    Diffuse Security Threats: USPS Air Filtration Systems Need More
    Testing and Cost Benefit Analysis before Implementation
    (22-AUG-02, GAO-02-838).

    Following the anthrax attacks of October 2001, the Unites States
    Postal Service (USPS) has started to look at various technologies
    that could be implemented in the event of another bioterror
    attack. The high-efficiency particulate air (HEPA) filtration
    system is being used as a prototype at two facilities and is
    planned for implementation throughout the country. HEPA filtering
    technology is the state-of-the-art technology for the removal of
    particulate biohazards and other particles of micron-sized range.
    USPS has not adequately tested the HEPA filtration system to
    confirm that it will meet its intended purpose of trapping
    anthrax spores and its secondary purpose of cleaning the mail
    processing equipment. USPS's testing has not shown conclusively
    (1) the HEPA filtration system's ability to trap released hazards
    and other contaminants, and (2) what level of hazards or
    contaminants could be released into the mail processing
    environment as a result of the air filtration system's design.
    Furthermore, USPS has not verified through testing that the air
    filtration system will not interfere with the air sampling and
    detection equipment. Even though HEPA filtration systems could
    reduce the risk of exposure to biohazards, they may negate the
    benefits of other technologies being considered by USPS to
    protect its employees and customers in the event of another
    anthrax attack. Finally, the design and installation of the HEPA
    filtration system requires custom modification to USPS equipment
    nationwide and will likely cost more than USPS projected in its
    Emergency Preparedness Plan.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-02-838
        ACCNO:   A04500
      TITLE:     Diffuse Security Threats: USPS Air Filtration Systems
    Need More Testing and Cost Benefit Analysis before Implementation
         DATE:   08/22/2002
      SUBJECT:   Air pollution control
    	     Biological warfare
    	     Chemical and biological agents
    	     Counterterrorism
    	     Mail delivery problems
    	     Postal facilities
    	     Postal service
    	     Safety
    	     Strategic planning
    	     Terrorism
    	     National preparedness

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    GAO-02-838

    Report to Congressional Committees

    United States General Accounting Office

    GAO

    August 2002 DIFFUSE SECURITY THREATS

    USPS Air Filtration Systems Need More Testing and Cost Benefit Analysis
    before Implementation

    GAO- 02- 838

    Page i GAO- 02- 838 USPS Air Filtration Systems Letter 1

    Results in Brief 2 Background 4 USPS Needs to Address HEPA Filtration
    System*s Effectiveness

    and Design Issues 5 Air Filtration System*s Effects on Air Sampling and
    Detection Need

    to Be Determined 15 USPS Plans to Deploy Air Filtration Systems Nationwide
    Are Not

    Justified 16 Conclusions 18 Recommendations 18 Agency Comments and Our
    Evaluation 19

    Appendix I Comments from the U. S. Postal Service 22

    Figures

    Figure 1: Tray Showing Items Captured by HEPA Filtration System 9 Figure
    2: Design of HEPA Filtration System at Dulles P& DC/ F 10 Figure 3:
    Prototype FSX Air Filtration System on the AFCS 11 Figure 4: Prototype
    Torit Air Filtration System on the DBCS 12 Figure 5: AFCS Modified with
    Metal Hoods 13 Figure 6: DBCS Modified with Plastic Shrouds 14 Figure 7:
    DBCS Torit Air Filtration System 15

    Abbreviations

    AFCS Advanced Facer- Canceller System AFSM Automated Flats Sorting Machine
    DAR Decision Analysis Report DBCS Delivery Bar Code Sorter HEPA high-
    efficiency particulate air P& DC/ F processing and distribution center/
    facility USPS United States Postal Service Contents

    Page 1 GAO- 02- 838 USPS Air Filtration Systems

    August 22, 2002 The Honorable Henry A. Waxman Ranking Minority Member
    Committee on Government Reform House of Representatives

    The Honorable Danny K. Davis Ranking Minority Member Subcommittee on Civil
    Service, Census, and Agency Organization Committee on Government Reform
    House of Representatives

    In response to the anthrax attacks of October 2001, the United States
    Postal Service (USPS) acknowledged the need for increased protection for
    both its employees and customers. In this regard, USPS has started to look
    at various technologies that could be implemented in the event of another
    bioterror attack. One technology that is being used as a prototype at two
    facilities and planned for implementation throughout the country is the
    high- efficiency particulate air (HEPA) filtration system. HEPA filtering
    technology is the state- of- the- art technology for removal of
    particulate biohazards and other particles in the micron- sized range. It
    is used in countless facilities around the world for biosafety, electronic
    clean room assembly, isolation wards, surgical theaters, bioengineering,
    pharmaceutical processing, and any application where the maximum stateof-
    the- art reduction or removal of submicron particulate material is
    required. USPS expects that the use of HEPA filters will reduce the risk
    of exposure to biohazards and prevent cross- contamination of the mail.

    You requested that we review USPS*s plans to deploy air filtration systems
    nationwide at its processing and distribution centers/ facilities (P& DC/
    F). Specifically, we reviewed the (1) effectiveness and design of HEPA
    filtration systems for implementation on mail processing equipment; (2)
    issues associated with HEPA filter interaction with USPS*s proposed air
    sampling and detection systems; and (3) costs, benefits, and risks
    associated with deploying an air filtration system.

    To address these objectives, we reviewed and analyzed USPS*s Emergency
    Preparedness Plan and other documents describing the agency*s plans to
    deploy and test air filtration systems. To assess the effectiveness of the

    United States General Accounting Office Washington, DC 20548

    Page 2 GAO- 02- 838 USPS Air Filtration Systems

    HEPA design, we reviewed USPS*s test plans and results. We also visited
    the Dulles and Merrifield P& DC/ Fs in Virginia to observe USPS*s mail
    processing operations and how the HEPA filtration systems were designed,
    installed, tested, and used in an operational environment. During the
    course of our work we met with USPS officials to discuss the HEPA air
    filtration system*s interaction with detection equipment. We also met with
    industry personnel to discuss the effectiveness of HEPA filters in
    capturing biohazardous materials. Additionally, we interviewed USPS
    officials to discuss the objectives, costs, benefits, and risks of
    deploying the air filtration system nationwide. We conducted our review at
    the USPS Headquarters in Washington, D. C., and P& DC/ Fs in Merrifield
    and Dulles, Virginia, from May through July 2002, in accordance with
    generally accepted government auditing standards. We requested comments on
    a draft of this report from USPS, and these comments are discussed later
    in this report and reproduced in appendix I.

    USPS has not adequately tested the HEPA air filtration system to confirm
    that it will meet its intended purpose of trapping anthrax spores and its
    secondary purpose of cleaning the mail processing equipment. USPS*s
    testing has not shown conclusively (1) the HEPA air filtration system*s
    ability to trap released hazards and other contaminants, and (2) what
    level of hazards or contaminants could be released into the mail
    processing environment as a result of the air filtration system*s design.
    We recognize the challenge that USPS faces in trying to protect its
    workers from airborne biohazards while trying to maintain its operations
    and control costs. However, without adequate testing USPS has no assurance
    that investing in air filtration equipment will provide adequate risk
    reduction to its employees.

    Furthermore, USPS has not verified through testing that the air filtration
    system will not interfere with the air sampling and detection equipment.
    Even though HEPA filtration systems could reduce the risk of exposure to
    biohazards, they may negate the benefits of other technologies being
    considered by USPS to protect its employees and customers in the event of
    another anthrax attack. USPS recognizes that it will need additional
    technology to detect and identify potential hazardous materials as early
    as possible in the mailstream. Therefore, in addition to installing air
    filtration equipment, USPS is designing and installing air sampling and
    detection equipment to monitor airborne particles released during
    automated mail processing. USPS plans to use this sampling in conjunction
    with biohazard detection technology to confirm whether anthrax spores are
    present. To be most effective in collecting airborne anthrax, the air
    sampling Results in Brief

    Page 3 GAO- 02- 838 USPS Air Filtration Systems

    equipment must be placed directly over the automated mail processing
    machines. However, unless designed correctly, HEPA filtration systems
    might have a negative impact on the air sampling and detection equipment
    because the anthrax spores could become lodged in the filters and render
    the air intake ineffective for detection. Although the USPS has requested
    funding for both technologies, it has not yet completed any tests to
    determine whether the HEPA filtration systems interfere with the
    performance of the proposed air sampling and detection equipment, or
    whether other alternatives should be assessed.

    Finally, the design and installation of the HEPA filtration system
    requires custom modification to USPS equipment nationwide and will likely
    cost more than USPS projected in its Emergency Preparedness Plan. In
    addition, even as USPS is initiating efforts for the full deployment of
    HEPA filtration systems at its nearly 300 P& DC/ Fs across the country, it
    has not yet performed a comprehensive investment analysis to identify the
    costs, benefits, and risks associated with this initiative or any
    alternative solutions. While USPS estimates that the total cost of its
    HEPA filtration initiative could be over $300 million by the end of fiscal
    year 2002, without a complete investment analysis, the agency will not
    know whether these costs outweigh the benefits of the technology.
    Moreover, we believe that USPS*s $300 million estimate is understated
    because it does not include other costs associated with maintenance.
    Specifically, the HEPA filtration systems and portable vacuum systems
    appear to be less efficient in cleaning the mail processing equipment than
    the former process of blowing out the dust with compressed air (i. e.,
    pressurized air exiting through nozzles akin to the air nozzles used to
    fill up tires). Thus, there is the potential for greater maintenance
    costs, and USPS runs the risk that the costs of investing in a HEPA
    filtration system nationwide could be more than originally planned.

    To address these concerns, we are recommending that the Postmaster General
    take steps to (1) perform additional tests to assess the system*s ability
    to capture biohazardous materials and its compatibility with other
    proposed technologies before making a decision on whether to deploy the
    system nationwide; and (2) evaluate the costs, benefits, and risks
    associated with implementing air filtration on mail processing equipment
    and other alternative solutions before a large- scale rollout is
    initiated.

    In commenting on a draft of our report, the USPS generally agreed with our
    recommendations and stated that USPS already has actions under way to
    address them prior to deploying the filtration systems. While USPS had
    concerns that we placed too much emphasis on the secondary benefits of

    Page 4 GAO- 02- 838 USPS Air Filtration Systems

    the air filtration system*s ability to control dust and its increased
    maintenance costs, it agreed with our recommendation to conduct additional
    testing to determine the system*s ability to capture biohazards prior to
    making a decision on nationwide implementation.

    USPS is a vast enterprise that delivers about 680 million pieces of mail
    daily to virtually every household and business in the United States
    through an array of services. Typical mail items* letters, flats, and
    parcels* may be introduced into the mailstream through mailboxes and
    collection boxes, thousands of drop points at customer sites, mail
    facilities, and other locations across the country. Once mail enters the
    USPS mail processing operation, it becomes part of a complex and
    diversified system, requiring the coordinated effort of mail processing
    plants and delivery units across the country. While much of mail delivery
    is labor intensive, most of the effort required to sort the mail for
    distribution has been automated by a series of high- volume machines. USPS
    has at least 10 different types of automated mail processors totaling more
    than 10,000 pieces of equipment in operation. These machines exist at
    various points in the mailstream and have mechanical forces that are
    likely to cause the release of substantial amounts of anthrax spores from
    a piece of mail.

    The October 2001 anthrax attacks raised great concerns over the security
    of postal employees and customers from exposure to biohazardous materials.
    In January 2002, Congress passed Public Law 107- 117 providing USPS $500
    million for emergency expenses to buy equipment for sanitizing and
    screening mail and to protect postal employees and customers from
    biohazardous material with the requirement that they develop an emergency
    plan. 1 On March 6, 2002, USPS issued its Emergency Preparedness Plan. The
    plan discusses a variety of process changes and technology initiatives
    that could be applied to the threat of biohazards in the mail. In
    addition, the plan addresses USPS*s goals of protecting postal employees
    and customers from exposure to biohazardous material and safeguarding the
    mail system from future bioterror attacks, while maintaining current
    service levels. USPS plans to achieve this by developing prototypes to
    test and evaluate which technologies should be used together with existing
    mail processing equipment. To fund its efforts,

    1 USPS was also allocated $175 million out of emergency supplemental
    appropriations for fiscal year 2001 to be used in part to purchase mail
    sanitization equipment, for employee safety measures, and for other
    expenses related to the anthrax attacks. Background

    Page 5 GAO- 02- 838 USPS Air Filtration Systems

    USPS plans to request an additional approximately $1.8 billion for fiscal
    years 2002 through 2004.

    In response to the anthrax- laden letters that caused widespread
    contamination at two postal facilities, USPS began testing HEPA filters to
    minimize paper dust, reduce risks to employees from biohazards, and clean
    mail processing equipment. The Postal Service plans to deploy this
    technology at nearly 300 P& DC/ Fs 2 that handle outgoing mail, but is
    specifically testing the prototypes for this technology at its Dulles and
    Merrifield, Virginia P& DC/ Fs. 3 These filtration systems have been
    implemented to run on two major types of mail processing equipment, the
    Delivery Bar Code Sorter (DBCS) and the Advanced Facer- Canceller System
    (AFCS) at both sites. The DBCSs are computerized machines that sort
    letter- sized mail by using a reader to interpret an imprinted barcode,
    while the AFCS is a type of mail processing equipment that automatically
    faces letter- sized mail in a uniform orientation and cancels the postage
    stamps. However, issues associated with the design and effectiveness of
    HEPA filtration systems still need to be addressed. First, USPS has not
    completed necessary tests and analysis to confirm the effectiveness of
    HEPA filtration systems installed on mail processing equipment and,
    therefore, does not know whether this technology will satisfy the agency*s
    objectives. Second, the benefits of the HEPA air filtration system*s
    ability to reduce dust and clean the mail processing equipment have not
    been confirmed. Third, the amount of energy needed to run the HEPA systems
    might overwhelm the existing power supply at some P& DC/ Fs and,
    therefore, degrade the operation of current mail processing equipment.
    Finally, the mail processing equipment will have to be modified in order
    for the filtration systems to operate effectively.

    2 USPS P& DC/ Fs are the facilities in which mail is processed and
    distributed from its origin to its final destination using computer-
    controlled electromechanical sorting equipment and computer data
    processing systems. A vast transportation network including trucks,
    airplanes, and trains, moves the mail between these centers.

    3 Although the automated mail handling machines at the P& DC/ Fs generate
    a lot of dust, the mail processing environment has been checked and rated
    as an acceptable place to work by regulatory agencies. USPS Needs to

    Address HEPA Filtration System*s Effectiveness and Design Issues

    Page 6 GAO- 02- 838 USPS Air Filtration Systems

    To date, USPS has performed initial tests to determine the effectiveness
    of its HEPA system*s (1) airflow velocity and (2) ability to remove dust
    in the mail sorting machines. However, USPS has not yet confirmed whether
    its HEPA filtration system*s prototypes are designed properly to capture
    and contain airborne anthrax within the system and not release it into the
    mail processing environment. As a result, USPS does not yet know whether
    this technology will meet its intended objectives.

    USPS has performed tests to determine its HEPA filtration system*s airflow
    velocity, but it has not performed the necessary test to confirm whether
    the system can actually capture anthrax spores in a mailprocessing
    environment. When installed correctly and in the proper environment, HEPA
    filters were designed to effectively capture 99.97 percent of all dust,
    pollen, mold spores, and bacteria at the 0.3- micron particle size that
    might pass through them. Because biohazard particles typically fall into
    the range of 1 to 10 microns, HEPA filtration may significantly reduce the
    number of particles that exhaust from the vacuum system into the ambient
    air of postal facilities. USPS has designed its air filtration equipment
    such that the air flows in accordance with industry standards to capture
    particle sizes similar to anthrax. To test the effectiveness of this
    design, USPS is working with the National Institute for Occupational
    Safety and Health to release smoke and tracer gas 4 to verify that the air
    filtration equipment is working as expected. Using tracer gas confirms
    that the system is moving air as intended through the filters. Experts
    from the Environmental Protection Agency agree with this approach for
    testing airflow and capture velocity. However, this procedure does not
    test either how much anthrax is trapped in the system or the system*s
    effectiveness in not releasing anthrax into the mail processing
    environment. Without conducting tests that confirm the system*s ability to
    trap anthrax and not release any into the mail processing environment, the
    USPS has not proven that its design will meet the intent of protecting its
    employees and customers.

    4 Sulfur hexa fluoride (SF6). Effectiveness of HEPA

    Filtration Systems in Mail Processing Equipment Has Not Been Confirmed

    Page 7 GAO- 02- 838 USPS Air Filtration Systems

    According to USPS, another benefit of installing HEPA air filtration
    systems is that the negative air pressure (i. e., vacuum) generated by the
    systems may help clean the mail processing equipment. Until October 2001,
    USPS mail processing machines, including rollers, belts, and electronic
    card cages, were cleaned with compressed air* pressurized air exiting
    through nozzles akin to the air nozzles used to fill up tires* a generally
    acceptable way to blow out and clean dusty equipment. USPS maintenance
    personnel stated that using compressed air is the best way to clean its
    machines because most of the dust collects on the pinch rollers, which are
    hard to access using a vacuum nozzle. However, USPS banned compressed air
    blowing following the anthrax attacks last fall. As a result, USPS began
    installing HEPA systems to permanently vacuum its mail processing
    equipment and reduce or eliminate the need to hand vacuum the internal
    workings of the machines, which is the current process.

    USPS recently performed a test to quantify the amount of dust collected by
    the HEPA filtration systems deployed at Dulles, but the results have not
    yet been analyzed. USPS gathered data from June 11 through June 25, 2002,
    on the amount of dust captured by the HEPA filtration systems installed at
    the Dulles facility. The test used data collected from four machines* two
    AFCSs and two DBCSs* to determine how much dust the filtration systems are
    actually capturing and how much dust remains in the mail processing
    equipment. Although one AFCS and one DBCS have a HEPA filtration system
    installed, the remaining two did not. The test involved using preweighed
    filters on four portable HEPA vacuum cleaners, which are used to clean the
    four machines individually. After the 2- week test period, USPS weighed
    the portable vacuum filters and canisters to determine how much dust the
    mail processing equipment collected with the HEPA filtration system versus
    those that did not have the prototype system. These test results are still
    being analyzed. While this initial testing is a positive step, we are
    concerned that the amount of dust collected by the portable HEPA vacuums
    from the mail processing machines with filtration systems will be
    understated because the data reflect a 24- hour period of operations
    versus the normal operations, which are between 7 and 16 hours depending
    on the type of equipment. Accordingly, the test may not provide USPS with
    the reliable data necessary to make valid conclusions about the efficiency
    of the HEPA filtration system.

    Given the importance of USPS*s initiative, it is imperative that reliable
    tests be performed to confirm whether the use of air filtration systems to
    clean mail processing equipment is effective. According to our preliminary
    observations, the HEPA filtration systems installed at the Dulles P& DC/ F
    are collecting relatively few dust particles and may be causing the dust
    to Secondary Benefit of

    Reducing Dust and Cleaning Machines Also Not Confirmed

    Page 8 GAO- 02- 838 USPS Air Filtration Systems

    settle inside the mail processing equipment. When we visited the Dulles P&
    DC/ F, we were shown the trays where some of the dust could settle. The
    trays contained only rubber bands, paper clips, loose bits of paper, and
    mail. See figure 1 for the contents of HEPA filtration system*s tray at
    the Dulles P& DC/ F. The Dulles P& DC/ F maintenance manager stated that
    when maintenance personnel blew air back through the filters to purge any
    dust that may be trapped in them, there was no dust dislodged and the
    filters appeared to be clean. The bulk of the dust may be lodged in the
    innards of the machines and electronic equipment and not in the filters.
    Therefore, USPS maintenance officials are concerned that mail processing
    equipment, such as the DBCS, is not being cleaned as thoroughly as it was
    previously with the dry sweeping and compressed air blowing methods.
    Without an effective mechanism to clean the equipment, 5 the dust lodged
    in the machines will manifest itself relatively quickly and may result in
    burned out pinch rollers, equipment breakdowns, and generally higher
    repair costs and downtime. Hence, USPS may incur additional costs for
    repairing equipment in the AFCS and the DBCS, and the additional
    maintenance may possibly affect its operations.

    5 Although USPS P& DC/ F officials are also attempting to clean the
    machines with the HEPA filtered portable vacuum cleaners recently
    acquired, the nozzles are not small enough to allow the staff to clean the
    intricate portions of the equipment, including bearings and electronic
    card cages.

    Page 9 GAO- 02- 838 USPS Air Filtration Systems

    Figure 1: Tray Showing Items Captured by HEPA Filtration System

    USPS believes that installing HEPA filtration systems will minimize the
    risks of airborne biohazards in the event of another anthrax attack,
    reduce dust levels, and lessen workers* allergy- like symptoms. Therefore,
    USPS is proposing the use of HEPA filtration technology as a final
    filtering stage to remove smaller particles that constitute airborne
    biohazards. However, the design and configuration of the HEPA filtration
    system calls for additional requirements.

    First, USPS has identified that the HEPA filtration systems installed at
    the Dulles P& DC/ F require additional power to avoid affecting current
    mail processing equipment. At the Dulles facility, two air filtration
    systems* the Torit and FSX* have been installed. The Torit system is being
    tested on the DBCS. The FSX system is being tested on the AFCS. See figure
    2 for a picture of the HEPA filtration system design at the Dulles P& DC/
    F and figures 3 and 4 are pictures of the FSX and Torit HEPA air
    filtration systems being tested at the Dulles P& DC/ F. Both the FSX and
    Torit systems have been installed with the ductwork covering the entire
    AFCS USPS HEPA Design Calls

    for Additional Requirements

    Page 10 GAO- 02- 838 USPS Air Filtration Systems

    and the DBCS units. The front of the DBCS is covered with plastic, and the
    back of the cabinet doors have channels cut into them to allow the air to
    flow up into the ductwork along the entire length of the machine.

    Figure 2: Design of HEPA Filtration System at Dulles P& DC/ F

    Page 11 GAO- 02- 838 USPS Air Filtration Systems

    Figure 3: Prototype FSX Air Filtration System on the AFCS

    Page 12 GAO- 02- 838 USPS Air Filtration Systems

    Figure 4: Prototype Torit Air Filtration System on the DBCS

    According to USPS officials, this design, as it is configured, presumably
    collects dust from all of the rollers and belts along the length of the
    machine and directs airborne dust to the ductwork. However, this design
    requires a large amount of power to generate enough airflow to move the
    dust through the machines. As a result, the Vice President of Engineering
    is concerned that the amount of energy required to run the HEPA filtration
    systems might overwhelm the power supply at the P& DC/ F and may result in
    an outage if additional power is not provided. He added that the HEPA
    filtration system*s impact on the power supply is a serious concern, which
    the agency plans to address by performing site surveys to determine how
    much additional power is required for HEPA air filtration to operate
    effectively and to avoid degrading the performance of mail processing
    equipment.

    Page 13 GAO- 02- 838 USPS Air Filtration Systems

    Another concern with USPS*s design of the HEPA filtration system on the
    mail processing equipment is that modifications must be made to each type
    of machine to ensure that it is automatically and continuously vacuumed
    and minimal dust escapes. For instance, the air from inside these machines
    will be filtered using HEPA filters before it is discharged back into the
    mail processing environment. The continuous flow of air into the equipment
    and the discharge of air through multistage vacuum filtration (to
    initially filter out larger particles to prevent their plugging the finer
    filters), with a final filtration through a HEPA filter, is expected to
    reduce the release of airborne hazards from processing equipment into the
    facility by several orders of magnitude. To ensure that air is routed to
    the HEPA filters, the AFCS and the DBCS have to be closed up with metal
    and plastic hoods, respectively. See figures 5 and 6 for examples of the
    AFCS metal hoods and DBCS plastic shrouds and figure 7 for the DBCS Torit
    air filtration system.

    Figure 5: AFCS Modified with Metal Hoods

    Installation of HEPA Air Filtration Systems Requires Equipment
    Modifications

    Page 14 GAO- 02- 838 USPS Air Filtration Systems

    Figure 6: DBCS Modified with Plastic Shrouds

    Page 15 GAO- 02- 838 USPS Air Filtration Systems

    Figure 7: DBCS Torit Air Filtration System

    USPS has not yet performed any tests to determine whether the HEPA air
    filtration system will impede the performance of the proposed air sampling
    and detection system. While HEPA filtration systems might reduce the risk
    of exposure to biohazards, USPS will need additional technologies to
    detect and identify potential hazardous materials as early as possible in
    the mailstream. Therefore, in addition to installing air filtration
    equipment, USPS is designing and installing air sampling and detection
    equipment to monitor airborne particles released during automated mail
    processing. USPS plans to use this sampling in conjunction with biohazard
    detection technology to confirm whether anthrax spores are present.
    According to USPS officials, to be most effective in collecting airborne
    anthrax, the air sampling and detection system must be placed directly
    over the automated mail processing machines, including the AFCS and the
    DBCS, where the anthrax dispersion is most likely to occur. The efficacy
    of the air sampling detection equipment, however, might be hindered since
    the AFCS and Air Filtration System*s

    Effects on Air Sampling and Detection Need to Be Determined

    Page 16 GAO- 02- 838 USPS Air Filtration Systems

    DBCS will have to be closed up with metal and plastic hoods, respectively,
    in order for the HEPA filtration equipment to function effectively. Refer
    to figures 5 and 6 for pictures of AFCS and DBCS with the metal and
    plastic hoods installed. Therefore, any HEPA filtration equipment that is
    installed in the P& DC/ F would have to be designed so that it does not
    interfere with anthrax air sampling and detection system. USPS engineers
    recognize this requirement and stated that they would design a *dead
    zone,* or an area free of any negative air pressure, in the location where
    singular pieces of mail are processed through pinch rollers so that a
    proper sample can be taken by the air sampling and detection system.
    Consequently, until USPS tests this requirement, it will not know whether
    the *dead zone* design will be sufficient to ensure that an adequate
    sample can be collected for detection.

    According to industry best practices, investment analysis is a critical
    process required to select and fund technology investments that will
    result in cost- effective solutions focused on measurable and specific
    missionrelated benefits. This process involves examining the fundamental
    cost, benefit, schedule, and risk characteristics of each investment
    before it is funded. USPS has not completed an investment analysis of its
    HEPA air filtration systems currently deployed at the Dulles P& DC/ F and,
    thus, has not justified investing in HEPA filtration systems for
    deployment in its approximately 300 P& DC/ Fs across the country.

    Even though the USPS has prepared cost estimates to develop and implement
    HEPA filtration systems at its nearly 300 P& DC/ Fs across the nation,
    these estimates are incomplete and, therefore, are understated. USPS plans
    to implement the HEPA air filtration systems nationwide, at a cost of $245
    million, by the end of fiscal year 2002 for air filtration on the Loose
    Mail system, AFCS, DBCS, and the Automated Flats Sorting Machine 100
    (AFSM). A supplemental funding request of $61 million is also being
    considered for fiscal year 2002 to acquire additional air filtration
    systems on the regular and outgoing DBCS machines. When added to the $245
    million already being considered for near- term purchase, the total cost
    of HEPA air filtration systems could increase to $306 million by September
    2002. However, these amounts do not include USPS*s recurring costs
    including the air filtration estimate of more than $125 million annually
    for regular activities such as equipment maintenance, purchase of new
    filters, training, and updates to air filtration manuals for more than
    10,000 HEPA filtration systems nationwide. Furthermore, USPS may also
    incur additional costs. For instance, preliminary data show that the HEPA
    filtration systems require more USPS Plans to Deploy

    Air Filtration Systems Nationwide Are Not Justified

    Page 17 GAO- 02- 838 USPS Air Filtration Systems

    power, which results in additional costs to run these systems. According
    to our analysis of the initial implementation of air filtration on the
    Loose Mail systems, an annual cost of about $8 million will be required to
    power these systems. When this amount is added to expenditures associated
    with providing more power to support the 6,300 AFCS and DBCS units on
    which HEPA filtering technology will be installed, the annual cost for the
    extra energy required could be as high as $42 million. 6

    Furthermore, there is the potential risk for greater maintenance costs
    because the HEPA filtration systems and portable vacuum systems appear to
    be less efficient in cleaning the mail processing equipment and may result
    in burned out bearings and equipment parts. USPS maintenance and
    engineering personnel at Dulles and Merrifield informed us that there is
    significant potential for equipment maintenance costs to rise. For
    example, we analyzed the potential cost impact of bearing replacement for
    the DBCS machines and found that, depending on the cost of the bearing, an
    additional $26 to $46 million could be spent on maintenance each year.
    According to USPS officials, the DBCS is the largest fleet of machines the
    USPS owns, and they run all secondary mail. If these machines break down
    more often because the bearings need replacing, this could affect both
    costs and operations. In addition, USPS will also have to consider the
    risks of increased maintenance costs associated with other equipment such
    as the AFCS, Loose Mail, and AFSM 100, which also contain bearings.
    However, until USPS completes a risk assessment to determine if the
    bearings are wearing out faster using the new maintenance procedures, it
    cannot know the extent of the additional maintenance costs that will be
    required.

    With respect to benefits, USPS officials stated that the agency is
    reluctant to quantify benefits because it is committed to spend whatever
    is necessary to protect its employees from future biohazard attacks.
    Therefore, the officials noted that it is difficult to quantify the
    benefits of this technology and its ability to safeguard human life.
    Nevertheless, without completing required tests to confirm that the HEPA
    filtration systems are able to contain airborne anthrax in a mail
    processing environment, USPS will not know whether it is making a
    worthwhile investment.

    6 These cost estimates assume that the air filtration systems are running
    at the same time the machines are processing the mail.

    Page 18 GAO- 02- 838 USPS Air Filtration Systems

    We recognize the challenge that USPS faces in trying to protect its
    workers from airborne biohazards while trying to maintain its operations
    and control costs. By designing and testing air filtration systems on its
    mail processing machines, USPS has taken steps to reduce risk of exposure
    from biohazards to its employees. However, the USPS HEPA air filtration
    system design has not yet been proven to contain anthrax spores or reduce
    the levels of dust in a mail processing environment and in mail processing
    equipment. In addition, the HEPA filtration system*s design and
    installation require additional energy and modifications to the mail
    processing equipment in order to work properly. Furthermore, USPS has not
    verified through testing that the HEPA air filtration system will not
    interfere with the air sampling and detection system. Finally, even though
    USPS has identified initial cost estimates, it has not yet completed
    investment analyses to identify the costs, benefits, and risks associated
    with alternative deployment scenarios for HEPA filtration systems. As a
    result, USPS has no assurance that investing in HEPA air filtration
    systems will provide adequate risk reduction to its employees.

    Given the magnitude of this investment and its impact on maintaining the
    mail processing equipment, as well as potential effects on its operations
    and proposed biohazard detection capabilities, it is important that the
    USPS show the specific performance gains attributable to this initiative
    before full deployment is pursued.

    To ensure that USPS is making a sound investment, we recommend that the
    Postmaster General direct the Vice President of Engineering to complete
    the following actions before determining whether to proceed with a large-
    scale rollout of air filtration systems at 300 USPS P& DC/ Fs:

     Perform tests to determine (1) the HEPA air filtration system*s ability
    to trap released hazards and other contaminants and (2) what level of
    hazards or contaminants could be released into the mail processing
    environment as a result of the air filtration system*s design.  Perform
    integrated tests with HEPA air filtration system and detection

    technologies being considered to determine whether the *dead zone* will
    impede the detection technology*s performance.  Identify the effects of
    the HEPA filtration system*s energy consumption on

    mail processing equipment performance and what could be done to mitigate
    this risk.  Complete an investment analysis to prioritize USPS*s plans to
    spend

    approximately $300 million to deploy the HEPA air filtration systems
    nationwide. Conclusions

    Recommendations

    Page 19 GAO- 02- 838 USPS Air Filtration Systems

     Analyze alternative solutions, including whether maintenance costs can
    be reduced by using compressed air for cleaning mail processing equipment
    after implementing a suitable detection technology.

    USPS provided comments on a draft of this report in a letter dated August
    9, 2002. These comments are summarized below and reproduced in appendix I.
    In commenting on a draft of our report, USPS shared overall concerns that
    (1) our report placed too much emphasis on the supposed secondary benefits
    of the air filtration systems, (2) their cost estimates in its Emergency
    Preparedness Plan are low, and (3) increased maintenance costs are not
    anticipated.

    On the other hand, USPS generally agreed with our recommendations to
    continue testing the system to confirm its ability to trap anthrax spores
    and to test for interaction between the air filtration and detection
    systems. Furthermore, the Service noted that detailed site surveys would
    be performed at each P& DC/ F as part of the deployment planning process
    to ensure that operation of these systems will not adversely affect the P&
    DC/ F*s power supply. USPS also commented that a Decision Analysis Report
    (DAR) is being prepared that will address both start- up costs to procure
    and deploy the equipment, as well as recurring costs such as increased
    electrical usage, maintenance support, spare parts, and training costs for
    HEPA air filtration systems. In its comments, the Service stated that it
    plans to submit a DAR that must be reviewed and approved by senior
    management and voted on by USPS*s Board of Governors prior to deployment.
    Finally, USPS agreed with our recommendation that it review the
    prohibition on using compressed air to clean mail processing equipment
    after effective biohazard detection systems are in place.

    With regard to the concern about too much emphasis on secondary benefits,
    USPS noted that the main purpose of adding air filtration systems to the
    mail processing equipment is to minimize the potential exposure risk to
    postal employees and customers in the event of another anthrax attack.
    Further, the Service stated that it does not expect the air filtration
    systems to eliminate the need for daily cleaning of the mail processing
    equipment, and that no cost reductions for reducing nuisance dust were
    used to justify the deployment of these systems. We modified our report to
    address USPS*s concern that the draft report placed too much emphasis on
    the secondary effects of air filtration systems.

    The reason we also focused on the HEPA air filtration system*s ability to
    clean mail processing equipment is because an additional maintenance
    Agency Comments

    and Our Evaluation

    Page 20 GAO- 02- 838 USPS Air Filtration Systems

    cost of up to $46 million annually could result from installing these HEPA
    air filtration systems and changing maintenance practices from compressed
    air blowing to hand vacuuming. Furthermore, USPS*s Emergency Preparedness
    Plan discusses the HEPA air filtration system*s ability to clean equipment
    and also states that such designs for reducing nuisance dust were under
    way prior to the anthrax attacks.

    USPS*s comments additionally stated that the cost for deploying HEPA air
    filtration systems nationwide was based on the best information available
    at the time. The Service anticipates that as it moves further into testing
    and manufacturing, it may run into unanticipated complications that will
    require revisions to the cost estimates. We agree that unanticipated
    complications may arise and, as a result, additional funding may be
    required to reengineer and resolve these issues, which will most likely
    increase the cost to develop, deploy, and maintain the HEPA air filtration
    systems. Furthermore, we are concerned that the costs are understated due
    to the potential for increased operational costs to power the equipment.
    This potentially could add up to $42 million annually.

    The Service also had concerns relating to our finding on increased
    maintenance costs. The comments stated that USPS has not seen any increase
    in the number of machine repairs and parts replacements that were required
    because of dust buildup in bearings and other components and, therefore,
    does not foresee any increased maintenance costs. Our audit work and
    evidence provided to us by USPS engineers shows that bearing replacement
    rates have changed in the last 6 months. USPS may need to conduct more
    studies and analysis before it will know for sure whether the cost of the
    new maintenance procedures is higher or lower.

    With regard to USPS*s concurrence with our other recommendations, these
    planned actions are the appropriate steps to take. USPS plans to conduct
    additional testing at the Dulles P& DC/ F to determine the system's
    effectiveness in capturing biohazards and to determine the amount of
    biohazards that might be released into the mail processing environment.
    Testing in an P& DC/ F environment with particles in the 2 to 6 micron
    range can be used by the USPS to confirm that the system operates as
    designed and will provide the USPS with objective data to make appropriate
    modifications, if necessary, to improve the design.

    Finally, once the additional testing is completed, USPS plans to complete
    the DAR for the HEPA air filtration system and present it for management
    review. This should ensure that USPS management has accurate and

    Page 21 GAO- 02- 838 USPS Air Filtration Systems

    complete information on the capabilities and cost of the air filtration
    system prior to making a decision on nationwide implementation.

    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 date of this letter. At that time, we will provide copies to
    interested congressional committees, the Postmaster General, and Chief
    Executive Officer of USPS. We also will make copies available to others
    upon request. In addition, the report will be available at no charge on
    the GAO Web site at http:// www. gao. gov.

    If you have any questions on matters discussed in this report, please
    contact me at (202) 512- 6412 or Madhav Panwar, Director, at (202) 512-
    6228. We can also be reached by E- mail at rhodesk@ gao. gov and panwarm@
    gao. gov, respectively. Individuals making key contributions to this
    report were Karen A. Richey, Yvette R. Banks, Teresa Anderson, Teea Kim,
    and Sushil Sharma.

    Keith A. Rhodes Chief Technologist, Applied Research and Methods

    Appendix I: Comments from the U. S. Postal Service

    Page 22 GAO- 02- 838 USPS Air Filtration Systems

    Appendix I: Comments from the U. S. Postal Service

    Appendix I: Comments from the U. S. Postal Service

    Page 23 GAO- 02- 838 USPS Air Filtration Systems

    Appendix I: Comments from the U. S. Postal Service

    Page 24 GAO- 02- 838 USPS Air Filtration Systems (460532)

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