This is the accessible text file for GAO report number GAO-06-389
entitled 'Combating Nuclear Smuggling: DHS Has Made Progress Deploying
Radiation Detection Equipment at U.S. Ports-of-Entry, but Concerns
Remain' which was released on March 28, 2006.
This text file was formatted by the U.S. Government Accountability
Office (GAO) to be accessible to users with visual impairments, as part
of a longer term project to improve GAO products' accessibility. Every
attempt has been made to maintain the structural and data integrity of
the original printed product. Accessibility features, such as text
descriptions of tables, consecutively numbered footnotes placed at the
end of the file, and the text of agency comment letters, are provided
but may not exactly duplicate the presentation or format of the printed
version. The portable document format (PDF) file is an exact electronic
replica of the printed version. We welcome your feedback. Please E-mail
your comments regarding the contents or accessibility features of this
document to Webmaster@gao.gov.
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed
in its entirety without further permission from GAO. Because this work
may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this
material separately.
Report to Congressional Requesters:
March 2006:
Combating Nuclear Smuggling:
DHS Has Made Progress Deploying Radiation Detection Equipment at U.S.
Ports-of-Entry, but Concerns Remain:
GAO-06-389:
GAO Highlights:
Highlights of GAO-06-389, a report to congressional requesters:
Why GAO Did This Study:
Preventing radioactive material from being smuggled into the United
States is a key national security objective. To help address this
threat, in October 2002, DHS began deploying radiation detection
equipment at U.S. ports-of-entry. This report reviews recent progress
DHS has made (1) deploying radiation detection equipment, (2) using
radiation detection equipment, (3) improving the capabilities and
testing of this equipment, and (4) increasing cooperation between DHS
and other federal agencies in conducting radiation detection programs.
What GAO Found:
The Department of Homeland Security (DHS) has made progress in
deploying radiation detection equipment at U.S. ports-of-entry, but the
agency’s program goals are unrealistic and the program cost estimate is
uncertain. As of December 2005, DHS had deployed 670 portal monitors
and over 19,000 pieces of handheld radiation detection equipment.
However, the deployment of portal monitors has fallen behind schedule,
making DHS’s goal of deploying 3,034 by September 2009 unlikely. In
particular, two factors have contributed to the schedule delay. First,
DHS provides the Congress with information on portal monitor
acquisitions and deployments before releasing any funds. However, DHS’s
lengthy review process has caused delays in providing such information
to the Congress. Second, difficult negotiations with seaport operators
about placement of portal monitors and how to most efficiently screen
rail cars have delayed deployments at seaports. Regarding the
uncertainty of the program’s cost estimate, DHS would like to deploy
advanced technology portals that will likely cost significantly more
than the currently deployed portals, but tests have not yet shown that
these portals are demonstrably more effective than the current portals.
Consequently, it is not clear that the benefits of the new portals
would be worth any increased cost to the program. Also, our analysis of
the program’s costs indicates that DHS may incur a $342 million cost
overrun.
DHS has improved in using detection equipment and in following the
agency’s inspection procedures since 2003, but we identified two
potential issues in Customs and Border Protection (CBP) inspection
procedures. First, although radiological materials being transported
into the United States are generally required to have a Nuclear
Regulatory Commission (NRC) license, regulations do not require that
the license accompany the shipment. Further, CBP officers do not have
access to data that could be used to verify that shippers have acquired
the necessary documentation. Second, CBP inspection procedures do not
require officers to open containers and inspect them, although under
some circumstances, doing so could improve security. In addition, DHS
has sponsored research, development, and testing activities to address
the inherent limitations of currently fielded equipment. However, much
work remains to achieve consistently better detection capabilities.
DHS seems to have made progress in coordinating with other agencies to
conduct radiation detection programs; however, because the DHS office
created to achieve the coordination is less than 1 year old, its
working relationships with other agencies are in their early stages of
development and implementation. In the future, this office plans to
develop a “global architecture” to integrate several agencies’
radiation detection efforts, including several international programs.
What GAO Recommends:
The Secretary of Homeland Security should work with other agencies, as
necessary, to (1) streamline internal review procedures so that
spending data can be provided to the Congress in a more timely way; (2)
update the current deployment plan; (3) analyze the benefits and costs
of advanced portals, then revise the program’s cost estimates to
reflect current decisions; (4) develop ways to effectively screen rail
containers; (5) revise agency procedures for container inspection; and
(6) develop a way for CBP officers to verify NRC licenses.
In commenting on a draft of this report, DHS stated that it agreed
with, and will implement, our recommendations.
www.gao.gov/cgi-bin/getrpt?GAO-06-389.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Gene Aloise, (202) 512-
3841.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
DHS Has Made Progress in Deploying Radiation Detection Equipment, but
the Agency's Program Goals Are Unrealistic and the Cost Estimate Is
Uncertain:
CBP Officers Have Made Progress in Using Radiation Detection Equipment
Correctly and Adhering to Inspection Guidelines, but There Are
Potential Issues with Agency Procedures:
DHS Is Working to Improve the Capabilities of Currently-fielded and New
Radiation Detection Equipment, but Much Work Remains to Achieve Better
Equipment Performance:
The Newly Created Domestic Nuclear Detection Office Is Structured to
Improve Coordination of Executive Branch Radiation Detection Programs:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Scope and Methodology:
Appendix II: GAO Contact and Staff Acknowledgments:
Appendix III: Comments from the Department of Homeland Security:
Related GAO Products:
Tables:
Table 1: Status of Portal Monitor Deployments as of December 2005:
Table 2: Cooperation with DNDO Brought about by Presidential Directive:
Figures:
Figure 1: Monthly Cumulative Values of Work Planned but Not Finished As
Planned:
Figure 2: Monthly Cumulative Cost Overruns:
Figure 3: CBP Officers Conducting an External Secondary Inspection at a
Seaport:
Figure 4: A CBP Officer Entering a Cargo Container During a Secondary
Inspection at a Seaport:
Figure 5: The "SMARTCART," a Mobile Portal Monitor Using Advanced
Detection Technology, Being Tested at the CMTB in New York:
Abbreviations:
ANSI: American National Standards Institute:
CBP: Customs and Border Protection:
CMTB: Counter Measures Test Bed:
DHS: Department of Homeland Security:
DNDO: Domestic Nuclear Detection Office:
DOD: Department of Defense:
DOE: Department of Energy:
FBI: Federal Bureau of Investigation:
FLETC: Federal Law Enforcement Training Center:
GAO: Government Accountability Office:
LSS: Laboratories and Scientific Services:
NIST: National Institute for Standards and Technology:
NTS: Nevada Test Site:
NRC: Nuclear Regulatory Commission:
PNNL: Pacific Northwest National Laboratory:
S&T: DHS Science and Technology Directorate:
TSA: Transportation Security Administration:
Letter March 24, 2006:
Congressional Requesters:
Since the attacks of September 11, 2001, combating terrorism has been
one of the nation's highest priorities. As part of that effort,
preventing radioactive material from being smuggled into the United
States--perhaps to be used by terrorists in a nuclear weapon or in a
radiological dispersal device (a "dirty bomb")--has become a key
national security objective. The Department of Homeland Security (DHS)
is responsible for providing radiation detection capabilities at U.S.
ports-of-entry.[Footnote 1] Until April 2005, U.S. Customs and Border
Protection (CBP) managed this program. However, on April 15, 2005, the
president directed the establishment, within DHS, of the Domestic
Nuclear Detection Office (DNDO), whose duties include acquiring and
supporting the deployment of radiation detection equipment.[Footnote 2]
CBP continues its traditional screening function at ports-of-entry to
prevent illegal immigration and to interdict contraband, including the
operation of radiation detection equipment. The Pacific Northwest
National Laboratory (PNNL), one of the Department of Energy's (DOE)
national laboratories, manages the deployment of radiation detection
equipment for DHS.[Footnote 3]
DHS's program to deploy radiation detection equipment at U.S. ports-of-
entry has two goals. The first is to use this equipment to screen all
cargo, vehicles, and individuals coming into the United States. The
United States has over 380 border sites at which DHS plans to deploy
radiation detection equipment. The volume of traffic entering the
United States also adds to the size and complexity of the job. For
example, each day, DHS processes about 64,000 containers arriving in
the United States via ships, trucks, and rail cars; 365,000 vehicles;
and more than 1.1 million people. The second goal of the program is to
screen all of this traffic without delaying its movement into the
nation. To illustrate the difficulty of achieving this second goal,
CBP's port director at the San Ysidro, California, land border crossing
estimated that prior to initiating radiation screening, the volume of
traffic through the port-of-entry was so great that, at times, the wait
to enter the United States from Mexico was about 2.5 hours. He noted
that had radiation detection screening added a mere 20 seconds to the
wait of each vehicle, the wait during those peak times could have
increased to about 3.5 or 4 hours--an unacceptable outcome in his view.
DHS's current plans call for completing deployments of radiation
detection equipment at U.S. ports-of-entry by September 2009.
To screen commerce for radiation, CBP uses several types of detection
equipment and a system of standard operating procedures. Current
detection equipment includes radiation portal monitors, which can
detect gamma radiation (emitted by all of the materials of greatest
concern) and neutrons (emitted by only a limited number of materials,
including plutonium--a material that can be used to make a nuclear
weapon). CBP officers also carry personal radiation detectors--commonly
referred to as "pagers"--small handheld devices that detect gamma
radiation, but not neutrons. For the most part, pagers are meant to be
personal safety devices, although they are used in some locations to
assist with inspections. Finally, CBP officers also use radioactive
isotope identification devices, which are handheld devices designed to
determine the identity of radioactive material--that is, whether it is
a nuclear material used in medicine or industry, a naturally occurring
source of radiation, or weapons-grade material. All of these devices
have limitations in their ability to detect and identify nuclear
material.
Generally, CBP's standard procedures direct vehicles, containers, and
people coming into the country to pass through portal monitors to
screen for the presence of radiation. This "primary inspection" serves
to alert CBP officers that a radioactive threat might be present. All
traffic that causes an alarm during primary inspection is to undergo a
"secondary inspection" that consists of screening with another portal
monitor to confirm the presence of radiation, and includes CBP officers
using radiation isotope identification devices to determine the source
of radiation being emitted, (e.g., harmless sources, such as ceramics,
or dangerous sources, such as weapons-grade nuclear material). If CBP
officers identify a nuclear or radiological threat during a secondary
inspection, or if the officers' pagers register a dangerously high
level of radiation, then officers are to establish a safe perimeter
around the nuclear material and contact scientists in CBP's
Laboratories and Scientific Services (LSS) for further
guidance.[Footnote 4] In some cases, CBP identifies incoming sea-bound
cargo containers through a system that targets some containers for
inspection based on their perceived level of risk. In these situations,
CBP works with seaport terminals to have containers moved to an agreed-
upon location for inspection. These inspections include the use of
active imaging, such as an x-ray, and passive radiation detection, such
as a radiation isotope identification device. Typically, if CBP
officers find irregularities, physical examinations are conducted.
In September 2003, we reported on CBP's progress in completing domestic
deployments. In particular, we reported that certain aspects of CBP's
installation and use of the equipment diminished its effectiveness and
that coordination among agencies on long-term research issues was
limited. Since the issuance of our 2003 report, questions have arisen
about the efficacy of the detection equipment CBP has deployed--in
particular, its purported inability to distinguish naturally occurring
radioactive materials from a nuclear bomb.
Because of the complexity and importance of these issues, you asked us
to assess the progress made in (1) deploying radiation detection
equipment at U.S. ports-of-entry and any problems associated with that
deployment, (2) using radiation detection equipment at U.S. ports-of-
entry and any problems associated with that use, (3) improving the
capabilities and testing of this equipment, and (4) increasing the
level of cooperation between DHS and other federal agencies in
conducting radiation detection programs.
To address these objectives, we (1) analyzed CBP's project plan,
including the project's costs and deployment schedules, to deploy
radiation detection equipment at U.S. ports-of-entry; (2) visited
several ports-of-entry, including two international mail and express
courier facilities, five seaports, and three land border crossings; (3)
participated in radiation detection training for CBP officers; and (4)
visited four national laboratories, the Nevada Test Site, and an Air
Force base involved with testing and deploying radiation detection
equipment. We focused primarily on the issues surrounding radiation
portal monitors because they are a major tool in the federal
government's efforts to thwart nuclear smuggling. We also focused on
this equipment because its procurement and installation cost far
exceeds the cost of procuring and deploying other radiation detection
equipment such as handheld equipment also used at U.S. ports-of-entry.
We reviewed documentation, such as deployment and cost figures,
equipment test plans and results, and agency agreements to cooperate in
detecting radiation. We also interviewed key program officials at each
of these agencies to discuss the deployment of radiation detection
equipment, attempts to improve the equipment's capabilities, and
cooperation among agencies to protect the United States from nuclear
terrorism. We performed a data reliability assessment of the data we
received, and interviewed knowledgeable agency officials on the
reliability of the data. We determined the data were sufficiently
reliable for the purposes of this report. More details on our scope and
methodology appear in appendix I. We conducted our review from March
2005 to February 2006 in accordance with generally accepted government
auditing standards.
Results in Brief:
Between October 2000 and October 2005, the United States spent about
$286 million to deploy radiation detection equipment at domestic ports-
of-entry. However, the deployment of portal monitors has fallen behind
schedule, making DHS's goal of deploying 3,034 by 2009 unlikely. To
meet its long-term goal, DHS would have to deploy about 52 portal
monitors a month for the next 4 years--a rate that far exceeds the 2005
rate of about 22 per month. Moreover, the program's estimated total
cost of $1.3 billion is highly uncertain. Several factors have
contributed to the slow pace of deployment. First, program officials
typically disburse funds to the contractor managing the deployment late
in the fiscal year. For example, the contractor did not receive its
fiscal year 2005 allocation until September 2005. These delays have
caused the contractor to postpone or cancel contracts, sometimes
delaying deployments. According to the House Appropriations Committee
report on the CBP portion of DHS's fiscal year 2005 budget, CBP should
provide the Congress with an acquisition and deployment plan for the
portal monitor program prior to funding Pacific Northwest National
Laboratory (PNNL). This plan took many months to finalize, mostly
because it required multiple approvals within DHS and the Office of
Management and Budget (OMB) prior to being submitted to the Congress.
The lengthy review process delayed the release of funds and, in some
cases, disrupted and delayed deployment. In fiscal year 2005, this
process was further delayed by the creation of DNDO, and the
uncertainty regarding the new office's responsibilities. Second,
negotiations with seaport operators to deploy portal monitors have
taken longer than anticipated because some operators believe screening
for radiation will adversely affect the flow of commerce through their
ports. DHS has adopted a deployment policy designed to achieve
cooperation with seaport operators because agency officials believe
such arrangements are more efficient and, in the long term, probably
more timely. Third, devising an effective way to conduct secondary
inspections of rail traffic departing seaports without disrupting
commerce has delayed deployments. This problem may worsen because the
Department of Transportation (DOT) has forecast that the use of rail
transit out of seaports will probably increase in the near future.
Addressing and solving the problems with screening rail transport is
critical to the successful completion of the DHS program.
Regarding the total cost of the project, CBP's $1.3 billion estimate is
highly uncertain and overly optimistic. The estimate is based on CBP's
plans for widespread deployment of advanced technology portal monitors
currently being developed. However, the prototypes of this equipment
have not yet been shown to be more effective than the portal monitors
now in use, and DHS officials say they will not purchase the advanced
portal monitors unless they are proven to be superior. Moreover, when
the advanced technology portal monitors become commercially available,
experts estimate that they will cost between about $330,000 and
$460,000 each--far more than the currently-used portal monitors which
cost between $49,000 and $60,000. The installation cost for both types
of portal monitor is roughly $200,000. Even if future test results
indicate better detection capabilities, without a detailed comparison
of the two technologies' capabilities it is not clear that the
dramatically higher cost for this new equipment would be worth the
investment. Finally, our analysis of CBP's deployment data indicates
that the program will probably experience a significant cost overrun of
between $88 million and $596 million, with a $342 million overrun most
likely.
The CBP officers we observed conducting primary and secondary
inspections appeared to use radiation detection equipment correctly and
to follow inspection procedures. In contrast, in 2003 we reported that
CBP officers sometimes used radiation detection equipment in ways that
reduced its effectiveness and sometimes did not follow agency
procedures. Generally, CBP requires that its officers receive formal
training in using radiation detection equipment, and many officers have
gained experience and proficiency in using the equipment since the
program's inception. However, we also identified two potential issues
in CBP inspection procedures that, if addressed, could strengthen the
nation's defenses against nuclear smuggling. For example, individuals
and organizations shipping radiological materials to the United States
generally must acquire a Nuclear Regulatory Commission (NRC) license,
but regulations do not require that the license accompany the shipment.
Further, according to CBP officials, CBP officers lack access to NRC
license data that could be used to verify that shippers of radiological
material actually obtained required licenses, and to authenticate
licenses that accompany shipments. The second potential issue pertains
to CBP's guidance for conducting secondary inspections. Currently, CBP
procedures require only that officers locate, isolate, and identify
radiological material. Typically, officers perform an external
examination by scanning the sides of cargo containers with a radiation
isotope identification device during secondary inspections. The
guidance does not specifically require officers to open containers and
inspect their interiors, even when an external examination cannot
unambiguously resolve an alarm. However, at one port-of-entry we
visited, CBP officers routinely opened and entered commercial truck
trailers to conduct secondary inspections when an external inspection
could not locate and identify the radiological source. This approach
increases the chances that the source of the radioactivity that
originally set off the alarm will be correctly located and identified.
According to senior CBP officials at this port-of-entry, this
additional procedure has had little negative impact on the flow of
commerce and has not increased the cost of CBP inspections, despite
being implemented at one of the busiest commercial ports-of-entry in
the nation.
DHS would like to improve the capabilities of currently-fielded
radiation detection equipment. Today's equipment lacks a refined
capability to rapidly determine the type of radioactive materials they
detect, which means that CBP officers often conduct secondary
inspections of containers carrying non-threatening material. To address
this limitation, DHS has sponsored research, development, and testing
activities that attempt to improve the capabilities of existing
radiation portal monitors and to produce new, advanced technologies
with even greater detection and identification enhancements. However,
much work remains for the agency to achieve consistently better
detection capabilities, as the efforts undertaken so far have had only
mixed results. For example, DHS sponsored the development of a software
package designed to reduce the number of false alarms from portal
monitors already in widespread use. However, tests of the software have
been largely inconclusive. In some test scenarios, there was little
difference in detection capability between portal monitors equipped
with--and without--the new software. Experts have recommended further
testing to improve the software's capabilities. Further, DHS is testing
new, advanced portal monitors that use a technology designed to both
detect the presence of radiation and identify its source. However, in
tests performed during 2005, the detection capabilities of the advanced
technology prototypes demonstrated mixed results--in some cases they
worked better, but in other cases, they worked about the same as
already deployed systems. In addition, DHS also sponsors a long-range
research program aimed at developing innovative technologies designed
to improve the capabilities of radiation detection equipment. For
example, DHS is supporting research at two national laboratories on a
new system designed to better detect radiation sources, even when
shielded with materials designed to hide their presence. The two
laboratories have constructed several prototypes, but currently the
high cost of this technology limits its commercial attractiveness.
Finally, DHS plans to use its new testing facility being built at the
Nevada Test Site to improve on existing test capabilities and to
support the agency's development, testing, acquisition, and deployment
of radiation detection technologies.
Historically, cooperation between agencies conducting radiation
detection programs has been limited. Currently DHS, largely through
DNDO, cooperates with DOE, the Department of Defense (DOD), and other
agencies to coordinate these programs; however, because DNDO was
created less than 1 year ago, its cooperative efforts--and its working
relationships with other federal agencies--are in their early stages of
development and implementation. Currently, other federal agencies are
providing staff to work directly with DNDO. However, it is too soon to
determine the overall effectiveness of these efforts. DHS also works
with other agencies to make current detection efforts more efficient
and effective. For example, in April 2005, DHS and DOE entered into a
memorandum of understanding to, among other things, exchange
information on radiation detection technologies to improve the
effectiveness of their deployment; the agencies also agreed to share
lessons learned from operational experiences, and data received from
radiation detection equipment deployed at U.S. and foreign ports. Also
in April 2005, DHS entered into an agreement with the Port Authority of
New York and New Jersey to, among other things, integrate lessons
learned from field experience into domestic radiation detection
efforts. In the future, DNDO intends to develop an integrated worldwide
system. The resulting "global architecture," as it is being called by
DNDO officials, would be a multi-layered defense strategy that includes
programs that attempt to secure nuclear materials and detect their
movements overseas, such as DOE's Second Line of Defense program; to
develop intelligence information on nuclear materials' trans-shipments
and possible movement to the United States; and to integrate these
elements with domestic radiation detection efforts undertaken by
governments--federal, state, local, and tribal--and the private sector.
We are recommending a series of actions designed to help DHS speed up
the pace of portal monitor deployments, better account for schedule
delays and cost uncertainties, make the most efficient use of program
resources, and improve its ability to interdict illicit nuclear
materials.
We provided a draft of this report to DHS for its review and comment.
DHS stated that it agreed with, and will implement, our
recommendations.
Background:
Initial concerns about the threat posed by nuclear smuggling were
focused on nuclear materials originating in the former Soviet Union. As
a result, the first major initiatives concentrated on deploying
radiation detection equipment at borders in countries of the former
Soviet Union and in Central and Eastern Europe. In particular, in 1998,
DOE established the Second Line of Defense program, which, through the
end of fiscal year 2005, had installed equipment at 83 sites mostly in
Russia.[Footnote 5] In 2003, DOE implemented a second program, the
Megaports Initiative,[Footnote 6] to focus on the threat posed by
nuclear smuggling overseas by installing radiation detection equipment
at major seaports around the world.[Footnote 7]In the United States,
the U.S. Customs Service began providing its inspectors with portable
radiation detection devices in 1998. After September 11, 2001, the
agency expanded its efforts to include the deployment of portal
monitors--large-scale radiation detectors that can be used to screen
vehicles and cargo.[Footnote 8] In March 2003, the U.S. Customs Service
was transferred to DHS, and the border inspection functions of the
Customs Service, including radiation detection, became the
responsibility of CBP.[Footnote 9]
Deploying radiation detection equipment at U.S. borders is part of
DHS's strategy for addressing the threat of nuclear and radiological
terrorism. DHS's strategy includes: (1) countering proliferation at the
source by assisting foreign governments in their efforts to detect and
interdict nuclear and radiological smuggling; (2) controlling the
illegal export of technology and equipment from the United States that
terrorists could use to develop a nuclear or radiological weapon; (3)
detecting and interdicting potential smuggling attempts before they
reach the United States; and (4) securing U.S. ports-of-entry through
multiple technologies that include radiation detection and nonintrusive
inspections to view images of cargo in sea containers.
CBP plans to deploy radiation portal monitors in five phases, or
"categories of entry" (1) international mail and express courier
facilities; (2) major northern border crossings; (3) major seaports;
(4) southwestern border crossings; and (5) all other categories,
including international airports, remaining northern border crossings
and seaports, and all rail crossings. In this final phase, CBP also
plans to replace the currently-fielded portal monitors with newer, more
advanced technology. Generally, CBP prioritized these categories
according to their perceived vulnerability to the threat of nuclear
smuggling. CBP did not, however, conduct a formal threat assessment.
International mail and express courier facilities present a potential
vulnerability because mail and packages arrive with no advance notice
or screening. Northern border crossings are also vulnerable, according
to CBP, because of the possible presence of terrorist cells operating
in Canada. The third category, major seaports, is considered vulnerable
because sea cargo containers are suitable for smuggling and because of
the large volume of such cargo. Seaports account for over 95 percent of
the cargo entering the United States. Southwestern borders are
vulnerable because of the high volume of traffic and because of the
smuggling that already occurs there. Although airlines can quickly ship
and deliver air cargo, CBP considers air cargo to be a slightly lesser
risk because the industry is highly regulated.
In deploying radiation detection equipment at U.S. borders, CBP
identified the types of nuclear materials that might be smuggled, and
the equipment needed to detect its presence. The radiological materials
of concern include assembled nuclear weapons; nuclear material that
could be used in a nuclear weapon but that is not actually assembled
into a weapon ("weapons-grade nuclear material"); radiological
dispersal devices, commonly called "dirty bombs;" and other illicit
radioactive material, such as contaminated steel or inappropriately
marked or manifested material. Detecting actual cases of attempted
nuclear smuggling is difficult because there are many sources of
radiation that are legal and not harmful when used as intended. These
materials can trigger alarms (known as "nuisance alarms") that are
indistinguishable from those alarms that could sound in the event of a
true case of nuclear smuggling. Nuisance alarms are caused by patients
who have recently had radiological treatment; a wide range of cargo
with naturally occurring radiation, such as fertilizer, ceramics, and
food products; and legitimate shipments of radiological sources for use
in medicine and industry. In addition, detecting highly-enriched
uranium, in particular, is difficult because of its relatively low
level of radioactivity. Furthermore, a potential terrorist would likely
attempt to shield the material to reduce the amount of radiation
reaching the detector and thereby decrease the probability of
detection.
The process of deploying portal monitors begins with a site survey to
identify the best location at an entry point for installing the
equipment. While in some cases the choice may be obvious, operational
considerations at many entry points require analysis to find a location
where all or most of the cargo and vehicles can pass through the portal
monitor without interfering with the flow of commerce. After
identifying the best option, CBP works with local government and
private entities to get their support. At many U.S. entry points, the
federal government does not own the property and therefore collaborates
with these entities to deploy the equipment. It is CBP's policy to
depend exclusively on such negotiations, rather than to use any kind of
eminent domain or condemnation proceeding. The actual installation of
the portal monitors involves a number of tasks such as pouring
concrete, laying electrical groundwork, and hooking up the portal
monitors to alarm systems that alert officers when radiation is
detected. Finally, PNNL tests the equipment and trains CBP officers on
its operation, including how to respond to alarms.
To coordinate the national effort to protect the United States from
nuclear and radiological threats, in April 2005, the president directed
the establishment of DNDO within DHS. The new office's mission covers a
broad spectrum of responsibilities and activities, but is focused
primarily on providing a single accountable organization to develop a
layered defense system. This system is intended to integrate the
federal government's nuclear detection, notification, and response
systems. In addition, under the directive, DNDO is to acquire, develop,
and support the deployment of detection equipment in the United States,
as well as to coordinate the nation's nuclear detection research and
development efforts. For fiscal year 2006, DNDO's total budget is
approximately $318 million, which includes at least $81 million for
research and development of advanced nuclear detection technologies and
$125 million for portal monitor purchase and deployment.
The Homeland Security Act of 2002 gave DHS responsibility for managing
the research, development, and testing of technologies to improve the
U.S. capability to detect illicit nuclear material.[Footnote 10] Prior
to the creation of DNDO, DHS's Science and Technology (S&T) directorate
had this responsibility. DNDO has assumed these responsibilities and
works with S&T's Counter Measures Test Beds (CMTB) to test radiation
detection equipment in New York and New Jersey. As of January 2006,
DNDO has provided $605,000 to DOE national laboratories that support
this effort. Additional funding for fiscal year 2006 from S&T and DNDO
to support test and evaluation activities at the CMTB is yet to be
determined. The Homeland Security Act also provided DHS the authority
to use DOE national laboratories for research, development, and testing
of new technologies to detect nuclear material.[Footnote 11]
DHS Has Made Progress in Deploying Radiation Detection Equipment, but
the Agency's Program Goals Are Unrealistic and the Cost Estimate Is
Uncertain:
As of December 2005, DHS had completed deployment of portal monitors at
two categories of entry--a total of 61 ports-of-entry--and has begun
work on two other categories; overall, however, progress has been
slower than planned. According to DHS officials, the slow progress has
resulted from a late disbursal of funds, and delays in negotiating
deployment agreements with seaport operators. Further, we believe the
expected cost of the program is uncertain because DHS's plans to
purchase newer, more advanced equipment are not yet finalized; also we
project that the program's final cost will be much higher than CBP
currently anticipates.
The Program to Install Portal Monitors Has Fallen Behind Schedule:
Between October 2000 and October 2005, DHS, mainly through its prime
contractor PNNL, has spent about $286 million to deploy radiation
detection equipment at U.S. ports-of-entry. As of December 2005, DHS
had deployed 670 of 3,034 radiation portal monitors--about 22 percent
of the portal monitors DHS plans to deploy.[Footnote 12] The agency has
completed portal monitor deployments at international mail and express
courier facilities and the first phase of northern border sites--57 and
217 portal monitors, respectively. In addition, by December 2005, DHS
had deployed 143 of 495 portal monitors at seaports and 244 of 360 at
southern borders. In addition, three portal monitors had been installed
at the Nevada Test Site to analyze their detection capabilities and
four had been retrofitted at express mail facilities. As of February
2006, CBP estimated that with these deployments CBP has the ability to
screen about 62 percent of all containerized shipments entering the
United States, and roughly 77 percent of all private vehicles (POVs).
Within these total percentages, CBP can screen 32 percent of all
containerized seaborne shipments; 90 percent of commercial trucks and
80 percent of private vehicles entering from Canada; and approximately
88 percent of all commercial trucks and 74 percent of all private
vehicles entering from Mexico.
CBP does not maintain a firm schedule for deploying handheld radiation
detectors, such as pagers and radiation isotope identification devices.
This is equipment used mainly to help pinpoint and identify sources of
radiation found during inspections. Instead, according to CBP
officials, the agency acquires and deploys such equipment each fiscal
year as needed. The handheld radiation detectors are procured to
coincide with portal monitor deployments to ensure mission support.
Since fiscal year 2001, CBP has spent about $24.5 million on pagers,
and about $6.6 million on radiation isotope identification devices. At
present, CBP can field roughly 12,450 pagers--enough to ensure that all
officers conducting primary or secondary inspections at a given time
have one. The agency intends to deploy about 6,500 additional pagers.
Similarly, CBP's 549 radiation isotope identification devices are
deployed at domestic ports-of-entry. CBP intends to acquire another 900
to ensure that all needs are met.
Overall, CBP and PNNL have experienced difficulty meeting the portal
monitor deployment schedule. None of the planned portal monitor
deployments has progressed according to schedule, and monthly
deployments would have to increase by almost 230 percent to meet a
September 2009 program completion date. For example, in November 2005,
deployments at land crossings were about 20 months and $1.9 million
behind schedule, while deployments at the first 22 seaports were about
2 years and $24 million behind schedule.[Footnote 13] Despite these
delays, PNNL reported in November 2005 that the overall project
schedule should not extend beyond its current completion date of
September 2009. However, our analysis indicates that CBP's deployment
schedule is too optimistic.
In fact, for CBP and PNNL to meet the current deployment schedule, they
would have to install about 52 portal monitors per month from November
2005 to September 2009. In our view, this is unlikely because it
requires a rate of deployment that far exceeds recent experience. For
example, during calendar year 2005, PNNL deployed portal monitors at
the rate of about 22 per month, and deployments have fallen further and
further behind schedule. Between February and December 2005, for
example, PNNL did not meet any of its scheduled monthly deployments,
never deploying more than 38 portal monitors during any single month.
If CBP continues to deploy portal monitors at its 2005 pace, the last
monitor would not be deployed until about December 2014. Table 1
details the status of portal monitor deployments, as of December 2005.
Table 1: Status of Portal Monitor Deployments as of December 2005:
Portal monitor deployment phase: International mail and express
consignment facilities[A] (23 facilities);
Total portals planned: 57;
Status: Completed April 2004 4 months late.
Portal monitor deployment phase: Land border and rail ports-of-entry
(205 crossings);
Total portals planned: 967;
Status: 20 months late.
Portal monitor deployment phase: Seaports (106 terminals) and
international airports;
Total portals planned: 1,205;
Status: 24 months late.
Portal monitor deployment phase: Retrofits[B];
Total portals planned: 82[C];
Status: Projected September 2009 completion.
Portal monitor deployment phase: Other sites[D];
Total portals planned: 3.
Portal monitor deployment phase: Excess equipment[E];
Total portals planned: 721.
Portal monitor deployment phase: Total;
Total portals planned: 3,035[F].
Sources: PNNL and CBP.
[A] Excludes FedEx and UPS, both of whom screen packages overseas as
agreed in a memorandum of understanding with CBP.
[B] "Retrofitting" refers to replacing currently-fielded portal
monitors with advanced-technology portal monitors.
[C] PNNL plans a "net" increase of 82 portal monitors as a result of
retrofits.
[D] "Other sites" refers to portal monitors installed at the Nevada
Test Site for testing purposes.
[E] "Excess equipment" refers to the older portal monitors being
replaced through the retrofit process.
[F] The total number of portal monitors planned for deployment is based
on December 2005 estimates from CBP and PNNL. It represents a recent
estimate of CBP's requirements, and according to CBP, it will be used
to update the agency's current deployment plan, which calls for
deploying 2,397 portal monitors by September 2009.
[End of table]
Further, we analyzed CBP's earned value management data as of November
2005 and determined that, although CBP planned for the deployment
program to be 20.5 percent complete by that date, the program is only
about 16 percent complete. In addition, our analysis indicates that
since the program's inception, work valued at $48.6 million has fallen
behind schedule. Moreover, the trend over the past 14 months shows CBP
and PNNL falling further behind schedule, as seen in figure 1.
Figure 1: Monthly Cumulative Values of Work Planned but Not Finished As
Planned:
[See PDF for image]
Note: The "zeropoint" on this figure denotes work that was completed at
its planned cost. A positive number means that all the work completed
to that point costs less than planned, while a negative number means
that all the work completed to that point costs more than planned.
[End of figure]
There have been at least three major sources of delay that have
affected the portal monitor deployment program: funding issues,
negotiations with seaport terminal operators, and problems in screening
rail cars--particularly in a seaport environment.
Funding Issues:
According to CBP and PNNL officials, recurrent difficulties with the
project's funding are the most important explanations of the schedule
delays. Specifically, according to DHS and PNNL officials, CBP has been
chronically late in providing appropriated funds to PNNL, thereby
hindering its ability to meet program deployment goals. For example,
PNNL did not receive its fiscal year 2005 funding until September 2005.
According to PNNL officials, because of this delay, some contracting
activities in all deployment phases had to be delayed or halted, but
the adverse effects on seaports were especially severe. For example,
PNNL reported in August 2005 that site preparation work at 13 seaports
had to cease because the Laboratory had not yet received its fiscal
year 2005 funding allocation. According to senior CBP officials, their
agency's inability to provide a timely spending plan to the Congress
for the portal monitor deployment program is the main reason for these
funding delays. According to the House Appropriations Committee report
on the CBP portion of DHS's fiscal year 2005 budget, CBP should provide
the Congress an acquisition and deployment plan for the portal monitor
program prior to funding PNNL.[Footnote 14] However, these plans
typically take many months for CBP to finalize--in part because CBP
requires that the plans undergo several levels of review--but also
because these plans are reviewed by DHS and OMB before being submitted
to the Congress. In fiscal year 2005, this process was further delayed
by the creation of DNDO, uncertainty regarding DNDO's responsibilities,
and negotiations regarding the expenditure of the fiscal year 2005
appropriations.
CBP has tried to address this problem by reprogramming funds when money
from other programs is available. In some cases, the amount of
reprogrammed funds has been fairly large. For example, about 15 percent
of fiscal year 2005's funding included money reprogrammed from other
CBP sources, or almost $14 million. In fiscal year 2004, about $16
million was reprogrammed--or about a third of the fiscal year's total.
And in fiscal year 2003, the total of reprogrammed money was about $18
million--about 20 percent.
Delays in Gaining Agreements Have Slowed Seaport Deployments:
Negotiations with seaport operators have been slow and have also
delayed the portal monitor deployment program. According to CBP and
PNNL officials, one of the primary reasons behind the seaport phase's
substantial delay in deployments is the difficulty in obtaining
contractual agreements with port and terminal operators at seaports.
DHS has not attempted to impose agreements on seaport operators
because, according to officials, cooperative arrangements with the port
operators are more efficient and, in the long term, probably more
timely. According to CBP and PNNL officials, many operators believe
screening for radiation will adversely affect the flow of commerce
through their ports. In addition, deploying portal monitors in major
seaports presents several unique challenges. For example, seaports are
much larger than land border crossings, consist of multiple terminals,
and may have multiple exits. Because of these multiple exits, seaports
require a greater number of portal monitors, which may entail more
negotiations with port and terminal operators. In addition, port
operators at times have insisted on late-stage design changes,
requested various studies prior to proceeding with final designs,
insisted on inefficient construction schedules, and delayed their final
review and approval of project designs. According to CBP and PNNL,
these efforts often reflect the port and terminal operators' uneasiness
with portal monitor deployments, and their resolve to ensure that the
outcome of the deployment process maintains their businesses'
competitiveness. For example, port officials at one seaport requested
several changes late in the process, including performing an
unscheduled survey for laying cable, revising portal monitor locations
at two gates, and adding a CBP control booth at a third terminal.
According to CBP and PNNL officials, the agency prefers to accommodate
these types of changes, even late in the process and even if they slow
deployment, because in the long term they believe it is more efficient
and effective.
Screening Rail Cars in Seaports Presents Unique Problems:
The difficulty of devising an effective and efficient way to conduct
secondary inspections of rail traffic departing seaports without
disrupting commerce has created operational issues that could further
delay deployments. Four of the five seaports we visited employ rail
cars to ship significant amounts of cargo. In one seaport, the port
director estimated that about 80-85 percent of the cargo shipped
through his port departs via rail. For the other three seaports, the
percentages for rail traffic were 5 percent, 13 percent, and 40 percent
respectively. According to port officials, these seaports would like to
accommodate CBP's efforts to install radiation detection equipment
designed to screen rail traffic, but they are concerned that the
logistics of conducting secondary inspections on trains as they prepare
to depart the seaport could back up rail traffic within the port and
disrupt rail schedules throughout the region--potentially costing the
port tens of thousands of dollars in lost revenue. For example, one
senior port authority official told us that his port lacked ample space
to park trains for secondary inspections, or to maneuver trains to
decouple the rail car(s) that may have caused a primary inspection
alarm. As a result, trains that cause a primary alarm would have to
wait, in place, for CBP to conduct a secondary inspection, blocking any
other trains from leaving the port. According to this port official,
any delay whatsoever with a train leaving the port could cause rail
problems down the line because track switches are geared to train
schedules. To avoid these kinds of problems, CBP has delayed deploying
portal monitors in this seaport until technical and operational issues
can be overcome. As of December 2005, no portal monitors had been
deployed at this seaport, although according to PNNL's schedule, 5 of
its 11 terminals--a total of 19 portal monitors--should have been
deployed by October 2005. According to the port director at another
seaport we visited, a port that actually has a rail portal monitor
installed, similar operational issues exist. However, in addition to
backing up rail traffic within the port, trains awaiting secondary
inspections at this port could block the entrance/exit to a nearby
military base. The director of the state's port authority told us that
his solution has been to simply turn off the portal monitor. According
to CBP officials, this was entirely a state decision, since this portal
monitor is the state's responsibility and not part of CBP's deployment.
However, these officials also noted that they agreed with the states
and noted that they would not attempt to impose a solution or deadline
on either port. CBP officials noted that most seaport operators seem
willing to accommodate portal monitors, but until a better portal
monitor technology evolves that can help ensure a smooth flow of rail
traffic out of the port, negotiations with seaport operators will
continue to be slow.
According to CBP and port officials, they have considered several
potential solutions. For example, there is widespread agreement that
screening sea cargo containers before they are placed on rail cars
offers the best solution, but this option is operationally difficult in
many seaports. Mobile portal monitors, when commercially available, may
also offer a partial solution. In addition, CBP is optimistic that
advanced portal monitors, when they become commercially available, may
help solve some of the problems in the rail environment by limiting the
number of nuisance alarms. However, according to the CBP and port
officials we contacted, screening rail traffic continues to pose a
vexing operational problem for seaports.
The concerns that seaport operators and CBP expressed regarding
screening rail commerce in seaports may increase and intensify in the
future because rail traffic, in general, is expected to increase
substantially by 2020. DOT has forecast that by 2020, rail will
transport roughly 699 million tons of international freight--up from
358 million tons carried in 1998. Officials at 3 of the 5 seaports we
visited expect rail traffic through their facilities to increase
dramatically during the next 10 to 15 years. As the volume of trade
increases, so too will the economic stakes for the port and terminal
operators, while the regulatory burden for CBP is likely to increase as
well. Delays--for any reason, including radiation detection--are likely
to become more costly, and CBP will likely have ever-increasing numbers
of rail cars to screen.
In addition, although CBP is not scheduled to begin deploying portal
monitors to screen rail shipments at land border crossings until 2007,
the agency will likely experience operational challenges at land border
crossing similar to those it is now experiencing at seaports. For
example, at both land border crossings and seaports, if a rail car
alarms as it passes through a portal monitor, that car will possibly
have to be separated from the remaining train--sometimes a mile in
length--to undergo a secondary inspection. Furthermore, because trains
transport numerous types of cargo containing large quantities of
naturally occurring radioactive material, CBP faces the challenge of
maintaining a nuisance alarm rate that does not adversely affect
commerce. CBP and PNNL are currently conducting testing of a prototype
rail portal monitor to determine the potential impact of naturally
occurring radioactive material on rail operations at land border
crossings.
Other Factors Have Delayed Portal Monitor Deployments:
Unforeseen design and construction problems have also played a role in
delaying portal monitor deployments. For example, deployments at six
southern border sites have been delayed to coincide with the sites'
expansion activities. According to CBP officials, there are two
approaches to accommodating a port-of-entry's alterations, both of
which may delay portal monitor deployments. First, CBP and PNNL may
decide to delay the start of portal monitor projects until the port-of-
entry completes its alterations, to make certain that portal monitor
placements are properly located. Second, port-of-entry expansion
activities may alter existing traffic flows and require that PNNL
redesign its portal monitor deployments. The portal monitor deployments
at three southern border ports-of-entry has taken much longer than
planned because of the port's expansion activities. According to PNNL,
there is now considerable schedule uncertainty associated with these
deployments, which may ultimately impact the completion of the southern
land border deployments.
Portal monitor deployments have also been hampered by poor weather. For
example, cold weather at several northern sites caused some unexpected
work stoppages and equipment failures that resulted in construction
delays of 2 to 3 months. Finally, one southern border site has been
delayed because of major flooding problems. The flooding issue must be
resolved before the deployment can be completed.
DHS's Portal Monitor Deployment Program Cost Estimate Is Uncertain and
Overly Optimistic:
DHS's current estimate to complete the program is $1.3 billion, but
this estimate is highly uncertain and overly optimistic. First, DHS's
cost estimate is based on a plan to deploy advanced-technology portal
monitors that have so far shown mixed results for detecting radiation
compared to currently-fielded portal monitors. Since the efficacy of
the advanced portal monitors has not yet been proven conclusively,
there is at least some uncertainty over whether--and, if so, how many-
-of the new portal monitors may be deployed. In addition, the final
cost of the new portal monitors has not been established. Second, our
analysis of CBP's earned value data also suggests that the program will
likely cost much more than planned.
The current deployment plan calls for installing advanced portal
monitors at all cargo primary and secondary inspection locations, at
all secondary inspection locations for private vehicles, and also
retrofitting many sites with the advanced equipment, when it becomes
available. However, according to senior officials at DNDO, the advanced
technology must meet all of DNDO's performance criteria, and must be
proven superior to the portal monitors already in use, before DNDO will
procure it for use in the United States. Recent tests of the new portal
monitors indicate that DNDO's criteria have not yet been met. For
example, S&T sponsored research in 2004 that compared the detection
capabilities of currently-fielded portal monitors with the advanced
portal monitors. The results of that research suggested that, in some
scenarios, the detection abilities of the two portal monitor types were
nearly equivalent. In other scenarios, the new equipment's detection
capability was significantly better. S&T concluded that more work
remains to be done in optimizing and comparing portal monitors so as to
understand how they can be used to the greatest effect at U.S. ports-
of-entry. In 2005, DNDO sponsored additional research designed to
compare the two types of portal monitor, and determined that the
advanced portal monitors' detection capabilities were somewhat better
than those of the currently-fielded equipment. In addition, in October
2005, DNDO completed the first comprehensive tests for these advanced
portal monitors at the Nevada Test Site. This advanced technology
combines the ability to detect radiation and identify its source.
According to an official who helped supervise these tests, the new
portal monitors' performance did not meet all of DNDO's expectations
with regard to providing significant detection improvements over
currently-fielded equipment in all scenarios. CBP and DNDO officials
also expressed concerns regarding the advanced portal monitors'
detection capabilities in light of the Nevada test results. In
particular, senior CBP officials questioned whether the advanced portal
monitors would be worth their considerable extra costs, and emphasized
finding the right mix of current and advanced-technology equipment
based on the needs at individual ports-of-entry. According to DNDO
officials, the potential improvement over currently fielded portal
monitors in capability to identify radioactive sources, and hence to
detect actual threats as opposed to simply detecting radiation, has not
yet been quantified. However, these officials believe that the results
to date have been promising, and DNDO intends to continue supporting
the advanced portal monitor's development and believe the new
technology may be ready for deployment early in calendar year 2007.
There is also considerable uncertainty regarding the eventual cost of
the advanced portal monitors--if they become commercially available,
and if DNDO opts to use them. Experts we contacted estimated that the
new portal monitors could cost between $330,000 and $460,000 each.
These estimates are highly uncertain because advanced portal monitors
are not yet commercially available. As a point of reference, the portal
monitors currently in use typically cost between $49,000 and $60,000.
These costs include only the purchase price of the equipment, not its
installation. According to CBP and PNNL officials, installation costs
vary, but average about $200,000 per portal monitor. Even if future
test results indicate that the new technology exhibits much better
detection and identification capabilities, it would not be clear that
the dramatically higher cost for this new equipment would be worth the
considerable investment, without the agency having first rigorously
compared the portal monitors' capabilities taking their costs into
account. Currently, DNDO and CBP are working together to determine the
most appropriate technologies and concepts of operation for each port-
of-entry site. The two agencies are also trying to determine the
highest priority sites for advanced-technology portal monitors based on
the extent to which the new portal monitors show improved performance.
In November 2005, PNNL reported that the portal monitor deployment
program could experience an overall cost overrun of $36 million. In
contrast, our analysis of CBP's earned value data indicates that the
agency should expect a cost overrun of between $88 million and $596
million. We based our cost overrun projections on the rates at which
CBP and PNNL deployed portal monitors, through November 2005. The more
efficient the agency and its contractor are in deploying portal
monitors, the smaller the cost overruns; conversely, when efficiency
declines, cost overruns increase.[Footnote 15]
In fact, as shown in figure 2, recent cumulative program cost trends
have been negative, indicating that CBP's cost overruns are deepening
over time.
Figure 2: Monthly Cumulative Cost Overruns:
[See PDF for image]
Note: The "zero point" on this figure denotes work that was completed
at its planned cost. A positive number means that all the work
completed to that point costs less than planned, while a negative
number means that all the work completed to that point costs more than
planned.
[End of figure]
PNNL noted that its management reserve of $62 million should cover the
anticipated overrun. However, we do not agree.[Footnote 16] First, we
believe the cumulative cost overrun will far exceed PNNL's estimate of
$36 million. We believe an overrun of about $342 million, the midpoint
of our projected overrun range, is more likely. Since 1977, we have
analyzed over 700 acquisition projects on which EVM techniques have
been applied. These analyses consistently show that once a program is
15 percent complete (as is the case with this program), cost
performance almost never improves and, in most cases, declines. PNNL's
recent cost trend follows this pattern. Second, based on these 700-plus
studies, our estimate takes a more realistic view that the portal
monitor deployment program's cost performance most likely will continue
to decline; hence the management reserve will be consumed over time as
the program incurs unexpected expenses. Finally, to meet the deployment
program's planned costs, PNNL would have to greatly improve its work
efficiency. However, our analysis of prior EVM-based projects indicates
that productivity rates nearly always decline over the course of a
project. We determined that PNNL's efficiency rate for the most recent
8 months has averaged about 86 percent--PNNL has been delivering about
$.86 worth of work for every dollar spent. In order to complete the
remaining work with available funding, PNNL's efficiency rate would
have to climb to around 98 percent, a rate of improvement unprecedented
in the 700-plus studies we have analyzed.
CBP Does Not Know If PNNL's Cost and Schedule Data Are Reliable:
Federal agencies are required by OMB to track the progress of major
systems acquisitions using a validated EVM system and to conduct an
integrated baseline review.[Footnote 17] We found that PNNL has an EVM
system but has not certified it to show that it complies with guidance
developed by the American National Standards Institute/Electronic
Industries Alliance.[Footnote 18] This guidance identifies 32 criteria
that reliable EVM systems should meet. In addition, we found that PNNL
has not conducted an integrated baseline review--a necessary step to
ensure that the EVM baseline for the portal monitor program represents
all work to be completed, and adequate resources are available.
However, although the EVM data have not been independently validated,
we examined the EVM data and found that they did not show any anomalies
and were very detailed. Therefore, we used them to analyze the portal
monitor program status and to make independent projections of the
program's final costs at completion.
CBP Officers Have Made Progress in Using Radiation Detection Equipment
Correctly and Adhering to Inspection Guidelines, but There Are
Potential Issues with Agency Procedures:
CBP officers we observed conducting primary and secondary inspections
appeared to use radiation detection equipment correctly and to follow
the agency's inspection procedures. In fact, in some cases, CBP
officers exceeded standard inspection procedure requirements by opening
and entering containers to better identify radiation sources. In
contrast, in 2003, when we issued our last report on domestic radiation
detection, CBP officers sometimes deviated from standard inspection
procedures and, at times, used detection equipment incorrectly.
However, the agency's inspection procedures could be strengthened.
CBP Officers Appeared to Use Equipment Correctly and Follow Procedures:
During this review, at the 10 ports-of-entry that we visited, the CBP
officers we observed conducting primary and secondary inspections
appeared to follow inspection procedures and to use radiation detection
equipment correctly. The officers' current proficiency in these areas
follows increases in training and in CBP's experience using the
detection equipment. In contrast, in 2003 we reported that CBP officers
sometimes used radiation detection equipment in ways that reduced its
effectiveness.
CBP has increased the number of its officers trained to use radiation
detection equipment; in fact, the agency now requires that officers
receive training before they operate radiation detection equipment. As
of February 2006, CBP had trained 6,410 officers to use radiation
isotope identification devices, 8,461 to use portal monitors, and
22,180 to use pagers. Many CBP officers received training on more than
one piece of equipment and about 900 have since left the agency.
Generally, today CBP officers receive radiation detection training from
4 sources: the CBP Academy in Glynco, Georgia; the Border Patrol
Academy in Artesia, New Mexico; a DOE-sponsored 3-day training course
for interdicting weapons of mass destruction, in Washington state; and
on-the-job training at ports-of-entry. Training at the Academies in
Georgia and New Mexico includes formal classroom instruction, as well
as hands-on exercises on how to use portal monitors, isotope
identifiers, and pagers. This training includes simulated scenarios in
which officers use radiation detection equipment to conduct searches
for nuclear and radiological materials. On-the-job instruction
continues at field locations as senior CBP officers, as well as PNNL
and other DHS contractor staff, work closely with inexperienced
officers to provide them with practical training on how the radiation
detection equipment works and how to respond to alarms. According to
senior CBP officials, all of the instructors that offer training on
using radiation detection equipment are certified in its use. Trainees
must demonstrate proficiency in the use of each system prior to
assuming full responsibility for radiation detection inspections. About
1,600 CBP officers have participated in DOE's 3-day training course
designed to acquaint CBP officers with detection equipment. CBP is
currently developing refresher training courses on the use of radiation
detection equipment. To further enhance officers' ability to
effectively respond to real or potential threats, several of the field
locations that we visited conduct "table-top exercises" that simulate
scenarios in which the equipment detects an illicit radiological
source.
According to several of the CBP field supervisors we contacted, many
officers have gained proficiency in following procedures and using
radiation detection equipment through substantial field experience
responding to alarms. The number of alarms officers typically handle
varies according to the size of the site, its location, and type. For
example, an isolated land border site would probably experience fewer
alarms than a major seaport because of the differences in the volume of
traffic. However, it was common for several of the locations we visited
to experience 15 to 60 alarms per day. One seaport we visited had 9
terminals, usually with 2 primary and 1 secondary portal monitors.
According to CBP officials, each terminal recorded about 8 to 12 alarms
per day. The director of port security for a major eastern seaport we
visited estimated that her facility records roughly 150 portal monitor
alarms each day. Virtually all have been nuisance alarms, but CBP
officials still believe they gained valuable experience in using the
equipment and following procedures.
All of the primary and secondary inspections we witnessed were nuisance
alarms. In all of these cases except one, officers followed CBP's
guidance--as well as local variations meant to address issues unique to
the area--and correctly used detection equipment. The lone exception
occurred at a site whose primary inspection station was staffed by a
state port police officer. After the station's portal monitor
registered an alarm for a truck departing the site, the police officer
did not follow CBP's procedures.[Footnote 19] For example, he did not
collect any documentation from the driver. At all other sites we
visited, when a primary portal monitor sounded, CBP officers gathered
the cargo's manifest, the vehicle registration, and the driver's
license prior to sending the vehicle through secondary inspection.
Officers use these documents to check the driver and vehicle cargo. The
port police officer told us that he recognized the driver in this case,
and so the officer did not believe it was necessary to collect such
information. A CBP officer performed the secondary inspection in line
with agency guidance. In fact, after using a radiation isotope
identification device to conduct an external inspection and determine
the source of the alarm--potassium hydroxide--the officer required that
the driver open the back of the truck so she could make a visual check
of the cargo. From the time of the initial alarm, until the truck
departed the site boundary, about 35 minutes elapsed. According to port
and CBP officials, this particular alarm, its resolution, and the
amount of time it took to resolve are typical of the site. We also
discussed the site's radiation detection efforts with the truck driver,
in particular the delay associated with this alarm. He noted that he
considers the delays experienced at this site to be relatively minor,
and that the delays have not had any adverse effects on his business.
We also visited a seaport that experienced a legitimate alarm in which
CBP officers used the detection equipment correctly and responded
according to procedures. Uranium hexafluoride, a potentially hazardous
chemical containing low levels of radioactivity, caused this alarm. A
primary portal monitor at the seaport sounded as a truck carrying one
container attempted to exit a terminal. Following standard operating
procedures, the truck was diverted to a secondary inspection station,
where a secondary portal monitor also alarmed. A CBP officer then
scanned the container and cab of the truck with an isotope identifier,
which indicated that the radiation source was located in the cab within
several metal pails. The isotope identifier identified two radiation
sources, one of which was uranium-235--potentially a weapons-usable
material. The other source was uranium-238. Again following procedures,
CBP officers isolated the sources of radiation and provided LSS
scientists with information collected by the isotope identifier.
Officers also reviewed the driver's delivery papers; used various CBP
databases to check the driver, importer, and consignee's history of
transporting goods; and contacted the driver's dispatcher and the U.S.
consignee to gather information on and assess the legitimacy of the
shipment. The consignee explained that the pails contained trace
amounts of uranium hexafluoride that had been sent to the company's
laboratory for testing. Following additional investigation, which
included an X-ray of the pails and a review of DOT requirements
regarding radiation-warning placard requirements, CBP determined that
the event was not a security threat and released the driver and
conveyance. Senior officials at this seaport told us that CBP's
radiation detection guidance served as an effective and successful
guide to resolving this alarm.
Potential Issues in CBP's Inspection Procedures Could Be Mitigated to
Improve Detection Capabilities:
We identified two potential issues in CBP's national inspection
procedures that could increase the nation's vulnerability to nuclear
smuggling. The first potential issue involves NRC documentation.
Generally, NRC requires that importers obtain an NRC license for their
legitimate shipments of radiological materials into the United
States.[Footnote 20] However, NRC regulations do not require that the
license accompany the shipment, although in some cases importers choose
to voluntarily include the license. According to CBP officials, CBP
lacks access to NRC license data that could be used to verify that
importers actually acquired the necessary licenses or to authenticate a
license at the border. At present, CBP officers employ a variety of
investigative techniques to try to determine if individuals or
organizations are authorized to transport a radiological shipment. For
example, CBP officers review their entry paperwork, such as shipping
papers. Officers also often interview drivers about the details of the
delivery and observe their behavior for any suspicious or unusual
signs. At one land border crossing we visited, officers told us that
frequent and legitimate shippers of radiological material provide
advance notice that a radiological shipment will be transported. This
can lead to law enforcement personnel being called in to escort the
shipment through the port-of-entry.
The second potential issue pertains to CBP's secondary inspection
guidelines. Generally, CBP's guidelines require that CBP officers
locate, isolate, and identify the radiation source(s) identified during
primary inspections. Customarily, officers use a radiation isotope
identification device to perform an external examination of cargo
containers in these situations. (See fig. 3.) However, the
effectiveness of a radiation isotope identification device is
diminished as its distance from the radioactive source increases, and
by the thickness of the metal container housing the radioactive source.
As a result, secondary inspections that rely solely on external
examinations may not always be able to locate, isolate, and identify an
illicit shipment of nuclear material.
Figure 3: CBP Officers Conducting an External Secondary Inspection at a
Seaport:
[See PDF for image]
[End of figure]
The local procedures at some ports-of-entry we visited go beyond the
requirements established by CBP's guidelines by having CBP officers
open and, if necessary, enter containers when conducting secondary
inspections. (See fig. 4.) For example, at one high-volume seaport we
visited, the local inspection procedures require officers to open and,
if necessary, enter a container to locate and identify a radiological
source if an external examination with an isotope identifier is unable
to do so. Under such circumstances, the port's procedures require the
officer to open the container doors, locate the source, and obtain
another reading as close to the source as possible. By entering the
container, an officer may be able to reduce the isotope identifier's
distance from the radioactive source, and thus obtain a more accurate
reading. If the isotope identifier is unable to detect and identify the
source after two readings within the container, officers must contact
LSS for further guidance. Officers at this seaport have opened
containers in the past when the isotope identifier had been unable to
detect naturally occurring radioactive material, such as granite or
ceramic tile, which is low in radioactive emissions. CBP supervisors at
this seaport said that this occurs infrequently and that it adds a very
minimal amount of time to the inspection process. In addition, at a
land border crossing we visited, the local standard operating
procedures instruct CBP officers to conduct a physical examination on
vehicles that alarm for the presence of radiation. Officials at this
particular port-of-entry said that they have entered vehicles with an
isotope identifier when the device has been unable to detect or
identify the radioactive source from vehicles' exterior. During a
physical examination, officers are supposed to open the vehicle and
look for high-density materials, such as lead or steel, which can be
used to shield gamma radiation and solid objects with large quantities
of liquid that could be used to shield neutron radiation. Because the
majority of alarms at this land border crossing are caused by medical
isotopes in people, CBP officers physically inspect vehicles on an
infrequent basis.
Figure 4: A CBP Officer Entering a Cargo Container During a Secondary
Inspection at a Seaport:
[See PDF for image]
[End of figure]
Finally, we also visited a land border crossing where CBP officers
routinely open and enter commercial trucks to conduct secondary
inspections, even though the site's local procedures do not require
this additional examination. Officials at this port said that they open
up containers to verify that the container's manifest and reading from
the isotope identifier are consistent with the container's load. If
they are not consistent, CBP officers are supposed to contact LSS for
further guidance. During our visit, we observed a truck that alarmed at
primary and secondary portal monitors. CBP officers then required the
driver to park at a loading dock, where officers first used an isotope
identifier to screen the truck from the outside; the reading from the
isotope identifier was inconclusive, however. Officers then opened and
entered the container with an isotope identifier, conducted a second
reading of the radioactive source, and determined that the material
inside the container was a non-threatening radioactive source that
matched the manifest. A CBP supervisor released the truck. This
inspection, from the time of the original alarm to the truck's release
took about 25 minutes--slightly greater than the 20-minute average for
this site. According to CBP supervisors, officers at this port-of-entry
follow this practice routinely, even during the site's peak hours. This
approach enables the officers to get closer to the source and obtain a
more accurate reading. Furthermore, since this practice enables
officers to conduct a more thorough examination of the containers'
contents, it may increase the likelihood that CBP officers will find
any illicit radioactive material. According to senior CBP officials at
this port-of-entry, despite being implemented at one of the busiest
commercial ports-of-entry in the nation, this additional procedure has
had little negative impact on the flow of commerce and has not
increased the cost of CBP inspections.
DHS Is Working to Improve the Capabilities of Currently-fielded and New
Radiation Detection Equipment, but Much Work Remains to Achieve Better
Equipment Performance:
DHS has managed research, development, and testing activities that
attempt to address the inherent limitations of currently-fielded
radiation detection equipment and to produce new, advanced technologies
with even greater detection capabilities. DHS is enhancing its ability
to test detection equipment by building a new test facility at DOE's
Nevada Test Site. In addition, DHS tests radiation detection equipment
under real-life conditions at S&T's CMTB in New York and New Jersey.
However, much work remains for the agency to achieve consistently
better detection capabilities, as the efforts undertaken so far have
achieved only mixed results.
Currently-fielded Radiation Detection Equipment Has Inherent
Limitations:
Currently-fielded radiation portal monitors have two main limitations.
First, they are limited by the physical properties of the radiation
they are designed to detect, specifically with regard to the range of
detection (some radioactive material emits more radiation than others).
Further, this limitation can be exacerbated because sufficient amounts
of high-density materials, such as lead or steel, can shield radiation
emissions to prevent their detection. Second, currently-fielded portal
monitors cannot distinguish between different types of radioactive
materials, i.e., they cannot differentiate naturally occurring
radioactive material from radiological threat materials. CBP officers
are required to conduct secondary inspections on all portal monitor
alarms, including nuisance alarms. According to the CBP field
supervisors with whom we spoke, nuisance alarms comprise almost all of
the radiation alerts at their ports-of-entry. Port operators noted a
concern that nuisance alarms might become so numerous that commerce
could be impeded, but thus far these alarms have not greatly slowed the
flow of commerce through their ports-of-entry.
CBP's currently-fielded radiation isotope identification devices also
have inherent limitations. For example, during some secondary
inspections, radiation isotope identification devices are unable to
identify radiological material. In these cases, CBP standard procedures
require that officers consult LSS to conclusively identify the source.
According to CBP officers at two of the ports we visited, this usually
lengthens secondary inspections by 20 to 30 minutes, although in some
cases an hour or more was needed to resolve the alarm. Furthermore, a
2003 Los Alamos National Laboratory evaluation of seven isotope
identifiers, including the one deployed by CBP, concluded that all
devices had difficulty recognizing radioactive material and correctly
identifying the material they did recognize. The Los Alamos finding is
consistent with our field observations, as CBP officers at several of
the ports-of-entry we visited reported similar trouble with their
radiation isotope identification devices.
Laboratory testing of currently-fielded radiation detection equipment
has further demonstrated their limitations in effectively detecting and
identifying nuclear material. For example, in February 2005, DHS
sponsored testing of commercially available portal monitors, isotope
identifiers, and pagers against criteria set out in American National
Standards Institute (ANSI) standards. The ANSI standards provide
performance specifications and test methods for testing radiation
detection equipment, including portal monitors and handheld devices.
The actual testing was performed by four DOE laboratories, with
coordination, technical management, and data evaluation provided by the
Department of Commerce's National Institute for Standards and
Technology (NIST). The laboratories tested a total of 14 portal
monitors from 8 manufacturers against 29 performance requirements in
the ANSI standards. Overall, none of the radiation detection equipment,
including the portal monitors and handheld devices deployed by CBP, met
all of the performance requirements in this first round of testing.
However, according to S&T officials, many of the limitations noted in
CBP's equipment were related to withstanding environmental conditions-
-not radiation detection or isotope identification. However, in some
tests, the portal monitors that CBP employs, along with many others,
exhibited poor results. For example, in tests conducted to evaluate the
portal monitors' response to neutron radiation, of which plutonium is a
primary source, almost all monitors, including a portal monitor fielded
by CBP, failed to meet the ANSI requirement. However, according to S&T
officials, the test was conducted using the manufacturer's standard
configuration, rather than the configuration CBP uses in its field
operations. In another test, one that used CBP's typical field
parameters rather than the manufacturer's, the portal monitor passed
all the radiation detection performance requirements. S&T believes that
the portals used by CBP would meet all the radiation performance
requirements if set up with the parameters and configuration as used in
the field. In addition, isotope identifiers displayed weaknesses. For
example, the isotope identifier currently in use by CBP was not able to
simultaneously identify two different isotopes, as required by the ANSI
standards. When tested with barium-133 and plutonium-239, the isotope
identifier was able to recognize the barium but failed to recognize the
plutonium--a weapons-grade nuclear material. As this was a first round
of testing and modifications were made to both the standards and
testing protocols after the procedures were completed, NIST plans to
manage testing of the equipment again in early 2006. The results from
both rounds of testing are intended to provide guidance for federal,
state, and local officials in evaluating and purchasing radiation
detection equipment, and to enable manufacturers to improve their
equipment's performance.
DHS Has Sponsored Research and Development to Improve the Capabilities
of Current Technology and to Develop New Technology but Much Work
Remains:
DHS has sponsored research efforts designed to improve the detection
capabilities of the currently-fielded portal monitors and to provide
them with the ability to distinguish radiological sources. For example,
PNNL researched, developed, and tested a new software--known as "energy
windowing"--to address the currently-fielded portal monitors' inability
to distinguish between radiological materials. Energy- windowing is
supposed to identify and screen out material, such as fertilizer or
kitty litter, that cause nuisance alarms and thereby reduce the number
of such alarms at cargo screening facilities, while also improving the
portal monitor's sensitivity to identify nuclear material of concern.
PNNL has activated energy-windowing on the 556 portal monitors it has
deployed at land border crossings and seaports. At a few ports-of-entry
that we visited, CBP officials said that the software has been
effective in significantly reducing the number of nuisance alarms.
However, tests of the software have shown that its effectiveness in
reducing nuisance alarms largely depends on the types of radiation
sources it has been programmed to detect and differentiate. In tests
involving some common, unshielded radiation sources, such as cobalt-57
and barium-153, the new software has shown improved detection and
discrimination capabilities. However, during scenarios that target
other common, shielded threat sources--such as those that might be used
in a shielded radiological dispersal device or nuclear weapon--the
software has been less able to detect and discriminate. Experts have
recommended further testing to fully explore the software's
capabilities.
DHS is also sponsoring the development of three new technologies that
are designed to address the main inherent limitations of currently-
fielded portal monitors. CBP's deployment plan currently calls for the
widespread installation of the first of these technologies, "advanced
spectroscopic portal monitors." According to DNDO, the advanced
spectroscopic technology uses different detection materials that are
capable of both detecting the presence of radiation and identifying the
isotope causing the alarm. It is hoped that the spectroscopic portal
monitor can more quickly identify the sources of alarms, thereby
reducing the number of nuisance alarms. This increased operational
effectiveness may allow the portal monitors to be set at a lower
detection threshold, thus allowing for greater sensitivity to materials
of concern. DHS commissioned PNNL to determine whether spectroscopic
portal monitors provide improved performance capabilities over the
currently-fielded monitors. In July 2004 and July 2005, PNNL conducted
two small-scale preliminary studies to compare the two types of portal
monitors in side-by-side tests using shielded and unshielded
radioactive materials. In the first test, PNNL concluded that the
relative performance of spectroscopic and currently-fielded portal
monitors is highly dependent on variables such as the radioactive
sources being targeted and the analytic methods being used. The results
of these tests were mixed. In some situations, spectroscopic portal
monitors outperformed the current technology; in other cases, they
performed equally well. In the second test, PNNL concluded that the
spectroscopic monitor's ability to detect the shielded threat sources
was equal to, but no better than, those of the currently-fielded portal
monitors. However, because spectroscopic portal monitors have the
ability to identify isotopes, they produced fewer nuisance alarms than
the current portal monitors. PNNL noted that because the studies were
limited in scope, more testing is needed.
In October 2005, DNDO completed the first round of comprehensive
testing of spectroscopic portal monitors at its testbed at the Nevada
Test Site. DNDO tested 10 spectroscopic portal monitors against 3
currently-fielded monitors in 7,000 test runs involving the portal
monitors' ability to detect a variety of radiological materials under
many different cargo configurations. According to senior DNDO officials
who supervised these tests, preliminary analysis of test data indicates
that the spectroscopic portal monitors' performance demonstrated
somewhat mixed results. Spectroscopic portal monitors outperformed
currently-fielded equipment in detecting numerous small, medium-sized,
and threat-like radioactive objects, and were able to identify and
dismiss most naturally occurring radioactive material. However, as the
amount of source material declined in size, the detection capabilities
of both types of portal monitors converged. Because the data produced
by the test runs is voluminous and complex, NIST and another contractor
are still in the process of analyzing the test data and plan to produce
a report summarizing the results of the testing in 2006. DNDO received
responses to the Advanced Spectroscopic Portal Request for Proposal in
February 2006, and intends to use the data from the Nevada Test Site to
help evaluate these responses. In fiscal year 2006, DNDO also intends
to award contracts to two or three manufacturers for further
engineering development and production.
The second new technology is "high-Z detection," which is designed to
better detect high atomic number (high-Z) materials--such as Special
Nuclear Material (SNM)--and shielding materials--such as lead--that
could be used to shield gamma radiation from portal monitors. The Cargo
Advanced Automated Radiography System (CAARS) program within DNDO is
intended to develop the technologies necessary for automated detection
of high-Z material. DNDO envisions using the advanced portal monitor
technology for the detection of lightly shielded nuclear threats and
radiological dispersal devices, and using CAARS technology for the
detection of high-Z materials.
The third new technology is "active interrogation," which is designed
to better detect nuclear material, especially shielded sources, and
DNDO expects it to play a role further in the future than advanced
portal monitors and CAARS. DHS and DOE are supporting research at DOE
national laboratories, such as Los Alamos and Lawrence Livermore, to
develop these systems. Active interrogation systems probe or
"interrogate" containers with neutron or gamma rays to induce
additional radiation emissions from radioactive material within the
container. According to DNDO, these systems are too large and costly to
consider for current use. In addition, because these systems emit
radiation, care will have to be taken to ensure personnel safety before
any deployments are made.
In addition to these relatively near-term research and development
efforts, DNDO intends to solicit proposals from private, public,
academic, and federally funded research centers to pursue radiation
detection projects with a more long-term orientation. The solicitation
identifies five areas of research:
* mobile detection systems that can be used to detect potential
radiological threats that are in transit, at fixed locations, and at
special events;
* detection systems that can be integrated into ships, trucks, planes,
or into containers;
* active detection technologies, including portal monitors and handheld
devices that can detect and verify the presence of shielded nuclear
materials;
* innovative detector materials that provide improved detection and
isotope identification capabilities over existing materials, in
addition to technologies that lead to reductions in the costs to
manufacture detector materials, increasing the size and choice of the
shapes of detector materials without a loss in performance; and:
* alternate means to detect and identify nuclear material other than
through radiation detection such as mass, density, or temperature.
DHS Sponsors Test Facilities in Nevada, New York, and New Jersey to
Support Efforts to Improve Detection Capabilities:
DHS is testing commercially available portal monitors, advanced portal
monitors, and handheld devices at its new Radiological and Nuclear
Countermeasures Test and Evaluation Complex at the Nevada Test Site
(NTS). DNDO, with assistance from DOE's National Nuclear Security
Administration, began construction of the complex in 2005.[Footnote 21]
While construction work is under way, an Interim Test Track was built
nearby. The complex is to support the DNDO's development, testing,
acquisition, and support of the deployment of radiation detection
technologies. When completed, the complex will be comprised of several
operating areas where testing and evaluation of detection systems will
be conducted, such as a testing facility to evaluate active
interrogation technologies; and a large, instrumented outdoor testing
area to test mobile detection systems. The complex will also have a
vehicle choke point where detection systems for land border crossings,
toll plazas, and entrances to tunnels and bridges can be evaluated.
According to DNDO officials, an important advantage of using NTS is
that it provides the necessary facilities to test detection system
capabilities with special nuclear materials in threat-representative
configurations. The complex will be open to other organizations within
DHS, including CBP, S&T, the Transportation Security Administration,
and the U.S. Coast Guard. It will also be open to DOE national
laboratories, universities, and private companies conducting radiation
detection development and production for DHS. The facility is expected
to become fully operational in January 2007.
In addition to the Nevada complex, DHS manages CMTB to test radiation
detection equipment in an operational environment. The CMTB originated
as a DOE funded demonstration project in fiscal year 2003, but
transferred to DHS in August 2003. The scientific, engineering, and
technical staff of the CMTB are drawn predominantly from the national
laboratories. The test bed encompasses various operational settings,
such as major seaports, airports, roadways, and railways. The CMTB
deploys commercially available and advanced radiation detection
equipment at these venues to test and evaluate their performance in
real-world situations, to develop better standard operating procedures,
and to assess the impact the equipment has on the flow of commerce. At
present, CMTB is testing portal monitors at toll crossings of two
tunnels and one bridge, two seaport terminals, and two air cargo
facilities. In addition, CMTB is developing several advanced secondary
inspection mobile technologies. (See fig. 5.) The advanced
spectroscopic portal monitors that DNDO is developing will likely be
evaluated at the CMTB, once testing is completed at the Nevada Test
Site.
Figure 5: The "SMARTCART," a Mobile Portal Monitor Using Advanced
Detection Technology, Being Tested at the CMTB in New York:
[See PDF for image]
[End of figure]
The Newly Created Domestic Nuclear Detection Office Is Structured to
Improve Coordination of Executive Branch Radiation Detection Programs:
DHS works with DOE, DOD, and other federal, state, and local agencies,
as well as the private sector to carry out radiation detection
programs. The newly established DNDO was set up to serve as DHS's main
instrument for coordinating these efforts. Since its creation in April
2005, DNDO has entered into working relationships with other agencies
and is taking the lead in developing what it calls a "global
architecture," an integrated approach to detecting and stopping nuclear
smuggling. However, because DNDO was created so recently, these efforts
are in their early stages of development and implementation.
DNDO Attempts to Improve Cooperation Among Other DHS Offices, DOE, DOD,
and Other Agencies in Deploying and Operating Equipment:
Historically, cooperation among agencies engaged in domestic radiation
detection has been limited. In April 2005, however, the president
signed a joint presidential directive that directed the establishment
of DNDO to, among other things, improve such cooperation by creating a
single accountable organization with the responsibility for
establishing strong linkages across the federal government and with
other entities. As currently envisioned under the directive, DNDO's
mission covers a broad spectrum of radiological and nuclear protective
measures, but focuses mainly on nuclear detection. The directive
includes several provisions directing DNDO to coordinate its activities
with other entities. For example, DNDO is to work with DOE, DOD, the
Departments of State and Justice, state and local agencies, and the
private sector to develop programs to thwart illicit movements of
nuclear materials. In addition, provisions of the directive require
consultation between DNDO, law enforcement and nonproliferation
centers, as well as other related federal and state agencies. Table 2
provides a summary of the cooperation brought about by the presidential
directive.
Table 2: Cooperation with DNDO Brought about by Presidential Directive:
Department of Homeland Security:
Agency: S&T;
Responsibilities: All radiological/nuclear detection programs and staff
subsumed by DNDO.
Agency: U.S. Coast Guard (USCG);
Responsibilities: USCG and DNDO coordinate on detection and reporting
resources, and protocols to ensure that USCG equipment is state-of-the-
art and that detection events are properly reported.
Agency: Office of State & Local; Government Coordination and
Preparedness (SLGCP);
Responsibilities: DNDO works to ensure good communication,
coordination, and takes other actions with state and local governments.
SLGCP personnel help staff DNDO.
Interagency Components:
Agency: Department of Energy;
Responsibilities: Provide staffing to, and coordinates with, DNDO in
equipping National Incident Response Teams. DOE also provides DNDO with
information from overseas programs. Makes the NTS and special nuclear
materials available for DNDO testing.
Agency: Department of Defense;
Responsibilities: Provide staffing to DNDO. Facilitate coordination
between DOD detection programs and domestic programs. Coordinate on
technical "reachback capabilities." Integrate any domestic detection
systems in communities near military bases with DNDO assets.
Agency: Department of Justice;
Responsibilities: Provide staffing to DNDO. FBI will coordinate on
establishing and executing "reachback capabilities." FBI remains the
lead law enforcement agency in terrorist events.
Agency: Department of State;
Responsibilities: Provide links and overall coordination between DNDO
and non-U.S. organizations responsible for radiation detection.
Agency: Central Intelligence Agency;
Responsibilities: Primary responsibility for gathering, analyzing, and
disseminating intelligence information relevant to DNDO operations. The
agency will accept collection requirements through channels from DNDO.
Agency: Nuclear Regulatory Commission;
Responsibilities: Coordinate detection requirements with DNDO. DNDO
shares detection event data with NRC, and NRC shares information with
DNDO on legal shipments of radiological materials.
Source: DNDO.
[End of table]
According to senior DNDO officials, although the close cooperation
called for in DNDO's mandate has been difficult to achieve, there are
two factors that may help DNDO succeed in this effort. First, the
presidential directive is explicit in directing other federal agencies
to support DNDO's efforts. The directive transfers primary
responsibility for radiation and nuclear detection activities in the
United States to DNDO, and requires DNDO to include personnel from
other agencies in its organization. For example, under the directive,
DOE will provide DNDO with information received from overseas programs,
including the Megaports Initiative and others, as well as information
from DOE's international partners involved with radiological and
nuclear detection systems. Second, all of the radiological and nuclear
detection programs and staff of S&T became part of DNDO.
DOE's Second Line of Defense program supports DNDO efforts by working
with the agency to exchange information, data, and lessons learned from
overseas deployments. According to senior officials at DNDO, the data
from overseas deployments are needed to help DNDO efforts to develop
profiles of potential risks to the United States. In addition, the
performance of these systems, as evidenced by these data, can help
improve domestic portal monitors' ability to detect radiation. In
addition, DOE provides equipment training opportunities for DHS
personnel. In April 2005, DOE and DHS formalized certain aspects of
this cooperation in a memorandum of understanding. Specifically, the
areas of cooperation include, among other things: discussing procedures
for the rapid analysis of cargo and for operational/emergency
responses, training CBP officers, exchanging technical and lessons
learned information, and providing updates on their respective
programs' implementation.
DHS has also entered into formal agreements with state and local
governments to coordinate their radiation detection efforts. For
example, in April 2005, just prior to DNDO's creation, DHS and the Port
Authority of New York and New Jersey finalized a memorandum of
understanding to provide services, personnel, and equipment to run the
CMTB program. Specifically, the program is designed to evaluate and
assess the role of threat detection technologies, develop and exercise
various concepts of operation and response tools, integrate lessons
learned from field experiences, and provide detection and monitoring
capabilities for testing and evaluation purposes. The agreement spells
out each partner's responsibilities, including coordination with other
agencies. According to a senior DNDO official, DNDO now has
responsibility for this and other similar agreements under its
authority to develop and evaluate new radiation detection equipment.
Finally, DNDO officials also believe that the way the agency has been
staffed and organized will aid its cooperation efforts. For example,
staff from DHS, DOD, DOE, the Departments of State and Justice, and
other agencies, have been detailed to DNDO. All of DNDO's major
organizational units are staffed with personnel from multiple agencies.
For example, the strategic planning staff within the Office of the
Director has employees from DOE, DOD, CBP, Federal Bureau of
Investigation (FBI), and DHS's Office of State and Local Government
Coordination and Preparedness. Significantly, DNDO's Office of
Operations Support, which is designed to provide real-time situational
data as well as technical support to field units, is headed by an FBI
executive with senior staff from CBP, DOE, and DHS's Transportation
Security Administration providing direct management support. According
to a senior DNDO official, having this broad range of agencies
represented in DNDO decision making helps ensure that agencies' views
are heard and fully considered, thereby helping to achieve the greatest
possible consensus even for difficult decisions. Further, agency
personnel detailed to DNDO have the authority to "bind" their
respective agencies, i.e., whatever decisions or agreements are reached
under the auspices of DNDO will bind their agency to comply to the
extent permitted by law. Finally, according to senior officials in DOE
and CBP, the current organizational arrangement appears to be working.
Officials noted that early in DNDO's history, communication was
difficult, but has recently improved. For example, CBP and DOE
officials told us they had hoped to have greater input into DNDO's
early efforts to develop integrated radiation detection systems.
However, these officials noted that by October 2005, DNDO seemed to
have heard and acted upon their recommendations. However, although
these officials were optimistic about future collaborations with DNDO,
they also noted that DNDO has not yet completed a large enough body of
work to conclude firmly that its coordination efforts will always be
similarly successful.
DNDO Is Cooperating with Other Agencies to Develop a Global Nuclear
Detection System:
Among the main purposes in creating the DNDO, according to its
Director, is to develop a global nuclear detection system that he
characterized as a "global architecture." DNDO's intention in
developing such an approach is to coordinate other agencies' efforts,
such as the Second Line of Defense and Container Security Initiative,
with the domestic deployment program to create an integrated, worldwide
system. The resulting "global architecture" would be a multi-layered
defense strategy that includes programs that attempt to secure nuclear
materials and detect their movements overseas; to develop intelligence
information on nuclear materials' trans-shipments and possible movement
to the United States; and to integrate these elements with domestic
efforts undertaken by governments--federal, state, local, and tribal--
and the private sector. Much of DNDO's work in terms of acquiring and
supporting the deployment of radiation detection equipment, as well as
in supporting research, development, and testing of new detection
equipment supports the office's mission to develop the U.S. domestic
portion this global architecture.
In addition, DHS, in conjunction with selected state and local
organizations, as well as other federal agencies and the private
sector, began two pilot projects in fiscal year 2003 to demonstrate a
layered defense system designed to protect the United States against
radiological and nuclear threats. DHS's Radiological Pilot Programs
Office coordinated the projects' initial efforts, and DNDO assumed
responsibility in October 2005. Field work began in fiscal year 2004
and will be completed in fiscal year 2007. The project leaders expect
the final report and lessons learned to be issued in fiscal year 2007.
Both pilot projects featured a broad selection of federal, state, and
local agencies, including state law enforcement, counter-terrorism,
emergency management, transportation, and port authorities.
Conclusions:
DHS has made progress deploying radiation detection equipment at U.S.
ports-of-entry; notably, the department achieved these gains without
greatly impeding the flow of commerce (i.e., the movement of cargo
containers out of ports-of-entry). However, we believe that DHS will
find it difficult under current plans and assumptions to meet its
current portal monitor deployment schedule at U.S. borders because it
would have to increase its current rate of deployment by 230 percent to
meet its September 2009 deadline. Our analysis of CBP's and PNNL's
earned value data suggests that millions of dollars worth of work is
being deferred each month and that the work that is completed is
costing millions more than planned. Currently, we estimate that CBP is
facing a likely cost overrun of about $340 million, and that the last
portal monitor may not be installed until late 2014. Unless CBP and
PNNL make immediate improvements in the schedule performance, then
additional slippage in the deployment schedule is likely.
A key overriding cause for these delays is the late disbursal of funds
to DHS contractors. This late dispersal disrupts and delays some
ongoing installation projects. In this regard, DHS approval processes
for documentation requested by the House Appropriations Committee are
lengthy and cumbersome. In one case, for example, funds for fiscal year
2005 were not made available to the DHS contractor until September
2005, the last month of the fiscal year. This process is taking too
long and needs to be shortened.
Further, the unsure efficacy and uncertain cost associated with the
advanced portal monitor technology means that DHS cannot determine,
with confidence, how much the program will eventually cost. In
particular, even if the advanced portal monitor technology can be shown
superior to current technology--which currently does not seem certain-
-DHS does not yet know whether the new technology will be worth its
considerable additional cost. Only after testing of the advanced portal
monitors has been completed and DHS has rigorously compared currently-
fielded and advanced portal monitors, taking into account their
differences in cost, will DHS be able to answer this question.
CBP has experienced difficulty deploying portal monitors at seaports,
at least in part because it has been unable to reach agreements with
many seaport operators, who are concerned that radiation detection
efforts may delay the flow of commerce through their ports. As a
result, the agency has fallen 2 years behind its seaport deployment
schedule--and seaports continue to be vulnerable to nuclear smuggling.
Significantly, there is no clear solution and no reason to be
optimistic that progress can be made soon. CBP's policy of negotiating
deployment agreements with seaport terminal operators has not yet
yielded agreements at many seaports and this has caused significant
delays in the deployment of portal monitors at some seaports. CBP has
chosen not to attempt to force terminal operators to cooperate. A
subset of this issue concerns screening rail traffic leaving seaports,
which is a particularly difficult problem. The operational concerns of
performing secondary rail inspections in seaports are daunting. Some
port operators as well as a national study strongly suggest that rail
transport will increase over the next 10 years. However, unless an
effective and efficient means to screen rail traffic is developed and
deployed, seaports will likely continue to either avoid installing
detection equipment altogether, or simply turn it off when its
operation might prove to be inconvenient. Without more progress on this
front, we risk rail cargo becoming a burgeoning gap in our defenses
against nuclear terrorism.
CBP appears to have made progress in using radiation detection
equipment correctly and adhering to inspection procedures. At several
ports-of-entry we visited, CBP officers physically opened and inspected
cargo containers to confirm the nature of the radiological source under
certain circumstances. They did this when they were unable to confirm
the type of radiological material through current approved procedures.
Since the currently deployed handheld equipment is limited in its
ability to accurately identify sources of radiation, opening the
container allows CBP officers to get closer to the source of the alarm
and thereby improve their chances of accurately identifying the source.
It also enables officers to verify that the container's contents are
consistent with the isotope identifier's initial reading and the
container's manifest. Furthermore, since DHS and DOE officials have
expressed concerns that illicit radiological material could be
shielded, this practice enables officers to conduct a more thorough
examination of the containers' contents--thereby increasing the
likelihood that CBP officers will find any illicit radioactive
material. Importantly, this process, according to border security
officials, did not impede the progress of commerce through any port-of-
entry.
On the other hand, because CBP officers do not have access to NRC
licensing data, it is difficult for them to verify that shippers have
obtained necessary NRC licenses and to verify the authenticity of any
NRC licenses that may accompany shipments of radioactive materials. As
a result, unless nuclear smugglers in possession of faked license
documents raised suspicions in some other way, CBP officers could
follow agency guidelines yet unwittingly allow them to enter the
country with their illegal nuclear cargo. As we see it, this is a
significant gap in CBP's national procedures that should be closed.
Recommendations for Executive Action:
Since DHS provides the Congress with information concerning the
acquisition and deployment of portal monitors, and since DHS's
procedures to obtain internal agreement on this information are lengthy
and cumbersome--often resulting in delays--we recommend that the
Secretary of Homeland Security, working with the Director of DNDO and
the Commissioner of CBP, review these approval procedures and take
actions necessary to ensure that DHS submits information to the
Congress early in the fiscal year.
In order to complete the radiation portal monitor deployment program,
as planned, we recommend that the Secretary of Homeland Security,
working with the Director of DNDO, and in concert with CBP and PNNL,
devise a plan to close the gap between the current deployment rate and
the rate needed to complete deployments by September 2009.
To ensure that DHS's substantial investment in radiation detection
technology yields the greatest possible level of detection capability
at the lowest possible cost, we recommend that once the costs and
capabilities of advanced technology portal monitors are well
understood, and before any of the new equipment is purchased, the
Secretary of Homeland Security work with the Director of DNDO to
analyze the benefits and costs of deploying advanced portal monitors.
This analysis should focus on determining whether any additional
detection capability provided by the advanced equipment is worth its
additional cost. After completing this cost-benefit analysis, the
Secretary of Homeland Security, working with the Director of DNDO,
should revise its total program cost estimates to reflect current
decisions.
To help speed seaport deployments and to help ensure that future rail
deployments proceed on time, we recommend that the Secretary of
Homeland Security, in cooperation with the Commissioner of CBP, develop
procedures for effectively screening rail containers and develop new
technologies to facilitate inspections.
To increase the chances that CBP officers find illicit radiological
material, we recommend that the Secretary of Homeland Security, working
with the Commissioner of CBP, consider modifying the agency's standard
operating procedures for secondary inspections to include physically
opening cargo containers during secondary inspections at all ports-of-
entry when the external inspection does not conclusively identify the
radiological material inside.
To further increase the chances that CBP officers identify illicit
radiological material, we recommend that the Secretary of Homeland
Security, working with the Chairman of NRC, develop a way for CBP
border officers to determine whether radiological shipments have the
necessary NRC licenses and to verify the authenticity of NRC licenses
that accompany such shipments.
To ensure that CBP is receiving reliable cost and schedule data, we
recommend that the Secretary of Homeland Security direct PNNL to have
its earned value management system validated so that it complies with
guidance developed by the American National Standards
Institute/Electronic Industries Alliance. In addition, we recommend the
Secretary of Homeland Security direct CBP and PNNL to conduct an
Integrated Baseline Review to ensure its earned value management data
is reliable for assessing risk and developing alternatives.
Agency Comments and Our Evaluation:
We provided a draft of this report to DHS for comment. In response, we
received written comments from DHS officials. DHS noted that the report
is factually correct. Further, the Department agreed with our
recommendations and committed to implementing them. DHS officials also
commented that our review did not completely capture the enormity or
complexity of the Radiation Portal Monitor program. We agree that this
program is a massive undertaking, and our original draft reflected this
perspective in several places. In commenting on our recommendation to
develop a better means for CBP border officers to verify NRC license
information, DHS stated that "NRC licenses are required to accompany
certain legitimate shipments of radiological materials…" However, DHS
is wrong on this point. According to senior NRC officials, no such
requirement exists. Finally, DHS provided some clarifying comments that
we incorporated into this report, as appropriate.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies to the
congressional committees with jurisdiction over DHS and its activities;
the Secretary of Homeland Security; the Director of OMB; and interested
congressional committees. We will also make copies of the report
available to others upon request. This report will also be available at
no charge on GAO's home page at [Hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-3841. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff who made major contributions to this
report are listed in appendix IV.
Signed by:
Gene Aloise:
Director, Natural Resources and Environment:
List of Requesters:
The Honorable Norm Coleman:
Chairman:
Permanent Subcommittee on Investigations:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Susan M. Collins:
Chairman:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Carl Levin:
Ranking Minority Member:
Permanent Subcommittee on Investigations:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable John D. Dingell:
Ranking Minority Member:
Committee on Energy and Commerce House of Representatives:
[End of section]
Appendixes:
Appendix I: Scope and Methodology:
To assess the Department of Homeland Security's (DHS) progress in
deploying radiation detection equipment, including radiation portal
monitors, radiation isotope identification devices, and pagers at U.S.
ports-of-entry and any problems associated with that deployment, we
reviewed documents and interviewed officials from the U.S. Customs and
Border Protection (CBP), Domestic Nuclear Detection Office (DNDO), and
Pacific Northwest National Laboratory (PNNL). We focused primarily on
the issues surrounding radiation portal monitors because they are a
major tool in the federal government's efforts to thwart nuclear
smuggling, and because the budget and other resources devoted to these
machines far exceeds the handheld equipment also used at U.S. ports-of-
entry. Further, we focused on the use of radiation detection equipment
in primary and secondary inspections, but we did not examine their use
as a part of CBP's targeted inspections. To assess CBP's current
progress in deploying portal monitors, we compared PNNL's December 2004
project execution plan for deploying radiation portal monitors--
including the project's schedule and estimated cost. We analyzed
budget, cost, and deployment data on portal monitors to determine
differences between PNNL's plan and its current progress. We also
assessed PNNL's cost and schedule performance using earned value
analysis techniques based on data captured in PNNL's contract
performance reports. We also developed a forecast of future cost
growth. We based the lower end of our forecast range on the sum of
costs spent to date and the forecast cost of work remaining. The
remaining work was forecast using an average of the current cost
performance index efficiency factor. For the upper end of our cost
range, we relied on the actual costs spent to date added to the
forecast of remaining work with an average monthly cost and schedule
performance index.
We also visited a nonprobability sample of CBP ports-of-entry,
including two international mail and express courier facilities, five
seaports, and three land border crossings.[Footnote 22] We selected
these ports-of-entry by using criteria such as the types of ports-of-
entry where CBP plans to deploy equipment; ports-of-entry with wide
geographic coverage; and ports-of-entry where portal monitors have
been--or are planned to be--installed. During each visit, we spoke with
CBP inspectors and local port authority officials on the progress made,
and any problems experienced in deploying the equipment at their
locations.
To assess CBP officers' use of radiation detection equipment, and how
inspection procedures are implemented at U.S. ports-of-entry, and any
problems associated with the use of the equipment, we reviewed CBP's
standard operating procedures for radiation detection; documents on its
training curriculum; and training materials on how to use the
equipment. We participated in a 3-day hands-on training course for CBP
officers at PNNL on how to use radiation detection equipment. We also
interviewed officials from CBP field and headquarters to discuss
problems associated with the use of the equipment. During our site
visits, we toured the facilities, observed the equipment in use, and
interviewed CBP officers about radiation detection policies and
procedures and the deployment of equipment at their locations. We
discussed with CBP officers how they determine the validity of Nuclear
Regulatory Commission (NRC) licenses when legitimate shipments of
radioactive material enter the nation.
To assess DHS's progress in improving and testing radiation detection
equipment capabilities, we reviewed documents and interviewed officials
from CBP, DNDO, Science and Technology Directorate (S&T), DOE, PNNL,
and the National Institute for Standards and Technology (NIST). We
reviewed S&T's April 2005 Program Execution Plan; DHS documentation on
the development of advanced radiation detection technologies; and test
results and assessments of the performance of both commercially
available radiation detection equipment and advanced technologies. We
visited four national laboratories--Lawrence Livermore, Los Alamos,
Pacific Northwest, and Sandia--that are involved in the research,
development, and testing of radiation detection technologies. In
addition, we visited the Counter Measures Test Bed (CMTB) in New York
and New Jersey, the Nevada Test Site, and the Department of Defense's
(DOD) test site at a U.S. Air Force base to observe the testing of
radiation detection equipment and discuss progress in improving and
testing radiation detection equipment with onsite experts.
To assess the level of cooperation between DHS and other federal
agencies in conducting radiation detection programs, we interviewed
officials from CBP; S&T; the Transportation Security Administration;
DOD's Defense Threat Reduction Agency; DOE's National Nuclear Security
Administration; and Lawrence Livermore, Los Alamos, Pacific Northwest,
and Sandia National Laboratories. We discussed the current extent of
coordination and whether more coordination could result in improvements
to DHS's deployment, development, and testing of radiation detection
equipment and technologies. We reviewed agency agreements to cooperate,
including a memorandum of understanding between DHS and DOE to exchange
information on radiation detection technologies and deployments, and a
memorandum of understanding between DHS and the Port Authority of New
York and New Jersey to integrate lessons learned into domestic
radiation detection efforts. In addition, we reviewed an organizational
chart from DNDO as well as our past reports on coordination between
federal agencies on deployment and testing.
We received training data from CBP, cost and budget data from CBP, and
deployment data from CBP and PNNL. We obtained responses from key
database officials to a number of questions focused on data reliability
covering issues such as data entry access, internal control procedures,
and the accuracy and completeness of the data. We determined these data
were sufficiently reliable for the purposes of this report.
We conducted our review from March 2005 to February 2006 in accordance
with generally accepted government auditing standards.
[End of section]
Appendix II: GAO Contact and Staff Acknowledgments:
GAO Contact:
Gene Aloise, (202) 512-3841:
Acknowledgments:
In addition to the contact named above, Jim Shafer; Nancy Crothers;
Emily Gupta; Brandon Haller; Richard Hung; Winston Le; Greg Marchand;
Judy Pagano; Karen Richey; Keith Rhodes, GAO's Chief Technologist; and
Eugene Wisnoski made key contributions to this report.
[End of section]
Appendix III: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20528:
March 6, 2006:
Mr. Eugene Aloise:
Director:
Natural Resources and Environment:
Government Accountability Office:
Washington, DC 20548:
Dear Mr. Aloise:
Thank you for providing us with a copy of the draft report GAO-06-389
Combating Nuclear Smuggling: DHS Has Made Progress Deploying Radiation
Detection Equipment, but Concerns Remain", which examines the
Department of Homeland Security's (DHS) recent progress in the
deployment and use of radiation detection equipment, improving the
capabilities and testing of such equipment, and the level of
cooperation between DHS and other federal agencies in conducting
radiation detection programs.
The GAO report is factually correct; however it does not completely
capture the enormity or complexity of the Radiation Portal Monitor
(RPM) program. CBP, in conjunction with the DHS Domestic Nuclear
Detection Office (DNDO), is continuing the deployment of this vital
radiation screening technology along the northern land border,
international mail and express consignment facilities, seaports and
along the southern border, where DHS has deployed hundreds of RPMs and
other hand held detection devices. From these deployments, DHS has
gained significant experience regarding radiation alarms and
implemented strict national response protocols and standard operating
procedures to facilitate alarm responses. To date, CBP has screened
over 80 million conveyances with RPMs and has successfully resolved all
alarming conveyances, over 318,000 radiation alarms. In fact, nearly
all radiation alarms that have been encountered have been inspected and
cleared in a matter of minutes with minimum disruption to the normal
flow of traffic.
DHS has engaged numerous stakeholders in cooperative efforts that
support the goals of the radiation detection program. DHS recognizes
that security-induced disruptions to the U.S. economy ultimately serve
the terrorists' goal of harming our economic well being, and is
determined to raise our security profile while simultaneously
facilitating the free flow of legitimate trade. We achieve both the
security and facilitation of trade by coordinating closely with all
stakeholders throughout the course of the program.
A wide variety of Department of Energy (DOE) laboratories and offices
continue to provide technical support to DHS in the areas of threat
definition, equipment performance standards development, technology
assessment and evaluations, on-site operational assistance and alarm
response. DHS is working with DOE Second Line of Defense, now actively
engaged in similar deployments overseas, supporting the Container
Security Initiative. To support this program, DHS also forged
relationships with various port authorities, bridge commissions, and
federal and state agencies such as the United States Postal Service and
the General Services Administration, and further has established
memorandum of understanding with commercial entities such as Federal
Express and United Parcel Service to implement overseas radiological
screening of packages destined to the United States.
To date, DHS has deployed 684 RPMs to our ports of entry. DHS' current
RPM screening capability for conveyances, travelers and packages
entering the United States is as follows:
* Based on our deployment of 57 RPMs to our mail and express courier
facilities, and in conjunction with our memorandum of understanding
with Federal Express and United Parcel Service, 100% of all mail and
packages entering the United States are screened for illicit
radiological materials.
* With the 222 RPMs deployed along the northern border, DHS screens
approximately 80% of personally owned vehicles (POV) traffic and 90% of
commercial truck traffic entering from Canada.
With the 154 RPMs deployed at our seaports, DHS screens approximately
34% of all sea-borne containers entering the United States.
With the 251 RPMs deployed along the southern border, DHS screens
approximately 74% of personally owned vehicles (POV) traffic and 88% of
commercial truck traffic entering from Mexico.
DHS has also deployed approximately 12,500 personal radiation detectors
(PRD) and over 550 radiation isotope identification devices (RIID) to
our ports of entry. At the ports of entry, DHS has implemented a policy
requiring 100% PRD coverage at primary chokepoints or at passport
control stations. Additionally, all high-risk conveyances are examined
with Non-Intrusive Inspection technology and with radiation detection
technology. No officer is authorized to employ any such detection
devices without first receiving formal training.
As part of its future vision, DHS goals are to accelerate the pace of
radiation monitoring equipment deployments, to improve the overall
quality and effectiveness of this technology, and to integrate them at
a national level to facilitate improved alarm response, data collection
and analysis, as well as maintenance status monitoring and life cycle
support. DHS will continue looking for new strategies, technologies,
and partnerships to deter, detect and interdict terrorists attempting
to transport illicit nuclear and radiological weapons and/or materials
into the United States. DHS has learned a great deal from our
deployments of radiation detection technology and will continue to
review and improve upon the methods and procedures associated with this
technology.
With respect to the classification of this report, GAO did not mark the
document "For Official Use Only." Please note that the information DHS
provided during the course of this audit concerns the technical
capabilities and deployment of DHS radiation detection devices around
the United States. These source materials were forwarded pursuant to
the GAO statutory authority to examine government records, on the
condition that GAO accord them the same level of confidentiality that
DHS accords them pursuant to 31 U.S.C. § 716(e). Specifically, these
materials were provided only for the use of GAO personnel working on
this matter and may not be released publicly.
DHS treats its radiation detection capabilities with the highest care.
DHS considers this material as "For Official Use Only - Law Enforcement
Sensitive" and thus exempt from public disclosure under FOIA and
subject to governmental privileges should it be sought in litigation.
Disclosure to the public of the technical and operational details of
DHS's radiation detection capabilities is sensitive, and could
reasonably be expected to risk circumvention of laws DHS enforces,
including the prevention of unlawful entry of radioactive material into
the United States. Therefore, this version of the report must be
treated as "For Official Use Only-Law Enforcement Sensitive."
The following represents the Departmental response to the
recommendations contained in the draft report.
Recommendation 1: In order to complete the radiation portal monitor
deployment program, as planned, we recommend that the Secretary of
Homeland Security working with the Director of DNDO, in concert with
CBP and PNNL, devise a plan to close the gap between the current
deployment rate and the rate to complete deployments by September 2009.
Response: Concur. CBP and DNDO will work with the Department to
facilitate improvements to the development and approval process
associated with the spend plan. Both CBP and DNDO are in favor of the
spend plan approval process being revised and streamlined.
Recommendation 2: We recommend that once cost and capabilities of
advanced technology portal monitors are well understood, and before any
new equipment is purchased, the Secretary of Homeland Security will
work with the Director, DNDO to analyze the benefits and costs of
deploying advanced portal monitors.
Response: Concur. The DNDO fully intends to analyze the benefits and
costs associated with deployment of advance portal monitors.
Recommendation 3: To help speed seaport deployments and to help ensure
that future rail deployments proceed-on time, we recommend that the
Secretary of Homeland Security, in cooperation with the Commissioner of
CBP, develop procedures for effectively screening rail containers and
develop new technologies to facilitate inspections.
Response: Concur. In terms of screening rail shipments at our seaports,
CBP has deployed and will continue to deploy Radiation Portal Monitors
(RPM) for on-dock and intermodal containers that are transported, via
chassis, to railcars. Of the top priority seaports which are comprised
of 93 terminals and account for approximately 98 percent of all
arriving containerized sea cargo, 17 sea terminals handle rail
shipments. Of the 17 terminals, 13 terminals utilize chassis to
transport their containers to their trains. CBP will instrument these
sites with RPMs to screen the containers, being carried on the chassis,
prior to the train being built. Deploying RPMs to chokepoints within
these terminals provides for an efficient and effective means of
screening for illicit radiological materials as well as facilitating
the flow of legitimate commerce.
For the sites that handle transport containers to rail on equipment
other than chassis (i.e., straddle carriers), CBP is pursuing both
innovative deployment strategies and next generation technology that
will effectively and efficiently screen containers without unduly
disrupting the flow of commerce.
Recommendation 4: To increase the chances that CBP Officers find
illicit radiological material, we recommend that the Secretary of
Homeland Security, working with the Commissioner of CBP, consider
modifying the agency's standard operating procedures for secondary
inspections to include physically opening cargo containers during
secondary inspections at all ports of entry, and particularly when the
external inspection does not conclusively identify the radiological
material inside.
Response: Partially Concur. This action is already inherent in CBP's
response policy. CBP's policy is to locate and resolve every radiation
alarm. If the alarm can be resolved based on the totality of the
circumstances and if resolution of the alarm can be achieved with an
external examination with handheld radiation detection technology, the
opening of a container may not be necessary.
CBP has consistently provided its field officers with training (e.g.,
at the CBP Academy, RIID training, etc) that stresses the requirement
to locate and resolve all radiation alarms. Our officers are trained to
conduct an examination of a container by first performing a methodical
search of the exterior of the alarming container. If the alarm cannot
be resolved, the officer should open the container to investigate the
source more closely.
CBP will revise its response policy to stress that whenever a secondary
radiation portal monitor alarm cannot be resolved with an external
radiation detection technology examination, an officer will open the
container in order to attempt to resolve the alarm.
Recommendation 5: To further the chances that CBP Officers identify
illicit radiological material, we recommend that the Secretary of
Homeland Security, working with the Chairman of the Nuclear Regulatory
Commission (NRC), develop a better means for CBP border officers to
verify the authenticity of NRC licenses.
Response: Concur. NRC licenses are required to accompany certain
legitimate shipments of radiological materials and, for the most part,
only a relatively small number of companies are involved in the
importation of legitimate radiological shipments that require an NRC
license.
For those shipments that require an NRC license, CBP will work with the
NRC to implement policy and procedures whereby CBP Officers can contact
the Laboratories and Scientific Services (LSS) National Teleforensics
Center which is an integral part of the National Targeting Center
whenever CBP Officers need assistance in verifying the authenticity of
an NRC license.
Recommendation 6: To ensure that CBP is receiving reliable cost and
schedule data, we recommend that the Secretary of Homeland Security
direct PNNL to have their earned value management system validated so
that it complies with guidance developed by the American National
Standards Institute of Electronic Industries Alliance. In addition, we
also recommend the Secretary of Homeland Security direct CBP and PNNL
to conduct an Integrated Baseline Review to ensure its earned value
management data is reliable for assessing risk and developing
alternatives.
Response: Concur. PNNL is currently in the process of having their
project management system certified which will include the validation
of their earned management system. The DOE/Office of Engineering and
Construction Management supported by the DOD/Defense Contract
Management Agency will be conducting a review of the PNNL project
management system in the 1st quarter of FY07.
CBP has completed four project baseline reviews since 2002 as reflected
in the revisions of the Project Execution Plan (PEP). Currently, the
fifth revision of the PEP is under development, which is being reviewed
in close coordination with the Domestic Nuclear Detection Office
(DNDO). It is anticipated that the PEP, Revision 5 will be completed by
April 2006.
In response to the Issue Description, it is noted that the current cost
overruns and the project-at-completion forecasted cost overrun are
totally within and offset by the project management reserve, thus CBP
does not expect a project-at-completion overrun for the current scope
of work. Specifically, this program is made up of many small projects,
374 at this time. A significant amount of the schedule variance, or
project delays, can be attributed to the delay of funding transferred
to PNNL as described in GAO Recommendation #1 of this report. The other
major item contributing to project delays is underestimating the time
required to gain stakeholder concurrence/agreement regarding site
design and operational considerations. These impacts noted, cost and
schedule concurrency could still be significantly increased because the
physical deployments, 374 separate projects, are actually mutually
exclusive and therefore are not dependent on one another. As the result
of added concurrency and the anticipation of future timely funds, the
likelihood of a project- at-completion cost and schedule overrun should
not be realized.
We thank you again for the opportunity to review the report and provide
comments.
Sincerely,
Signed by:
Steven J. Pecinovsky:
Director, Departmental GAO/OIG Liaison Office:
[End of section]
Related GAO Products:
Combating Nuclear Smuggling: Corruption, Maintenance, and Coordination
Problems Challenge U.S. Efforts to Provide Radiation Detection
Equipment to Other Countries.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-311]
Washington, D.C.: March 14, 2006.
Combating Nuclear Smuggling: Efforts to Deploy Radiation Detection
Equipment in the United States and in Other Countries.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-840T]
Washington, D.C.: June 21, 2005.
Homeland Security: Key Cargo Security Programs Can Be Improved.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-466T]
Washington, D.C.: May 25, 2005.
Container Security: A Flexible Staffing Model and Minimum Equipment
Requirements Would Improve Overseas Targeting and Inspection Efforts.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-557]
Washington, D.C.: April 26, 2005.
Preventing Nuclear Smuggling: DOE Has Made Limited Progress in
Installing Radiation Detection Equipment at Highest Priority Foreign
Seaports.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-375]
Washington, D.C.: March 31, 2005.
Customs Service: Acquisition and Deployment of Radiation Detection
Equipment.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-03-235T]
Washington, D.C.: October 17, 2002.
Nuclear Nonproliferation: U.S. Efforts to Help Other Countries Combat
Nuclear Smuggling Need Strengthened Coordination and Planning.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-02-426]
Washington, D.C.: May 16, 2002.
[End of section]
(360558):
FOOTNOTES
[1] The Departments of Energy, Defense, and State are also implementing
programs to combat nuclear smuggling in other countries by providing
radiation detection equipment and training to foreign border security
personnel. See Pub. L. No. 107-296 (2002) Title IV, § 402. We recently
reported on these programs in Combating Nuclear Smuggling: Corruption,
Maintenance, and Coordination Problems Challenge U.S. Efforts to
Provide Radiation Detection Equipment to Other Countries, GAO-06-311
(Washington, D.C.: Mar. 14, 2006).
[2] See NSPD-43/HSPD-14, Domestic Nuclear Detection (April 15, 2005).
[3] DOE manages the largest laboratory system of its kind in the world.
The mission of DOE's 22 laboratories has evolved. Originally created to
design and build atomic weapons, these laboratories have since expanded
to conduct research in many disciplines--from high-energy physics to
advanced computing.
[4] Laboratories and Scientific Services coordinates technical and
scientific support to all CBP trade and border protection activities.
These activities include, among other things, providing
scientific/forensic support, including on-site support, to CBP officers
and other government agencies with regard to the investigation and
interdiction of Weapons of Mass Destruction.
[5] We originally reported on U.S. efforts to combat nuclear smuggling
in 2002. See GAO, Nuclear Nonproliferation: U.S. Efforts to Help Other
Countries Combat Nuclear Smuggling Need Strengthened Coordination and
Planning, GAO-02-426 (Washington, D.C.: May 16, 2002). See also, GAO,
Combating Nuclear Smuggling: Corruption, Maintenance, and Coordination
Problems Challenge U.S. Efforts to Provide Radiation Detection
Equipment to Other Countries, GAO-06-311 (Washington, D.C.: Mar. 14,
2006).
[6] We recently reported on the Megaports Initiative. See GAO,
Preventing Nuclear Smuggling: DOE Has Made Limited Progress in
Installing Radiation Detection Equipment at Highest Priority Foreign
Seaports, GAO-05-375 (Washington, D.C.: Mar. 31, 2005).
[7] U.S. radiation detection assistance programs at foreign seaports
are coordinated with--and complementary to--DHS's Container Security
Initiative (CSI). Under CSI, which began operating in January 2002,
U.S. Customs officials stationed in foreign ports review the cargo
manifests of containers bound directly for the United States and
attempt to identify containers with potentially dangerous cargo, such
as explosives or weapons of mass destruction. GAO recently reported on
CSI. See GAO, Container Security: A Flexible Staffing Model and Minimum
Equipment Requirements Would Improve Overseas Targeting and Inspection
Efforts, GAO-05-557 (Washington, D.C.: Apr. 26, 2005).
[8] We initially reported on the U. S. Customs Service's efforts to
deploy radiation detection equipment at U.S. ports-of-entry in 2002.
See GAO, Customs Service: Acquisition and Deployment of Radiation
Detection Equipment, GAO-03-235T (Washington, D.C.: Oct. 17, 2002).
[9] See Pub. L. No. 107-296 (2002) and DHS Reorganization Plan (Nov.
25, 2002).
[10] Pub. L. No. 107-296 (2002).
[11] Pub. L. No. 107-296, § 309.
[12] CBP's most recent Project Execution Plan (December 2004) calls for
deploying a total of 2,397 portal monitors. However, by December 2005,
the scope of the deployments had grown to 3,034.
[13] CBP and PNNL use an earned value management system (EVM) to report
the domestic portal monitor deployment program's status against its
baseline--scope, schedule, and budget. Essentially, an EVM approach
compares the value of the work accomplished during a given period with
the value of the work scheduled to be accomplished during that period.
Differences from the schedule are measured in both cost and schedule
"variances." For example, program activities (such as deploying portal
monitors at a specific site) that are completed ahead of schedule would
be reported as positive variances, while activities that are completed
behind schedule would be reported as negative variances. Similarly, the
EVM system tracks whether completed activities are costing more or less
than expected. A negative cost variance would indicate that activities
are costing more than expected, while a positive cost variance would
mean activities are costing less than expected. We report schedule
differences in both calendar and EVM terms. Appendix II provides more
details on the EVM methodology and our analysis.
[14] H.R. Rpt. No. 108-541, at 25-26 (2004).
[15] We also assessed PNNL's cost and schedule performance using earned
value analysis techniques based on data captured in PNNL's contract
performance reports. We also developed a forecast of future cost
growth. We based the lower end of our forecast range on the costs spent
to date added to the forecast cost of work remaining. The remaining
work was forecast using an average of the current cost performance
index efficiency factor. For the upper end of our cost range, we relied
on the actual costs spent to date added to the forecast of remaining
work with an average monthly cost and schedule performance index.
[16] Management reserves are part of the total program budget intended
to be used to fund work anticipated but not currently defined. Most
programs usually wait until work is almost completed before making a
judgment that management reserve can be applied to cover cost
variances.
[17] See OMB Circular No. A-11, Part 7, "Planning, Budgeting,
Acquisition, and Management of Capital Assets," June 2005.
[18] American National Standards Institute (ANSI)/Electronic Industries
Alliance (EIA) EVM System Standard (ANSI/EIA-748-98), Chapter 2 (May
19, 1998).
[19] Since the officer is an employee of the state, he was not required
to follow CBP procedures. According to the port police supervisor
present at the scene, the officer acted within the scope of port police
guidance.
[20] See 10 CFR § 110.5.
[21] The National Nuclear Security Administration is a separately
organized agency within DOE that was created by the National Defense
Authorization Act for fiscal year 2000 with responsibility for the
nation's nuclear weapons, nonproliferation, and naval reactors
programs. See Pub. L. No. 106-65 (1999).
[22] Results from nonprobability samples cannot be used to make
inferences about a population, because in a nonprobability sample, some
elements of the population being studied have no chance or an unknown
chance of being selected as part of the sample.
GAO's Mission:
The Government Accountability Office, the investigative arm of
Congress, exists to support Congress in meeting its constitutional
responsibilities and to help improve the performance and accountability
of the federal government for the American people. GAO examines the use
of public funds; evaluates federal programs and policies; and provides
analyses, recommendations, and other assistance to help Congress make
informed oversight, policy, and funding decisions. GAO's commitment to
good government is reflected in its core values of accountability,
integrity, and reliability.
Obtaining Copies of GAO Reports and Testimony:
The fastest and easiest way to obtain copies of GAO documents at no
cost is through the Internet. GAO's Web site ( www.gao.gov ) contains
abstracts and full-text files of current reports and testimony and an
expanding archive of older products. The Web site features a search
engine to help you locate documents using key words and phrases. You
can print these documents in their entirety, including charts and other
graphics.
Each day, GAO issues a list of newly released reports, testimony, and
correspondence. GAO posts this list, known as "Today's Reports," on its
Web site daily. The list contains links to the full-text document
files. To have GAO e-mail this list to you every afternoon, go to
www.gao.gov and select "Subscribe to e-mail alerts" under the "Order
GAO Products" heading.
Order by Mail or Phone:
The first copy of each printed report is free. Additional copies are $2
each. A check or money order should be made out to the Superintendent
of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or
more copies mailed to a single address are discounted 25 percent.
Orders should be sent to:
U.S. Government Accountability Office
441 G Street NW, Room LM
Washington, D.C. 20548:
To order by Phone:
Voice: (202) 512-6000:
TDD: (202) 512-2537:
Fax: (202) 512-6061:
To Report Fraud, Waste, and Abuse in Federal Programs:
Contact:
Web site: www.gao.gov/fraudnet/fraudnet.htm
E-mail: fraudnet@gao.gov
Automated answering system: (800) 424-5454 or (202) 512-7470:
Public Affairs:
Jeff Nelligan, managing director,
NelliganJ@gao.gov
(202) 512-4800
U.S. Government Accountability Office,
441 G Street NW, Room 7149
Washington, D.C. 20548: