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Report to Congressional Committees: 

United States Government Accountability Office: 
GAO: 

March 2009: 

Nuclear Security: 

Better Oversight Needed to Ensure That Security Improvements at 
Lawrence Livermore National Laboratory Are Fully Implemented and 
Sustained: 

Physical Security at Lawrence Livermore National Laboratory: 

GAO-09-321: 

GAO Highlights: 

Highlights of GAO-09-321, a report to congressional committees. 

Why GAO Did This Study: 

In April 2008, the Department of Energy’s (DOE) security inspection at 
Lawrence Livermore National Laboratory (LLNL) found significant 
weaknesses, particularly in LLNL’s protective force’s ability to assure 
the protection of weapons-grade (special) nuclear material. LLNL is 
overseen by the National Nuclear Security Administration (NNSA), a 
separately organized agency within DOE, and managed by a contractor. 
NNSA is planning to remove most of the special nuclear material from 
LLNL. GAO was asked to (1) characterize security deficiencies 
identified in the 2008 inspection; (2) determine the factors that 
contributed to these deficiencies; (3) identify LLNL’s corrective 
actions to address security deficiencies; and (4) assess LLNL’s plan to 
permanently remove the riskiest special nuclear material from its site. 
To conduct this work, GAO visited LLNL, reviewed numerous documents and 
plans, and interviewed LLNL and NNSA security officials. 

What GAO Found: 

DOE’s Office of Independent Oversight found numerous and wide-ranging 
security deficiencies with LLNL’s safeguards and security program. DOE 
gave the laboratory the lowest possible rating in two security areas: 
protective force performance and classified matter protection and 
control. The Office of Independent Oversight also reported that LLNL’s 
physical security systems, such as alarms and sensors, and its security 
program planning and assurance activities needed improvement.  

Weaknesses in LLNL’s self-assessment program and LSO’s oversight 
contributed to security deficiencies at the laboratory. LLNL’s security 
self-assessment program and LSO’s annual security survey failed to 
identify numerous security deficiencies before DOE’s Office of 
Independent Oversight conducted its inspection. According to one DOE 
official, both programs were “broken” and missed even the “low-hanging 
fruit” of compliance-oriented deficiencies. More specifically, LLNL’s 
self-assessment program should have identified the magnitude of 
technical problems with a key weapon system used at the laboratory. 
Furthermore, LSO’s September 2007 security survey gave LLNL 100-percent 
satisfactory ratings in its security performance—differing markedly 
from the security performance DOE observed during its inspection a 
short time later. To address these issues, LSO is implementing a new 
program to better train security officials to perform security 
assessments and recognize deficiencies; however, according to LSO 
officials, LSO does not have a specific budget to implement this new 
security training program. 

LLNL has developed corrective action plans to address the 54 security 
deficiencies identified by the Office of Independent Oversight, and 
both NNSA and DOE will oversee the plans’ implementation. As of 
December 2008, LLNL reported having completed 74 percent of the 
milestones included in corrective action plans to address physical 
security deficiencies. DOE plans to re-inspect LLNL in April 2009 and 
focus on the effectiveness of corrective actions. In the past, LLNL has 
not sustained corrective actions to address similar security 
deficiencies. For example, in 1999 DOE reported that LLNL’s capability 
to conduct vulnerability assessments was deficient. By 2000, this 
problem had been corrected. In 2008, DOE again noted deficiencies in 
LLNL’s vulnerability assessment capability. NNSA has the opportunity to 
use its new performance-based management and operating contract to hold 
LLNL’s contractor financially accountable for ensuring that security 
improvements resulting from corrective actions are sustained. 

The plan to remove most of LLNL’s special nuclear material by the end 
of fiscal year 2012 faces challenges because the plan’s schedule 
depends on a number of factors, some of which LLNL does not control, 
such as the willingness and ability of other NNSA and DOE sites to 
receive the material, the timeliness of the effort, adequate funding, 
and the availability of specialized transport trucks operated by NNSA’s 
Office of Secure Transportation to transfer material to other DOE 
sites. 

What GAO Recommends: 

GAO recommends that the Administrator of NNSA improve and sustain 
federal oversight of security at LLNL by (1) developing a detailed plan 
and budget for training NNSA’s Livermore Site Office (LSO) security 
staff and (2) providing financial incentives to LLNL’s contractor to 
sustain security improvements. NNSA generally agreed with the report’s 
findings and recommendations. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/products/GAO-09-321]. For more 
information, contact Gene Aloise at (202) 512-3841 or aloisee@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

DOE's Office of Independent Oversight Identified Several Significant 
Weaknesses in LLNL's Safeguards and Security Program: 

A Weak Laboratory Self-Assessment Program and Insufficient Federal 
Oversight Contributed to Security Deficiencies at LLNL: 

LLNL Has Developed Corrective Action Plans to Address 54 Identified 
Security Deficiencies, and Both NNSA and DOE Will Oversee Their 
Implementation: 

LLNL Faces Challenges in Implementing Plans to Complete De-inventory of 
Its Category I and II Special Nuclear Material by the End of Fiscal 
Year 2012: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Safeguards and Security Topics Covered in Office of 
Independent Oversight Inspections: 

Appendix II: Comments from the National Nuclear Security 
Administration: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: LLNL Security Deficiencies Identified by the Office of 
Independent Oversight, by Topical Area, April 2008: 

Table 2: LLNL's Required Protective Force Performance Assurance 
Testing: 

Figures: 

Figure 1: LLNL Corrective Action Milestones by Security Topic, as of 
December 2008: 

Figure 2: Timeline for the Development and Final Approval of LLNL's 
Corrective Action Plans: 

Abbreviations: 

DBT: design basis threat: 

DOE: Department of Energy: 

LLNL: Lawrence Livermore National Laboratory: 

LLNS: Lawrence Livermore National Security, LLC: 

LSO: Livermore Site Office: 

NNSA: National Nuclear Security Administration: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

March 16, 2009: 

The Honorable Henry A. Waxman: 
Chairman: 
The Honorable John D. Dingell: 
Chairman Emeritus: 
The Honorable Joe Barton: 
Ranking Member: 
Committee on Energy and Commerce: 
House of Representatives: 

The Honorable Bart Stupak: 
Chairman: 
The Honorable Greg Walden: 
Ranking Member: 
Subcommittee on Oversight and Investigations: 
Committee on Energy and Commerce: 
House of Representatives: 

The Department of Energy (DOE) has long recognized that a successful 
terrorist attack on a site containing nuclear weapons or the fissile 
material used in nuclear weapons--called special nuclear material-- 
could have devastating consequences for the site and its surrounding 
communities. Lawrence Livermore National Laboratory (LLNL), located in 
Livermore, California, is one of three national laboratories 
responsible for designing, developing, and maintaining a safe, secure, 
and reliable nuclear weapons deterrent.[Footnote 1] For these and other 
missions, LLNL stores and uses special nuclear material. Special 
nuclear material--including plutonium and highly enriched uranium--is 
considered to be Category I when it is weapons-grade and in specified 
forms and quantities. The risks associated with Category I special 
nuclear material vary but include theft, and the potential for sabotage 
in the form of radiological dispersal, also known as a "dirty bomb." 
Because of these risks and LLNL's location in California's densely 
populated San Francisco Bay area, NNSA decided in October 2007 to 
permanently remove, or "de-inventory," all Category I nuclear material 
from LLNL.[Footnote 2] 

LLNL is overseen by the National Nuclear Security Administration 
(NNSA), a separately organized agency within DOE. DOE's and NNSA's 
safeguards and security program develops policies essential for 
preventing an unacceptable, adverse impact on national security. To 
manage potential risks, DOE has developed a classified policy that 
identifies the potential size and capabilities of terrorist forces 
against which facilities containing Category I special nuclear 
material--which at LLNL is the "Superblock" facility--must be prepared 
to defend.[Footnote 3] Additionally, LLNL must adhere to other DOE 
security requirements on the effective protection of classified assets, 
such as documents, removable electronic media, and nuclear weapons 
components. LLNL documents its ability to meet these requirements 
through its Site Safeguards and Security Plan. 

On October 1, 2007, Lawrence Livermore National Security, LLC (LLNS) 
took over as the management and operating contractor of LLNL after more 
than 50 years of operation by the University of California.[Footnote 4] 
NNSA measures LLNL's performance and determines LLNS' management and 
operating incentive fee using annual performance evaluation plans that 
establish NNSA's priorities for LLNL and ensure that contract 
requirements--such as effective security performance--are met. 

To determine the overall effectiveness of LLNL's implementation of DOE 
and NNSA security requirements--including its protection strategy to 
meet the DBT--two organizations periodically conduct comprehensive 
reviews of LLNL's security performance. First, NNSA's Livermore Site 
Office (LSO)--the on-site, federal office responsible for ensuring the 
secure operation of LLNL facilities and for accepting certain security 
risks on NNSA's behalf--conducts an annual survey and issues a report 
based on survey results, observations of security performance, and 
compliance with DOE and NNSA security directives. This survey is a 
means for LSO to oversee the laboratory's security performance and is 
intended to ensure that the security risks NNSA accepts are both known 
and mitigated to the extent practicable. Second, the Office of 
Independent Oversight, within DOE's Office of Health, Safety and 
Security, performs comprehensive, periodic security inspections at LLNL 
and other sites. These inspections may include performance assurance 
tests, such as "force-on-force" exercises that evaluate the ability of 
LLNL's protective force to successfully defend the Superblock facility 
against a mock terrorist group simulating a potential attacking force. 
All deficiencies--"findings"--identified during surveys and independent 
inspections require LLNL to take corrective actions; both LSO and the 
Office of Independent Oversight track the implementation of these 
actions. In addition, both LSO and DOE review the self-assessments LLNL 
conducts of its own security performance. 

In April 2008, DOE's Office of Independent Oversight concluded a 
comprehensive inspection of security at LLNL. As a result of this 
inspection, LLNL earned the lowest possible rating--"Significant 
Weakness"--in two of seven security performance areas, including 
protective force performance. Two additional security performance areas 
were rated as "Needs Improvement." 

In this context, you asked us to (1) characterize the security 
deficiencies identified by DOE's Office of Independent Oversight in its 
April 2008 inspection; (2) determine the factors that contributed to 
the deficiencies DOE's Office of Independent Oversight identified in 
its inspection; (3) identify corrective actions LLNL is taking to 
address identified security deficiencies and how these actions are 
being overseen; and (4) assess LLNL's plan for permanently removing 
Category I and II special nuclear material from its Superblock 
facility. 

To address these questions, we visited LLNL and observed facilities 
included in the Office of Independent Oversight's inspection. We also 
reviewed applicable DOE safeguards and security policies, such as the 
DBT and DOE Manual 470-4.1, Safeguards and Security Program Planning 
and Management. Furthermore, we reviewed both the Office of Independent 
Oversight's inspection reports and LSO's security surveys of LLNL from 
1999 to the present and analyzed trends in security performance, with a 
focus on the four of seven security areas for which the Office of 
Independent Oversight provided overall ratings of less than effective 
performance in its 2008 inspection report. In addition, we analyzed 
LLNL's Site Safeguards and Security Plan for defending the site against 
the 2003 DBT as well as other key laboratory plans for ensuring that 
DOE security training and performance testing requirements are met. 
Furthermore, we reviewed LLNL's and LSO's interim and final corrective 
action plans to address security performance deficiencies identified by 
the Office of Independent Oversight. We also interviewed officials from 
DOE's Office of Health, Safety and Security; NNSA's offices of Defense 
Nuclear Security and of Nuclear Material Management Integration; LSO; 
and LLNL. 

We conducted this performance audit from July 2008 to March 2009 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: 

LLNL's inventory of special nuclear material consists predominantly of 
weapons-grade plutonium and highly enriched uranium. This inventory 
takes two forms: (1) metals, including weapons components and material 
machined into forms for use in weapons components; and (2) oxides and 
other compounds, such as salts. Some of LLNL's special nuclear material 
inventory has been determined to be "programmatic," or material that 
has been declared to be of national security value and that has an 
identified program use. Other special nuclear material in LLNL's 
inventory has been determined to be "excess," or material declared to 
be of national security value but that does not have an identified 
program use. Finally, LLNL's inventory includes waste material that 
does not have a national security value. 

In accordance with DOE Manual 470.4-1, Safeguards and Security Program 
Planning and Management, NNSA must develop a safeguards and security 
program that ensures NNSA has the necessary protections in place to 
protect its security interests against malevolent acts, such as theft, 
diversion, sabotage, modification, compromise, or unauthorized access 
to nuclear weapons, nuclear weapons components, special nuclear 
material, or classified information. The safeguards and security 
program integrates NNSA's physical security efforts by protective guard 
forces, information and personnel security systems, and nuclear 
material control and accountability systems. Contractors that manage 
and operate NNSA laboratories--including LLNS--are required to comply 
with DOE safeguards and security directives, as stated in their 
management and operating contracts. 

Because LLNL contains Category I and II special nuclear material, DOE 
Manual 470.4-1 requires that it prepare a Site Safeguards and Security 
Plan, a classified document that identifies known vulnerabilities, 
risks, and protection strategies for the site and formally acknowledges 
how much risk the contractor and DOE are willing to accept. The 
protection measures identified in LLNL's approved Site Safeguards and 
Security Plan are developed in response to site-specific vulnerability 
assessments and become the basis for executing and reviewing protection 
programs at the Superblock. LLNL must annually review its Site 
Safeguards and Security Plan to ensure that implementation of the plan 
will provide effective security protection. This review includes a 
validation of the protective strategy, accomplished in part through an 
annual force-on-force exercise, which exercises LLNL's protective force 
against a mock adversary group simulating a potential attacking force. 
Force-on-force exercises are conducted using plausible attack 
scenarios. In addition, DOE Manual 470.4-3, Protective Force, requires 
that LLNL conduct other performance assurance tests throughout each 
year, including quarterly performance assurance tests of a more limited 
scope than full force-on-force exercises. 

While most NNSA and DOE sites were required to meet DOE's 2005 DBT, 
[Footnote 5] LLNL has been declared "non-enduring" and is required to 
meet DOE's less-demanding 2003 DBT. Specifically, in a March 7, 2008, 
memorandum the Acting Deputy Secretary of Energy concurred with NNSA's 
October 2007 decision to declare LLNL a non-enduring Category I and II 
special nuclear material site because of plans to remove this material. 
[Footnote 6] Together with DOE, NNSA determined that the benefits of 
expediting the removal of Category I and II special nuclear material 
outweighed the risks associated with foregoing security upgrades, and 
funds that were to be spent on these upgrades were redirected to 
support the de-inventory of special nuclear material. In line with this 
decision, DOE also agreed with NNSA's decision to suspend planned 
security upgrades at LLNL's Superblock facility that would have brought 
LLNL's security posture to the level consistent with the larger 
adversary threat identified in DOE's 2005 DBT. However, DOE and NNSA 
are requiring LLNL to maintain a "denial-of-task" security strategy 
until de-inventory is complete. Under this strategy, any adversaries 
that gain hands-on access to special nuclear material must be 
neutralized. LLNL and NNSA documented the site's ability to meet the 
2003 DBT through their approvals of LLNL's Site Safeguards and Security 
Plan, which had been revised and approved in January 2007, and through 
a validation force-on-force exercise conducted in December 2006. 

To evaluate the effectiveness of sites' protection programs, DOE uses a 
three-stage evaluation model: laboratory self-assessment, federal site 
office security surveys, and Office of Independent Oversight 
inspections. In each stage of the evaluation model, the results of 
performance assurance tests are considered. All three stages are 
required to address laboratory safeguards and security programs 
comprehensively. More specifically: 

* LLNL's self-assessment program is intended to provide the opportunity 
to self-identify security performance strengths and to address 
weaknesses internally before they can be exploited by a potential 
adversary. When security vulnerabilities are self-identified, these 
become the basis for federal decisions about how to mitigate them and 
what level of risk to accept. DOE requires that LLNL complete specific 
numbers and types of performance assurance tests to inform its self- 
assessments and assure DOE and NNSA that safeguards and security 
interests are being protected at their required levels. 

* LSO security surveys are intended to confirm the availability and 
adequacy of safeguards and security programs, as implemented by LLNL. 
Surveys must be conducted annually and are based, in part, on direct 
observations of security performance, including compliance with DOE and 
NNSA security directives. LSO may also consider LLNL's security self- 
assessment as part of its annual survey as well as its performance 
assurance test results. To be comprehensive, LSO surveys cover eight 
topical areas and 33 subtopical areas and provide one of three ratings: 
satisfactory--the element being evaluated meets protection objectives 
or provides reasonable assurance that protection objectives are being 
met; marginal--the element being evaluated partially meets protection 
objectives or provides questionable assurance that protection 
objectives are being met; or unsatisfactory--the element being 
evaluated does not meet protection objectives or does not provide 
adequate assurance that protection objectives are being met. LSO may 
identify security deficiencies that are required to be addressed 
through corrective actions. 

* The inspections by DOE's Office of Independent Oversight evaluate 
LLNL's and LSO's security performance. To determine the adequacy of 
security policy and the implementation of those policies, the Office of 
Independent Oversight conducts its own performance assurance tests of 
key security systems, observes security performance, and conducts 
interviews. Inspections result in reports, which may identify 
deficiencies that must be addressed through corrective actions. To be 
comprehensive, Office of Independent Oversight inspections cover eight 
topical areas and 36 subtopical areas[Footnote 7] (see appendix I) and 
provide one of three ratings: effective performance--the system 
inspected provides reasonable assurance that the identified protection 
needs are met; needs improvement--the system inspected only partially 
meets identified protection needs or provides questionable assurance 
that the identified protection needs are met; or significant weakness--
the system inspected does not adequately assure that identified 
protection needs are met. 

DOE's Office of Independent Oversight Identified Several Significant 
Weaknesses in LLNL's Safeguards and Security Program: 

During the course of its April 2008 inspection, the Office of 
Independent Oversight found significant weaknesses in LLNL's protective 
forces' performance against the adversary threat identified in DOE's 
2003 DBT, particularly during force-on-force scenarios and in other 
types of performance assurance testing. Deficiencies identified in 
LLNL's protection program management contributed to the protective 
forces' poor performance. In addition, the office identified 
deficiencies in LLNL's classified matter protection and control 
programs, which are intended to provide protection against unauthorized 
disclosure of classified matter, as well as in LLNL's physical security 
systems. LLNL's security performance in two other security topical 
areas--material control and accountability, and personnel security--
[Footnote 8] was rated effective.[Footnote 9] Table 1 describes the 
Office of Independent Oversight's overall findings for LLNL. The office 
also identified 12 security deficiencies for LSO. 

Table 1: LLNL Security Deficiencies Identified by the Office of 
Independent Oversight, by Topical Area, April 2008: 

Topical area: Protective force; 
Number of findings: 13; 
Overall rating: Significant weakness. 

Topical area: Classified matter protection and control; 
Number of findings: 7; 
Overall rating: Significant weakness. 

Topical area: Physical security systems; 
Number of findings: 7; 
Overall rating: Needs improvement. 

Topical area: Protection program management; 
Number of findings: 7; 
Overall rating: Needs improvement. 

Topical area: Personnel security; 
Number of findings: 4; 
Overall rating: Effective performance. 

Topical area: Material control and accountability; 
Number of findings: 0; 
Overall rating: Effective performance. 

Source: Office of Independent Oversight. 

Note: The Office of Independent Oversight identified an additional 16 
security deficiency findings in cyber security that were outside the 
scope of our review. 

[End of table] 

LLNL's Protective Force Performed Poorly in an Exercise against the 
2003 DBT: 

Despite an approved Site Safeguards and Security Plan and performance 
tests that validated LLNL's ability to defend against the 2003 DBT, 
DOE's Office of Independent Oversight identified 13 specific 
deficiencies in LLNL's protective force's performance; these 
deficiencies resulted in an overall rating of significant weakness, the 
lowest rating possible. These deficiencies became most apparent during 
force-on-force exercises designed to evaluate tactical response 
capabilities associated with the protection of LLNL's special nuclear 
material inventory, as well as limited scope performance tests to 
determine skill levels associated with routine and emergency duties. 
Specifically, the Office of Independent Oversight found the following: 

* LLNL had not conducted an annual force-on-force exercise, as required 
by DOE Manual 470-4.3, Protective Force. Prior to the April 2008 
exercise conducted during the Office of Independent Oversight's 
inspection, LLNL had not conducted a full force-on-force exercise since 
December 2006, when LLNL validated the site's ability to meet the 
adversary threat postulated by the 2003 DBT. 

* Other quarterly performance assurance tests, also required by DOE 
Manual 470-4.1, were too limited in scope to meet performance testing 
requirements. In addition, not all required quarterly performance 
assurance tests were completed. 

* LLNL protective force members did not demonstrate proficiency in 
specific response capabilities, such as donning chemical masks in the 
required time. 

* Communication among protective force members was poor during the 
force-on-force exercise and did not facilitate rapid and effective 
response to alarms and adversary movements. 

* While protective force members performed well in individual 
qualification tests, the protective force did not demonstrate effective 
team tactics. 

* Protective force commanders did not demonstrate sufficient command 
and control capabilities during the force-on-force exercise to 
effectively direct tactical units. 

* Protective force members failed to respond to their fighting 
positions as required by LLNL's Security Incident Response Plan. 

* LLNL's mobile weapon platform--an armored vehicle that carries a 
mounted M-134D Dillon multi-barreled machine gun and that was 
identified in the laboratory's approved Site Safeguards and Security 
Plan as key to the site's security--failed to competently support the 
protection mission. Numerous technical problems were noted with the 
weapon system's operation, and officers were unable to perform 
operational tests of the weapon at the Superblock because of safety and 
security concerns. Furthermore, officers were not allowed to train with 
the weapon at LLNL's nearby training range because of environmental 
concerns. 

* LLNL experienced "controller errors" when those running the exercise 
failed to communicate critical information on simulated events--such as 
explosions--that might have affected the exercise's outcome. Office of 
Independent Oversight and LLNL officials agreed that errors of this 
nature can be attributed to a lack of practice in conducting force-on- 
force exercises. 

In several instances, LLNL security officials knew of the deficiencies 
identified by the Office of Independent Oversight before the April 2008 
inspection, but had not committed to corrective actions. For example, 
LLNL security officials were aware of some mechanical problems with the 
mobile weapon platform before April 2008. Officials said the full 
extent of the problems was not known because the platform had not been 
sufficiently tested in an operational environment. Officials explained 
that performance tests of the mobile weapon platform did not include 
tests of how effectively the weapon would function in different attack 
scenarios, but rather tested officers' response times for getting to 
the weapon and positioning it. Nevertheless, a review of LLNL's 
quarterly performance assurance testing reports to LSO shows that LLNL 
reported completing 100 percent of required performance tests on all 
essential protection strategy elements, including the mobile weapons 
platform. These reports do not include the results of the performance 
assurance tests; they only state that the tests were conducted. LLNL 
has since taken steps to improve the reliability of the mobile weapon 
platform, and a complete review of the electrical and mechanical 
systems is underway. Similarly, in 2006, LSO found that LLNL had not 
conducted its annually-required force-on-force exercise. There was an 
18-month gap between a June 2005 exercise at LLNL and the one conducted 
in December 2006 to validate LLNL's protection strategy against the 
2003 DBT. 

Deficiencies in LLNL's protection program management also contributed 
to the protective forces' poor performance. The Office of Independent 
Oversight found seven security deficiencies in the area of protection 
program management--LLNL's security program planning and assurance 
activities--and rated this security topic as needing improvement. The 
seven findings were focused on three areas of security planning and 
feedback: vulnerability assessment, self-assessment, and performance 
assurance testing. More specifically, the office found the following: 

* The evidence files to support the vulnerability assessments 
underpinning LLNL's Site Safeguards and Security Plan were incomplete 
and raised questions about the scope and methodology used to prepare 
vulnerability assessments. 

* LLNL's security self-assessment program was not comprehensive and 
individual assessments of security elements lacked the breadth and 
depth to provide management with information necessary to make 
meaningful decisions. 

* The list of essential security program elements LLNL had included in 
its performance assurance test plan was incomplete and the performance 
assurance tests did not always include measures that would test the 
effectiveness of these elements. 

DOE Concluded That LLNL's Protection and Control over Classified Matter 
Was Deficient: 

DOE Manual 470.4-4, Information Security, lays out the classified 
matter protection and control requirements that are intended to prevent 
the unauthorized disclosure of classified matter. Protection strategies 
include properly marking classified documents and media to make visible 
their classification level and other information; using security 
containers (or safes), vaults, and vault-type rooms for classified 
matter storage; having accountability systems that use unique 
identification numbers for controlling access to and movement of 
certain classified matter; and having access barriers, such as 
combination locks. Other physical security systems--such as alarms and 
sensors to detect unauthorized access to rooms storing classified 
matter--are considered separately during Office of Independent 
Oversight inspections. 

According to DOE officials, in the area of classified matter protection 
and control, none of the seven individual findings of security 
deficiencies would independently have resulted in a rating of 
significant weaknesses; however, in total, the deficiencies identified 
led officials to question the overall effectiveness of LLNL's 
classified matter protection and control program. More specifically, 
the Office of Independent Oversight found the following classified 
matter protection and control deficiencies: 

* LLNL failed to comply with basic security requirements, such as the 
frequency of changes to safe combinations when individuals' needs for 
access to safes have changed; repeated errors in classified document 
marking; weaknesses in the timely completion of classification reviews 
for working papers; and errors in location records for all safes 
containing classified matter. 

* Individual LLNL directorates' policies for storing accountable 
classified removable electronic media after hours were inconsistent and 
conflicted with DOE requirements. 

DOE Identified Additional Areas of LLNL's Security Program That Needed 
Improvement: 

The Office of Independent Oversight also reported that LLNL's physical 
security systems needed improvement. The office identified seven 
security deficiencies, including the adequacy of the alarm systems' 
redundancy; the quality of lighting for, and images from, closed 
circuit television monitoring systems; the extent to which protective 
force posts needed repairs; and the protection strategy for security 
keys. Two of the office's findings involved the security of vault-type 
rooms in which classified matter is stored. 

The personnel security and material control and accountability security 
areas received effective performance ratings from the Office of 
Independent Oversight in April 2008. However, four security 
deficiencies were found in the personnel security area. All four 
related to aspects of LLNL's Human Reliability Program, a program 
designed to ensure that individuals who occupy positions affording 
access to special nuclear and explosive materials meet the highest 
standards of reliability and physical and mental suitability. 

A Weak Laboratory Self-Assessment Program and Insufficient Federal 
Oversight Contributed to Security Deficiencies at LLNL: 

Neither LLNL's security self-assessment program nor LSO's annual 
security survey identified the security performance deficiencies that 
DOE's Office of Independent Oversight found. According to one DOE 
official, both programs were "broken" and missed even the "low-hanging 
fruit" of compliance-oriented deficiencies that LLNL must now take 
actions to correct. More specifically, LLNL's self-assessment program 
did not identify security deficiencies in the laboratory's classified 
matter protection and control program or the performance assurance 
program established to test the operability and effectiveness of 
elements essential to LLNL's protective strategy. Furthermore, LSO's 
September 2007 annual security survey, completed only 6 months before 
the Office of Independent Oversight's inspection, resulted in 100- 
percent satisfactory ratings for the laboratory's security performance. 
The Office of Independent Oversight found LSO's survey program was not 
comprehensive, and LSO security officials said site office employees 
who conduct surveys need more subject matter training. 

LLNL's Self-Assessment Program Did Not Identify the Security 
Deficiencies Identified by DOE's Office of Independent Oversight: 

DOE's safeguards and security orders require that self-assessments 
comprehensively cover all topical and subtopical areas in order to 
assure the adequacy and effectiveness of security programs and their 
implementation. However, LLNL's self-assessment program failed to 
identify the security deficiencies identified by DOE's Office of 
Independent Oversight because the program (1) was not comprehensively 
implemented and (2) not supported by an effective performance assurance 
testing regime. In terms of implementation, the office reported that 
LLNL's and LSO's collaborative approach to selecting high-priority 
security topical areas for self-assessment each year benefited the self-
assessment program by making efficient use of limited resources; 
however, it also reported that several subtopic areas were not 
evaluated annually as required. Specifically: 

* There had not been a comprehensive, site-wide assessment of safes 
containing classified matter for 3 years. 

* LLNL's self-assessments were not broad and deep enough to provide 
laboratory management with sufficient information to make meaningful 
decisions about security performance. For example, self-assessments 
completed in fiscal year 2007 did not describe the evaluation criteria 
used to perform the assessments. 

DOE requires that all essential elements of a site's protection program 
be subject to performance testing to provide comprehensive assurance 
that the required levels of protection are met. Essential elements 
include the equipment (such as weapon systems), procedures (such as 
security incident response plans), and personnel (such as security 
police officers) components of LLNL's safeguards and security program. 
The failure of any of these components would reduce protection of 
departmental property to an unacceptable level. Each site, including 
LLNL, is required to develop a Performance Assurance Program Plan that 
describes the program and its implementation by identifying elements 
essential to the protection of Category I and II special nuclear 
material and Top Secret classified matter. The results of required 
performance assurance tests should contribute to the security topic 
self-assessments. 

We reviewed LLNL's quarterly reports to LSO on the laboratory's 
performance assurance testing activities for fiscal year 2007 and the 
first half of fiscal year 2008. With the exception of the first quarter 
of fiscal year 2007, these reports show the performance testing 
requirements were met or exceeded. However, the Office of Independent 
Oversight's inspection revealed multiple deficiencies in the design and 
implementation of LLNL's performance assurance testing program. 
Specifically, the office found that (1) the individual test plans LLNL 
developed for essential protection elements did not always measure the 
effective performance of these elements; (2) not all essential elements 
were included in LLNL's performance assurance testing program; and (3) 
LLNL did not perform annual force-on-force exercises or quarterly 
integrated performance tests as required. The September 2007 LSO 
security survey also found that LLNL did not perform some performance 
assurance tests with the required frequency. Table 2 provides 
information on LLNL's required protective force performance assurance 
tests and deficiencies identified by the Office of Independent 
Oversight and LSO. 

Table 2: LLNL's Required Protective Force Performance Assurance 
Testing: 

Type of test: Limited Scope Performance Tests; 
Description: Scheduled or unscheduled limited scope performance tests 
of individuals or teams test any operation, procedure, skill, or task 
performance that falls within the scope of protective force 
responsibility. Examples of these tests include individual and team 
tactical movement, arrest and control techniques, building clearing, 
command and control activities, and implementation of protection 
strategies; 
Minimum performance test frequency: Weekly at Category I/II special 
nuclear material facilities; all other facilities as required depending 
on security protection levels; 
Office of Independent Oversight and LSO findings: The Office of 
Independent Oversight found that LLNL's protective force lacked a 
specific protection capability that should have been demonstrated in 
limited scope performance tests. Further, technical problems with the 
mobile weapon platform should have been identified to a greater extent 
during limited scope performance tests. Finally, some limited scope 
performance tests did not effectively measure the performance of the 
security elements being tested. 

Type of test: Alarm Response and Assessment Performance Tests; 
Description: Unscheduled tests based on simulated adversary actions 
consistent with the DBT to evaluate protective force response to a 
specific location under alarm protection and readiness to alarm 
conditions; 
Minimum performance test frequency: Twice per quarter at Category I/II 
special nuclear material facilities and other alarmed special nuclear 
material facilities; once per quarter at all other locations; 
Office of Independent Oversight and LSO findings: The LSO survey 
reported that LLNL failed to assure that the required number of alarm 
response and assessment performance tests were conducted; The Office of 
Independent Oversight noted LSO's finding in its report. 

Type of test: Validation Force-on-Force Exercises; 
Description: Major tests of all elements involved in response to a DBT 
and site-specific threats that is used to validate site-specific 
protection strategies; 
Minimum performance test frequency: Once per year per facility for all 
sites with armed protective force; 
Office of Independent Oversight and LSO findings: The Office of 
Independent Oversight reported that LLNL protective force management 
had not conducted a validation force-on-force exercise in calendar year 
2007. 

Type of test: Command Post Exercises; 
Description: Scheduled or unscheduled exercises conducted to observe 
and evaluate crisis teams' overall handling of simulated safeguards 
and/or security or a natural disaster incident. Lines of authority, 
timeliness of reporting and decision-making, and facility and equipment 
availability must be included; 
Minimum performance test frequency: Twice per year at Category I/II 
special nuclear material facilities, and once per year at all other 
facilities; 
Office of Independent Oversight and LSO findings: Not discussed. 

Type of test: Command Field Exercises; 
Description: Extensions of Command Post Exercises, these exercises test 
the interaction among various support organizations, site management, 
and the protective force to a simulated event. Exercises focus on 
procedures, tactical intelligence, communications, logistics, and the 
interfaces between federal and contractor support systems; 
Minimum performance test frequency: Twice per year at Category I/II 
special nuclear material facilities, and once per year at all other 
facilities; 
Office of Independent Oversight and LSO findings: Not discussed. 

Type of test: Joint Training Exercises; 
Description: Exercises conducted with outside agencies that support the 
successful mitigation of a security incident; 
Minimum performance test frequency: At least once per year and 
consistent with requirements of the Site Safeguards and Security Plan; 
Office of Independent Oversight and LSO findings: Not discussed. 

Type of test: Integrated Performance Tests; 
Description: Scheduled tests encompassing all essential protection 
elements associated with a comprehensive site or facility threat 
scenario conducted to evaluate the overall facility safeguards and 
security effectiveness; 
Minimum performance test frequency: Category I facilities requiring 
denial protection strategies under the DBT (such as LLNL's Superblock) 
must conduct Integrated Performance Tests on a quarterly basis; 
Office of Independent Oversight and LSO findings: The Office of 
Independent Oversight reported that there was no evidence that LLNL's 
protective force had conducted quarterly integrated performance tests 
as required. 

Type of test: Training Exercises; 
Description: Exercises involving each protective force shift are site-
specific to the protective force in preventing the success of potential 
adversarial acts defined in the DBT; 
Minimum performance test frequency: Monthly; 
Office of Independent Oversight and LSO findings: Not discussed. 

Sources: GAO analysis of DOE Manual 470.4-3, Protective Force; DOE 
Manual 470-4.1, Safeguards and Security Program Planning and 
Management; Lawrence Livermore National Laboratory, Safeguards and 
Security Organization Performance Testing and Assurance Program Plan, 
September 21, 2006; Department of Energy, Office of Health, Safety, and 
Security, Volume I: Independent Oversight Safeguards and Security 
Inspection of the Livermore Site Office and the Lawrence Livermore 
National Laboratory, June 26, 2008; and National Nuclear Security 
Administration, Livermore Site Office, Periodic Safeguards and Security 
Survey of Lawrence Livermore National Laboratory (LLNL) October 2, 
2006, through September 28, 2007. 

[End of table] 

Had LLNL's self-assessment program been implemented comprehensively, 
with the required breadth and depth, and used performance assurance 
testing in addition to compliance-based reviews, security deficiencies 
identified by the Office of Independent Oversight might have been self- 
identified and corrected internally. This is particularly true with 
respect to deficiencies in the operation of the mobile weapon platform 
and protective force performance in command and control, 
communications, and team tactics. Significantly, the one area of LLNL 
security performance where the Office of Independent Oversight 
identified no security findings was nuclear material control and 
accountability. According to DOE and LLNL officials, the self- 
assessment program for nuclear material control and accountability 
provides assurance that all elements are evaluated. In addition, 
appropriate performance testing is conducted in this area. Since the 
April 2008 force-on-force exercise, LLNL has conducted four full-scale 
exercises--two each in August and November 2008--during which 
protective force performance was successful. In addition, limited scope 
performance tests continue to be conducted to ensure readiness and 
knowledge of LLNL's Security Incident Response Plan. Furthermore, since 
April 2008 LLNL has conducted quarterly force-on-force exercises, which 
the laboratory believes fulfills the requirement to conduct quarterly 
integrated performance tests. According to a LLNL security official, 
LSO and LLNL disagree as to whether conducting quarterly force-on-force 
exercises meets the requirement to conduct quarterly integrated 
performance tests. The official said LLNL and LSO are working to 
resolve the disagreement. 

LSO's Annual Security Survey Did Not Identify Deficiencies DOE Reported 
in 2008: 

LSO completed an annual survey of LLNL's security performance in 
September 2007, 6 months before the Office of Independent Oversight 
inspected LLNL in April 2008. The survey consisted of a year-long 
process during which LSO staff conducted assessments, walk-throughs, 
and observations to gather data on different security programs. As a 
result of this survey, LLNL received 100-percent satisfactory ratings 
in its security performance--differing markedly from the security 
performance DOE observed during its inspection a short time later. In 
particular, LSO's survey report noted as strengths that LLNL's self- 
assessment program was supported by laboratory management and that LLNL 
had succeeded in sustaining a protection strategy consistent with the 
2003 DBT, assertions the Office of Independent Oversight inspection 
called into question. The LSO survey did result in six findings of 
security deficiencies: one for protective force, two for physical 
security systems, two for cyber security, and one for nuclear material 
control and accountability. For example, with respect to protective 
forces, LSO found that LLNL could not assure that it had conducted the 
necessary number of alarm response and assessment performance tests 
during the survey period. With respect to physical security, LSO found 
that LLNL did not adequately implement DOE requirements prohibiting 
employees from bringing personal laptop computers into secure locations 
and did not adequately implement a key management system. 

The Office of Independent Oversight also includes a review of site 
offices' survey programs when it conducts its inspection of the 
protection program management security topic. In its April 2008 review, 
the office found LSO's survey program was deficient in several areas. 
Specifically, the office found that the LSO security survey: 

* Was not comprehensive, as required by DOE Manual 470.4-1. LSO staff 
did not consistently follow the assessment schedule, did not prepare 
adequate assessment plans, and did not retain evidence files of 
individual survey activities. It also did not provide enough data to 
assure that survey reports comply with DOE requirements to characterize 
the impact associated with observed deficiencies. 

* Did not consistently assure that security deficiencies were 
identified or that identified deficiencies resulted in findings that 
would require corrective action. For example, the office noted that 
survey narratives pertaining to the physical security systems area 
identified several deficiencies; however, the survey program did not 
assign findings to these deficiencies, and the survey report did not 
describe LLNL's compensatory measures, as required. 

* Resulted in a satisfactory rating for LLNL's self-assessment program 
without conducting the activities necessary to determine that the 
program was comprehensive. 

* Used reviews of the contractor's records and the contractor's 
implementation of the performance assurance program to determine the 
status of compliance and performance of protective force duties, rather 
than conducting independent performance assessments of LLNL's 
protective force. 

LSO security officials told us they are redesigning their security 
survey program in response to these findings. Rather than aggregating 
LSO security staffs' observations made over the course of a year, 
security at LLNL will be comprehensively surveyed during two set 
periods each year. These survey periods will be supplemented by 
continuous observation throughout the year. Surveys will continue to 
review compliance with DOE orders and requirements, but will also 
increase focus on assessing the extent to which security performance is 
effective. In addition, LSO is creating a security training program to 
ensure that all LSO officials who participate in the security survey 
program cover the different security topics comprehensively and are 
expert enough to recognize and report on deficiencies. According to LSO 
officials, site office employees have been responsible for identifying 
their own training needs and have had independence in determining how 
they met training requirements. Little formal training was provided on 
how to conduct security surveys. Rather, training was received on the 
job and through what one official described as an "oral tradition" of 
how to perform oversight activities. The new training program is 
designed around DOE security standards, and LSO officials said the 
majority of the training will be provided by DOE's National Training 
Center. The program is intended to ensure that LSO security staff 
members are adequately trained to fulfill their duties and 
responsibilities. LSO's goal is to have all security staff qualified 
through this program by 2010. Underpinning this new training program is 
what LSO security officials described as a "cultural shift"--an effort 
to rely less on contractor assurance of security performance and more 
on independent, federal expertise to test and recognize that 
performance. However, according to LSO officials, LSO does not have a 
specific budget to implement this new security training program. 
[Footnote 10] 

LLNL Has Developed Corrective Action Plans to Address 54 Identified 
Security Deficiencies, and Both NNSA and DOE Will Oversee Their 
Implementation: 

LLNL has developed corrective actions to address the security 
deficiencies identified by the Office of Independent Oversight. LSO and 
DOE will oversee the implementation of these corrective actions, and 
NNSA will judge whether implementation was successful when it 
determines LLNS' contract award fee at the end of fiscal year 2009. 
While LLNL's corrective actions put the laboratory on a path toward 
improved security performance, LLNL has not sustained corrective 
actions intended to address security deficiencies identified in 1999 
and 2002 that are similar to those identified by the Office of 
Independent Oversight in 2008. 

Corrective Action Plans Are Intended to Address 54 Identified Security 
Deficiencies: 

LLNL has developed corrective action plans to address 54 security 
deficiencies identified by the Office of Independent Oversight. 
[Footnote 11] These plans include a total of 257 individual milestones, 
185 of which are associated with the 4 security areas DOE rated as 
either having significant weaknesses or needing improvement. Corrective 
action plans associated with physical security deficiencies were made 
final between September and November, 2008. LLNL has reported that it 
will complete implementation of physical security milestones by October 
30, 2009. As of December 2008, LLNL reported having completed 136 of 
the 185 milestones, or about 74 percent (see figure 1). 

Figure 1: LLNL Corrective Action Milestones by Security Topic, as of 
December 2008: 

[Refer to PDF for image: stacked vertical bar graph] 

Security topic: Classified Matter Protection and Control; 
Completed milestones: 23; 
Remaining milestones: 8; 
Total milestones: 31. 

Security topic: Physical Security Systems; 
Completed milestones: 29; 
Remaining milestones: 9; 
Total milestones: 38. 

Security topic: Protective Force; 
Completed milestones: 60; 
Remaining milestones: 20; 
Total milestones: 80. 

Security topic: Protection Program Management; 
Completed milestones: 24; 
Remaining milestones: 12; 
Total milestones: 36. 

Source: GAO analysis of LLNL corrective action plans and milestone 
completion reports. 

[End of figure] 

In compliance with DOE Manual 470.4-1, Safeguards and Security Program 
Planning and Management, each corrective action plan includes a root 
cause analysis, risk assessment, and cost-benefit analysis, where 
appropriate. To complete root cause analyses, LLNL used a DOE-agreed 
upon methodology and assigned root causes as directed by agency 
guidance. Of the 54 findings, LLNL determined that 29 had a single root 
cause, 18 had 2 root causes, 2 had 3 root causes, and 5 had 4 or more 
root causes. LLNL identified five recurring causes and issues as a 
result of its root cause analysis, including: 

* Resource allocation. LLNL identified resource allocation as the 
single largest root cause of the security deficiencies. According to 
the Office of Independent Oversight, LLNL had sufficient financial and 
human resources to meet applicable protection requirements. However, 
LLNL and LSO officials believe that LLNL could not fully fund all 
security program activities within available security budgets. Instead, 
LLNL allocated security resources on the basis of a broad set of 
priorities, management decisions, and budget constraints, which 
resulted in unfunded security activities and accepted risks. By 
identifying resource allocation as a root cause of the security 
deficiencies, LLNL determined that security deficiencies might have 
been avoided if resources had been allocated differently. 

* Work/organization planning. In several cases, an activity or project 
was poorly planned or deviated from its plan because of time or budget 
constraints. In addition, some projects did not follow good project 
management practices or did not include contingency plans. For example, 
the Office of Independent Oversight found that a protective force 
armorer assigned to maintain weapons had not completed DOE's 
recertification requirements. LLNL determined that armorer 
recertification planning could be improved by adding this requirement 
to a training database. 

* Policies and procedures. In several instances, policies or procedures 
were not followed, and DOE orders and requirements were unclear or were 
interpreted differently from the Office of Independent Oversight's 
interpretation. For example, the Office of Independent Oversight found 
that LLNL did not follow DOE's requirement to conduct weekly 
inventories for all hard drives containing classified nuclear weapons 
design information. LLNL had interpreted DOE's requirement differently 
and did not conduct weekly inventories for hard drives that had been 
demagnetized, which makes the information stored on them unreadable. 

* Training. In several cases, training content did not adequately cover 
all requirements. In addition, LLNL reported that a lack of practical, 
hands-on experience--performance testing--was a contributing factor in 
many areas of protective force deficiencies. NNSA headquarters security 
officials told us that the lack of training was the main cause for the 
protective force's performance during the April 2008 force-on-force 
exercise. 

LLNL, LSO, and DOE officials agreed on other factors that contributed 
to the laboratory's overall security performance. First, the change in 
management and operating contractor from the University of California 
to LLNS in October 2007 contributed to a loss of focus on security 
performance. According to LLNL security officials, during the period of 
contract transition, employees' focus was on ensuring safety as well as 
on potential impacts on employee pensions. In addition, the contract 
transition contributed to a delay in conducting LLNL's required annual 
force-on-force exercise. Second, DOE's and NNSA's determination to 
declare LLNL a non-enduring site for Category I and II special nuclear 
material affected the morale of laboratory employees. LLNL security 
officials said highly experienced employees left the laboratory as a 
result of this declaration. Finally, successive changes to DOE's DBT 
policy between 2003 and 2005 affected the analytical process that 
underpins security planning. In particular, LLNL security officials 
said the laboratory faced challenges in completing necessary 
vulnerability assessments. 

To complete corrective action plans' risk assessments, LLNL security 
officials evaluated the worst-case scenario presented by individual 
findings of security deficiencies relative to a set of seven risk 
areas: mission success, cost, schedule, health and safety, environment, 
safeguards and security, and political and public trust. Ultimately, 
each finding was assigned a single, overall risk level: negligible 
risk, low risk, moderate risk, or high risk. According to LLNL's 
analysis, 43 percent of the findings were determined to be of 
negligible risk, and 57 percent were determined to be of low risk. LLNL 
officials said the low risk ratings associated with each of these 
findings is associated with the relatively low likelihood of a worst 
case scenario ever occurring, as well as the level of redundancy that 
exists for security systems. In contrast to LLNL's risk assessment 
methodology, the Office of Independent Oversight based its security 
ratings on evaluations of management system performance. 

The vast majority of the physical security corrective actions LLNL has 
planned can be completed using existing funding, according to the 
laboratory's plans. The complexity of these corrective actions and the 
costs associated with their implementation range from relatively simple 
and inexpensive to complex and expensive. For example, to correct one 
classified matter protection and control deficiency concerning policies 
for handling accountable classified removable electronic media after 
regular laboratory hours, LLNL plans to develop a new policy and 
conduct a series of briefings on how to implement the policy. 
Milestones associated with completing these corrective actions are 
straightforward and can be completed with existing funds. 

In contrast, to address the finding that LLNL's protective force had 
not conducted quarterly integrated performance assurance tests of 
sufficient scope, LLNL plans to redesign its performance assurance 
testing program and has already begun to conduct larger, more frequent 
protective force exercises. According to LLNL and NNSA security 
officials, conducting additional performance assurance training has 
resulted in a 30-percent overtime increase for the protective force and 
a $5.5 million budget shortfall in fiscal year 2009 to address findings 
and sustain this level of activity. According to NNSA, after an 
examination of security priorities and tradeoffs, the Office of Defense 
Nuclear Security provided LLNL with additional funding to cover this 
shortfall. 

NNSA and DOE Plan to Oversee Implementation of Corrective Actions: 

LSO and the Office of Independent Oversight have overseen the 
development of LLNL's corrective action plans, and the completion of 
these plans has been an iterative process (see fig. 2). While the 
process was ongoing, LLNL took steps to complete milestones that would 
be included in final corrective action plans. 

Figure 2: Timeline for the Development and Final Approval of LLNL's 
Corrective Action Plans: 

[Refer to PDF for image: timeline illustration] 

April 15, 2008 – April 24, 2008: Office of Independent Oversight 
conducts inspection. 

July 8, 2008: Office of Independent Oversight inspection report 
finalized. 

July 15, 2008: LLNL sends interim corrective action plans to LSO. 

July 28, 2008: LSO sends comments on interim corrective action plans to 
LLNL and the Office of Independent Oversight. 

September 2, 2008: Office of Independent Oversight sends additional 
comments on interim corrective action plans to LLNL. 

September 10, 2008: LLNL sends revised corrective action plans to LSO. 

October 10, 2008: LSO approves all but 8 corrective action plans. 

October 22, 2008: LLNL sends LSO revisions to the 8 unapproved 
corrective action plans. 

November 13, 2008: LSO approves the remaining 8 corrective action 
plans. 

December 15, 2008: The Office of Independent Oversight provides 
concurrence with LSO’s approvals for physical security corrective 
action plans. 

Source: GAO analysis of LLNL, LSO, and Office of Independent Oversight 
corrective action plan documentation. 

[End of figure] 

LSO officials said they plan to meet with LLNL officials every month to 
review the status of the corrective actions. LSO is required to 
describe the overall implementation status of corrective action plans 
and the extent to which these actions are effective in its annual 
security survey reports. In addition, the Office of Independent 
Oversight has scheduled a follow-up security inspection of LLNL for 
April 2009 that will include a force-on-force exercise. Office of 
Independent Oversight officials told us the inspection will also 
include a review of progress on corrective actions associated with the 
four security areas that received less than satisfactory ratings in 
2008. 

In keeping with the requirements of the National Defense Authorization 
Act for Fiscal Year 2000 which created NNSA,[Footnote 12] NNSA's Office 
of Defense Nuclear Security has provided significant assistance to LLNL 
and LSO to help address identified security deficiencies. Office of 
Defense Nuclear Security officials have worked directly with LLNL to 
develop a recovery plan to improve the effectiveness of LLNL's 
protection strategy. In addition, Office of Defense Nuclear Security 
officials have assisted LLNL in identifying corrective actions, and 
have provided assistance in implementing these corrective actions 
effectively. For example, officials from the Office of Defense Nuclear 
Security observed force-on-force exercises conducted at LLNL in August 
and November 2008 and provided feedback. In addition, to help LSO 
better integrate its security activities and improve security 
oversight, the Office of Defense Nuclear Security temporarily augmented 
LSO's security staff with assistance teams of security experts from 
other NNSA site offices and from NNSA headquarters. These assistance 
teams provided independent technical reviews of revisions to LLNL's 
vulnerability assessment documentation, protection strategy, training 
and testing procedures, and Site Safeguards and Security Plan, as well 
as support in resolving issues associated with classified matter 
protection. 

NNSA will ultimately judge the success of LLNL's corrective action 
implementation when it determines a contract award fee at the end of 
fiscal year 2009.[Footnote 13] In fiscal year 2008--LLNL's first year 
of contract performance evaluated under the new performance-based 
contract with LLNS--LLNS earned approximately $17.2 million, or 54 
percent of the total "at-risk" incentive fee available under the 
contract.[Footnote 14] This amount included $1.3 million, or just 9 
percent, of the total incentive fee available for safe and secure 
operations. NNSA identified the results of the Office of Independent 
Oversight's inspection and the significant issues in LLNL's physical 
and information security programs as concerns that contributed to the 
low award fee determination in this area. In particular, NNSA noted in 
its performance evaluation report for LLNL that considerable management 
attention from LLNS, NNSA, and DOE leadership was required to assure 
that the laboratory could meet protection requirements for special 
nuclear material. Furthermore, NNSA reported that LLNL failed to submit 
a security self-assessment report for fiscal year 2008, despite the 
Office of Independent Oversight's findings on the laboratory's self-
assessment program. 

LLNL Has Not Sustained Corrective Actions That Addressed Past Security 
Deficiencies: 

In its June 1999 and April 2002 inspections of security performance at 
LLNL, the Office of Independent Oversight identified weaknesses in 
LLNL's protection program management and protective force performance, 
as well as numerous deficiencies in its classified matter protection 
and control program. LLNL implemented corrective actions, and the 
Office of Independent Oversight later rated LLNL's performance as 
effective in these areas. However, LLNL did not sustain the corrective 
actions. Specifically: 

* In 1999, the Office of Independent Oversight reported that LLNL's 
capability to conduct the vulnerability assessments that underpin 
protection program planning was deficient. By 2000, LLNL had corrected 
this problem, and in a follow-up inspection the office called LLNL's 
vulnerability assessment program a model for the rest of the nuclear 
weapons complex. In its 2008 inspection, however, the Office of 
Independent Oversight again reported several deficiencies in the area 
of vulnerability assessment. 

* In 2002, the office found weaknesses in protective force training and 
command and control. These weaknesses appear to have been addressed by 
the time of the 2006 force-on-force exercise, when Office of 
Independent Oversight officials said LLNL's protective force performed 
well. In its 2008 inspection, however, the office again found 
significant weaknesses in protective force training and command and 
control. 

* In its 1999 inspection the office gave LLNL's classified matter 
protection and control program the lowest possible rating, but the 
office rated LLNL's program as satisfactory in a follow-up inspection 6 
months later. Though some findings were reported in the interim, 
overall satisfactory ratings were maintained for classified matter 
protection and control until the Office of Independent Oversight's 2008 
inspection. 

According to officials in NNSA's Office of Defense Nuclear Security, it 
will be challenging to sustain the security improvements that result 
from LLNL's successful implementation of corrective actions because of 
the laboratory's non-enduring status and the drawdown in security 
resources that will come as special nuclear material de-inventory 
activities are completed. Officials said that NNSA must provide 
incentives to ensure that LLNL's protective force can sustain the 
appropriate levels of protection until de-inventory is complete. 
According to a senior LSO official, sustaining attention on security 
performance could be difficult as NNSA priorities shift and future Site 
Office management weighs NNSA priorities. LLNL has taken steps to 
ensure a sufficient number of protective force members will remain 
employed by the laboratory to protect Category I and II special nuclear 
material throughout the de-inventory process as currently scheduled. A 
new collective bargaining agreement with LLNL's protective force union, 
concluded in December 2008, expires at the end of fiscal year 2012. The 
agreement includes annual, additional lump sum payments of up to 
$50,000 over 3 years to protective force members who remain at LLNL 
during the de-inventory process. 

LLNL Faces Challenges in Implementing Plans to Complete De-inventory of 
Its Category I and II Special Nuclear Material by the End of Fiscal 
Year 2012: 

When DOE concurred with NNSA's decision to remove Category I and II 
special nuclear material from LLNL, the de-inventory process was 
expected to be completed no later than the end of fiscal year 2014. 
According to officials from NNSA's Office of Nuclear Material 
Management Integration, NNSA decided to accelerate this schedule and 
complete de-inventory by the end of fiscal year 2012 as part of its 
efforts to transform the nuclear weapons complex. LLNL has completed a 
detailed schedule and associated resource-loaded project management 
documentation in support of the 2012 de-inventory date. NNSA officials 
said this accelerated schedule does not include any contingency funds 
set aside for risks within the project scope; however, LLNL officials 
said the schedule is aggressive but realistic. As of August 2008, LLNL 
had already decreased its inventory of Category I and II special 
nuclear material by approximately 33 percent from the laboratory's 
fiscal year 2006 inventory. 

In order to de-inventory most of its special nuclear material, LLNL 
must stabilize the material and package it according to DOE standards 
for shipment to a receiving site.[Footnote 15] The stabilization 
process uses special equipment, such as furnaces and gloveboxes, to 
remove impurities. The material packages are containers approved for 
use in transporting Category I and II special nuclear material to 
storage and other disposition sites. Given these requirements, it takes 
time to prepare packages for shipment. For example, according to LLNL 
it takes approximately 2 months to prepare each package of plutonium 
oxide for shipment. LLNL plans to ship over 250 packages of special 
nuclear material to sites around the nuclear weapons complex to 
complete the de-inventory, including Los Alamos National Laboratory; 
the Nevada Test Site; the Savannah River Site in Aiken, South Carolina; 
the Y-12 National Security Complex in Oak Ridge, Tennessee; the Idaho 
National Laboratory near Idaho Falls, Idaho; and the Waste Isolation 
Pilot Plant, in Carlsbad, New Mexico. Each of these sites has 
particular safety requirements in place that govern the types and 
amounts of material they can receive. For example, according to NNSA 
officials, the Savannah River Site can only receive material excess to 
programmatic needs. Similarly, the Waste Isolation Pilot Plant can only 
receive certain waste material. Work to stabilize and package LLNL's 
special nuclear material inventory is being conducted at Superblock 
while programmatic operations are ongoing. 

The plan to de-inventory LLNL's Category I and II special nuclear 
material by the end of fiscal year 2012 is challenging because 
executing it depends on a number of factors, some of which LLNL does 
not control. Specifically: 

* The willingness and ability of other NNSA and DOE sites to receive 
the material. NNSA officials said work stoppages at receiving sites 
could delay shipments, as could disputes over the terms of receiving 
special nuclear material. NNSA's Office of Nuclear Material Management 
Integration, an office NNSA created in July 2008 to coordinate the 
consolidation of special nuclear material among DOE sites, is helping 
to anticipate material acceptance issues by conducting monthly video 
conferences with LLNL and receiving sites. 

* The Superblock facility will be operational nearly 100 percent of the 
time through fiscal year 2012. According to NNSA officials, there is 
always a chance of a work stoppage in Superblock. At least one lengthy, 
safety-related work stoppage at Superblock occurred in the recent past 
and lasted approximately 16 months, from January 2005 to May 2006, 
until operations fully resumed. 

* Timely and adequate funding. LLNL estimates the entire de-inventory 
process will cost $41.3 million over 5 years (fiscal years 2008 through 
2012). This estimate does not include inflation or contingency funding. 

* The availability of specialized shipping packages and transport 
trucks consistent with the de-inventory schedule. All sites within the 
nuclear weapons complex use the same shipping packages and rely on 
NNSA's Office of Secure Transportation to safely and securely move 
special nuclear material. The current de-inventory schedule plans to 
have completed packaging and shipment of 90 percent of the inventory by 
March 2011. The final 10 percent of the material, the most difficult to 
process, will take the remaining 18 months. Any change in the 
availability of packages or transport trucks could affect the de- 
inventory schedule. 

* The availability of skilled staff and fissile materials handlers. 
According to a LLNL official, a limited number of people are qualified 
to use the equipment at LLNL necessary to stabilize and package special 
nuclear material, and the number of skilled staff may diminish as the 
laboratory's special nuclear material inventory diminishes. 

* The on-time procurement, installation, and startup of additional 
equipment. In order to meet the accelerated 2012 schedule, LLNL is 
procuring and installing additional equipment to add capabilities 
specific to the stabilization processes for certain metals and oxides. 
The last of these capabilities is expected to come on line in June 
2009. A delay could potentially affect the de-inventory schedule. 

According to LLNL and NNSA officials, there are not any feasible 
options that would allow substantial acceleration of the de-inventory 
schedule. We agree with this assessment. LLNL explored three options 
for further schedule acceleration. First, LLNL assessed the extent to 
which increasing its processing rate for special nuclear material by 
adding manpower or installing additional processing equipment would 
accelerate de-inventory. LLNL determined that only moderate schedule 
gains would be made by adding manpower because processing equipment is 
already operating 24 hours a day, 7 days a week. Installing additional 
processing equipment is not feasible because, according to LLNL, 
startup of new equipment of this type generally takes several years and 
would not be operational in time to affect the de-inventory process as 
currently scheduled. Second, LLNL explored options for shipping 
materials to other sites for processing at a later date. LLNL 
determined that this option is not feasible because sites do not have 
enough storage space for material that is not yet packaged. 
Furthermore, a LLNL official said other sites do not have processing 
capability, and material would have to be shipped back to LLNL for 
processing at a later date. Moreover, sites have restrictions on the 
types of material they can receive. Finally, DOE looked at whether the 
Department of Transportation's regulatory requirements for packaging 
and shipping could be relaxed. DOE and LLNL determined that any such 
relaxation would unacceptably increase safety, environmental, and 
security risks. 

Conclusions: 

It is essential that sites adequately protect the Category I and II 
special nuclear material they possess, given the threats and risks this 
material poses. Until LLNL has fully completed the process of de- 
inventorying its Category I and II special nuclear material from 
Superblock, it must maintain a high level of security. As LLNL's 
inventory of Category I and II special nuclear material diminishes, it 
may prove difficult to sustain the level of security vigilance expected 
of Category I sites. Even after Category I and II special nuclear 
material is no longer present at LLNL, LSO's security oversight 
responsibilities will continue because laboratory employees must comply 
with requirements for protecting and controlling classified matter and 
lesser categories of special nuclear material. Strong federal oversight 
can help ensure that security remains a priority at LLNL and that 
corrective actions implemented as a result of the Office of Independent 
Oversight's April 2008 inspection are sustained. To do this, a federal 
site office with adequately trained subject matter experts to perform 
comprehensive security oversight, as required by DOE policies, is 
needed. In addition, NNSA's annual performance evaluation plans, 
associated with its management and operating contract for the 
laboratory, include financial incentives for security performance. NNSA 
can use performance evaluation plans to provide LLNS with financial 
incentives to sustain laboratory security improvements. 

Recommendations for Executive Action: 

To improve and sustain federal oversight of security performance at 
LLNL, we recommend that the Administrator of NNSA and the LSO Manager 
take the following two actions: 

* Develop a detailed plan and budget for implementing LSO's proposed 
security training program. 

* Incorporate financial incentives into future performance evaluation 
plans, as allowed by the new LLNS management and operating contract, 
for sustaining security improvements at LLNL through the completion of 
the laboratory's Category I and II special nuclear material de- 
inventory. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to NNSA for its review and comment. 
NNSA generally agreed with the report and its recommendations. NNSA 
noted that in its view the Office of Defense Nuclear Security and LSO 
are providing strong oversight over security at LLNL to ensure that 
security improvements are fully implemented and sustained. In 
particular, NNSA emphasized the Office of Defense Nuclear Security's 
role in supporting the overall improvement of security at LLNL. NNSA's 
comments on our draft report are presented in appendix II. NNSA also 
provided technical comments, which we incorporated into the report as 
appropriate. 

As arranged with your offices, unless you publicly announce its 
contents earlier, we plan no further distribution of this report until 
30 days after the date of this report. At that time, we will send 
copies of this report to the Secretary of Energy; Administrator of 
NNSA; Director of LLNL; and appropriate congressional committees. In 
addition, the report will be available at no charge on the GAO Web site 
at [hyperlink, http://www.gao.gov]. 

If you or your staffs have any questions about this report or need 
additional information, please contact me at (202) 512-3841 or 
aloisee@gao.gov. Contact points for our Offices of Congressional 
Relations and Public Affairs may be found on the last page of this 
report. Appendix III lists key contributors to this report. 

Signed by: 

Gene Aloise: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I Safeguards and Security Topics Covered in Office of 
Independent Oversight Inspections: 

Safeguards and security topics: Protection Program Management; 
* Planning process; 
* Organization and staffing; 
* Budget process; 
* Program direction; 
* Control systems; 
* Survey program; 
Program definition: Programs are designed to ensure that security 
interests are provided an appropriate degree of protection from hostile 
acts. It is an iterative process, whereby activities related to 
planning, staffing, budget, direction, and feedback are integrated with 
overall strategic and near-term operational planning. 

Safeguards and security topics: Physical Security Systems; 
* Intrusion detection assessment; 
* Entry and search controls; 
* Badges, passes, and credentials; 
* Barriers; 
* Communications; 
* Testing and maintenance; 
Program definition: Programs are designed to use intrusion detection 
and assessment, entry and search control, barriers, communications, 
testing and maintenance, and supporting systems and interfaces to 
deter, detect, annunciate, assess, delay, and communicate an 
unauthorized activity. 

Safeguards and security topics: Protective Force; 
* Management; 
* Training; 
* Equipment and facilities; 
* Duties; 
Program definition: Programs are designed to protect both DOE security 
interests from theft, sabotage, and other hostile acts that may 
adversely impact national security or the health and safety of the 
public, as well as life and property at DOE facilities. 

Safeguards and security topics: Classified Matter Protection and 
Control; 
* Program management; 
* Control of secret and confidential documents; 
* Control of top secret documents; 
* Control of classified materials; 
* Special programs; 
* Operations security; 
* Technical surveillance countermeasures; 
* Classification management; 
Program definition: Programs are designed to provide protection against 
unauthorized disclosure of classified matter and for sensitive 
information from its inception to destruction or decontrol. 

Safeguards and security topics: Material Control and Accountability; 
* Administration; 
* Accounting; 
* Measurements; 
* Inventories; 
* Containment; 
Program definition: Programs are designed to provide an information and 
control system for nuclear material. These programs encompass those 
systems and measures necessary to establish and track nuclear material 
inventories, control access, detect loss or diversion of nuclear 
material, and ensure the integrity of those systems and measures. 

Safeguards and security topics: Personnel Security; 
* Management; 
* Personnel clearance program; 
* Security education program; 
* Visitor control program; 
* Human reliability program; 
Program definition: Programs are designed to ensure that access to 
sensitive information, classified matter, and special nuclear material 
will be granted only after it has been determined that such access will 
not endanger security and is consistent with the national interest. 

Safeguards and security topics: Cyber Security--classified and 
unclassified; 
Program definition: Programs are designed to prevent deliberate or 
inadvertent unauthorized disclosure, acquisition, manipulation, 
modification, or loss of information contained within computer networks 
and systems, as well as measures designed to prevent denial of 
authorized use of the system. 

Source: Office of Independent Oversight's inspector guides. 

Note: The Office of Independent Oversight inspects classified and 
unclassified cyber security as separate security topics. 

[End of table] 

[End of section] 

Appendix II: Comments from the National Nuclear Security 
Administration: 

Department of Energy: 
National Nuclear Security Administration: 
Office Of The Administrator: 
Washington DC 20585: 

March 5, 2009: 
	
Mr. Gene Aloise: 
Director: 
Natural Resources and Environment: 
U.S. Government Accountability Office: 
Washington, D.C. 20548: 

Dear Mr. Aloise: 

The National Nuclear Security Administration (NNSA) appreciates the 
opportunity to review the Government Accountability Office's (GAO) 
draft report, GAO-09-321, "Nuclear Security: Better Oversight Needed to 
Ensure that Security Improvements at Lawrence Livermore National 
Laboratory Are Fully Implemented and Sustained." We understand that GAO 
conducted this audit at the request of the House's Committee on 
Homeland Security to assess aspects of Livermore's security posture. 

The NNSA generally agrees with the report and recommendations. 
Following the Office of Independent Oversight's inspection of the 
Livermore Site Office (LSO) and Lawrence Livermore National Laboratory 
(LLNL) that identified significant weaknesses in the security program 
at the Laboratory, LLNL initiated an aggressive plan to improve the 
effectiveness of its protection strategy in coordination with the 
Office of Defense Nuclear Security (DNS) and LSO. DNS has devoted 
considerable resources supplementing LSO's efforts to oversee 
improvements to LLNL security and will continue to provide significant 
support and validate the site's capability of moving forward in a 
positive manner. Through the DNS/LSO collaboration, teams of security 
experts have monitored and evaluated the security strategy upgrades and 
a revision to the Security Incident Response Plan to ensure they were 
effective. The teams actively worked to provide independent technical 
reviews for vulnerability assessment actions, as well as protective 
force strategy and training/testing procedures, and provided advice and 
procedures for further improvements. Additionally, LLNL has made good 
progress in their de-inventory efforts in that they have recently 
relocated 20% of their special nuclear material inventory for a total 
of a 55% reduction since the site's de-inventory effort began. The 
active role of LSO and DNS provides strong oversight of the 
Laboratory's security program to ensure the implementation and 
sustainment of the LLNL security posture. 

Enclosed are general and technical comments to the report for your 
consideration. Should you have any questions about this response, 
please contact Cathy Tullis, Acting Director, Policy and Internal 
Controls Management. 

Sincerely, 

Signed by: 

William C. Ostendorff: 
Principal Deputy Administrator: 

Enclosure: 

cc: 

Associate Administrator for Defense Nuclear Security Director, Service 
Center: 
Senior Procurement Executive: 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

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

Staff Acknowledgments: 

In addition to the individual named above, Jonathan Gill and John 
Cooney, Assistant Directors; Allison Bawden; Tom Twambly; Ray 
Rodriguez; Omari Norman; Jamie Roberts; Tim Persons; Nabajyoti 
Barkakati; and Carol Hernstadt Shulman made important contributions to 
this report. 

[End of section] 

Footnotes: 

[1] The other design and development laboratories are Los Alamos 
National Laboratory in Los Alamos, New Mexico, and Sandia National 
Laboratories in New Mexico and California. 

[2] LLNL also plans to de-inventory all of its Category II special 
nuclear material—smaller quantities of weapons-grade materials, such as 
highly enriched uranium and plutonium—that could be credibly aggregated 
into Category I quantities. 

[3] Until recently, this policy was known as DOE’s design basis threat 
(DBT). In 2008, DOE replaced the DBT with a Graded Security Protection 
policy that provides information that is similar to the information in 
the DBT but is tailored to risks at specific sites within the DOE 
nuclear weapons complex. 

[4] LLNS is a limited liability corporation made up of Bechtel 
National, Inc.; the University of California; BWX Technologies, Inc. 
(now part of the Babcock & Wilcox Company); and the Washington Group 
International, Inc. The team also includes Battelle Memorial Institute, 
four small business contractors, and Texas A&M University. 

[5] As noted earlier, DOE has now replaced the 2005 DBT (DOE Order 
470.3A) with the Graded Security Protection plan (DOE Order 470.3B). 

[6] Prior to this decision, NNSA had committed LLNL to meeting the 2005 
DBT and had reported these plans to Congress in June 2006 as required 
by Section 3113 of the National Defense Authorization Act for Fiscal 
Year 2006 (Pub. L. No. 109-163, 119 Stat. 3136, 3543). 

[7] LSO and the Office of Independent Oversight categorize the topics 
and subtopics they cover differently. The Office of Independent 
Oversight also includes in its inspections subtopics covering 
safeguards and security at LSO. 

[8] While the Office of Independent Oversight gave an effective 
performance rating to LLNL’s personnel security program, in December 
2008 DOE’s Office of Inspector General found that LLNL did not fully 
adhere to DOE requirements regarding security clearance justifications 
and that no internal controls were in place to validate the 
justifications stated in security clearance requests. See U.S. 
Department of Energy, Office of Inspector General, Office of 
Inspections and Special Inquiries, Security Clearances at Lawrence 
Livermore National Laboratory and Sandia National Laboratory-
California, INS-O-09-01 (Washington, D.C.: December 2008). 

[9] The Office of Independent Oversight also inspected classified and 
unclassified cyber security at LLNL. Separately, we are reviewing cyber 
security across the DOE complex, including at LLNL, and therefore we 
did not include an assessment of cyber security findings at LLNL as 
part of this review. 

[10] We have reported in the past on the lack of comprehensiveness of 
site office security surveys and on a lack of training for site office 
staff. See GAO, Nuclear Security: NNSA Needs to Better Manage Its 
Safeguards and Security Program, [hyperlink, 
http://www.gao.gov/products/GAO-03-471] (Washington, D.C.: May 30, 
2003); and National Nuclear Security Administration: Additional Actions 
Needed to Improve Management of the Nation’s Nuclear Programs, 
[hyperlink, http://www.gao.gov/products/GAO-07-36] (Washington, D.C.: 
Jan. 19, 2007). 

[11] LLNL’s 54 corrective action plans address both physical and cyber 
security findings. Of these plans, 34 corrective action plans address 
physical security topical areas that received less than effective 
performance ratings. 

[12] Pub. L. No. 106-65, 113 Stat. 512, 953 (1999). 

[13] According to LLNL’s corrective action plans, one milestone to 
correct a protective force deficiency will not be completed before the 
end of fiscal year 2009. It is scheduled for completion on October 30, 
2009. 

[14] In fiscal year 2008, $1.5 million was deducted from the $17.2 
million in incentive fee that LLNS earned as a penalty for the loss of 
key personnel during the first year of the contract. However, LLNS also 
was awarded an additional $21.9 million, which represents the fixed 
fees for laboratory management and operation ($13.7 million) and work 
for other federal agencies and organizations ($8.2 million). In total, 
LLNS earned $37.5 million, or 70 percent of the maximum available total 
fee. 

[15] DOE-STD-3013-2004 Stabilization, Packaging, and Storage of 
Plutonium-Bearing Materials (April 2004); and DOE-STD-3028-2000 
Criteria for Packaging and Storing Uranium-233-Bearing Materials (July 
2000). 

[End of section] 

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