Radiological Emergency 
Preparedness Program Manual, (April 2012). 

[16] 10 C.F.R. 50.47 § (c)(1) (2012). 

[17] NRC officials told us that the agency might consider a review of 
the basis for the emergency planning zone size in the future. 

[18] 10 C.F.R. § 50.47(b) (2012); 44 C.F.R. § 350.5 (b)(2012). 

[19] NRC and FEMA, Criteria for Preparation and Evaluation of 
Radiological Emergency Response Plans and Preparedness in Support of 
Nuclear Power Plants, NUREG-0654/FEMA-REP-1, Rev. 1 (Washington, D.C.: 
November 1980). 

[20] NRC and FEMA, Criteria for Preparation and Evaluation of 
Radiological Emergency Response Plans and Preparedness in Support of 
Nuclear Power Plants: Guidance for Protective Action Strategies, NUREG-
0654/FEMA-REP-1, Rev. 1 Supplement 3 (Washington, D.C.: November 2011). 

[21] FEMA is composed of 10 regional offices that oversee FEMA 
activities. FEMA officials told us that regional REP offices have 
flexibility when interpreting FEMA guidance in order to reflect 
regional conditions. 

[22] NRC issues licenses for commercial nuclear power reactors to 
operate for 40 years. Under current regulations, licensees may renew 
their licenses for up to 20 years. Licensees seeking operating license 
renewal of reactors do not require a new finding of reasonable 
assurance. 

[23] NRC officials told us that they also review license conditions 
for the facility. 

[24] 10 C.F.R. pt. 50 app. E (IV) (2012). 

[25] NRC, Criteria for Development of Evacuation Time Estimate 
Studies, NUREG/CR-7002 (Albuquerque, New Mexico: November 2011). 

[26] To support the initial licensing process, the licensee and local 
and state authorities must conduct a full-scale exercise. According to 
FEMA guidance, the full-scale exercise should include all response 
organizations that would be involved in a response to an incident at 
the plant, but subsequent biennial exercises may not need to include 
all response organizations. 

[27] A public meeting must also be held near the power plant to, among 
other things, acquaint the public with the plans and answer questions 
about FEMA's review of the plan and the exercise. 

[28] Licensees and local and state authorities told us they conduct 
other drills and exercises throughout the year to train emergency 
response staff and ensure emergency preparedness is adequate. 

[29] According to FEMA and NRC officials, these exercises are usually 
conducted simultaneously, but simultaneous exercises are not required. 
NRC officials told us that this flexibility is provided to address 
circumstances in which there are multiple commercial nuclear power 
plant sites within a state, or two licensees on the same site. 

[30] Licensees are required by the planning standards to have 
procedures to notify local and state authorities and emergency 
personnel. 

[31] The time frames vary depending on the type of problem identified 
and the steps taken, if any, to address them. 

[32] FEMA officials told us that FEMA and NRC also participate in some 
aspects of scenario development. 

[33] EPA developed a Manual of Protective Action Guides and Protective 
Actions for Nuclear Incidents in 1980 to help local and state 
authorities determine when to take protective actions in response to 
an airborne plume during the early phase of an incident at a nuclear 
power plant. A protective action guide represents the projected 
radiation dose to individuals that triggers the need for protective 
actions from a release of radioactive material. EPA officials told us 
that protective action guides do not imply acceptable levels of risk 
or a boundary between safe and unsafe conditions, but they represent 
the approximate radiation levels at which certain protective actions 
are justified. 

[34] NRC and FEMA, Criteria for Preparation and Evaluation of 
Radiological Emergency Response Plans and Preparedness in Support of 
Nuclear Power Plants, NUREG-0654/FEMA-REP-1, Rev. 1 (Washington, D.C.: 
November 1980). 

[35] There are currently 65 nuclear power plants in the United States; 
however, some nuclear power plants are located on the same site and 
therefore have the same emergency planning zone. 

[36] Estimates for this survey have 95 percent confidence intervals 
within plus or minus 3.5 percentage points unless otherwise noted. 

[37] NRC and FEMA, Criteria for Preparation and Evaluation of 
Radiological Emergency Response Plans and Preparedness in Support of 
Nuclear Power Plants: Guidance for Protective Action Strategies, NUREG-
0654/FEMA-REP-1, Rev. 1 Supplement 3 (Washington, D.C.: November 2011). 

[38] NRC, Criteria for Development of Evacuation Time Estimate 
Studies, NUREG/CR-7002 (Albuquerque, New Mexico: November 2011). This 
guidance did not include instructions for shadow evacuation estimates 
for the area beyond 15 miles. 

[39] Some local authorities we spoke with said that they had also 
conducted surveys on preparedness for all types of emergencies, and 
some of these studies asked questions on radiological emergency 
awareness and likely reactions of the public. 

[40] NRC, Criteria for Development of Evacuation Time Estimate 
Studies, NUREG/CR-7002 (Albuquerque, New Mexico: November 2011). 

[End of section] 

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