Radiological Sources in Iraq: DOD Should Evaluate Its Source	 
Recovery Effort and Apply Lessons Learned to Future Recovery	 
Missions (07-SEP-05, GAO-05-672).				 
                                                                 
Following the invasion of Iraq in March 2003, concerns were	 
raised about the security of Iraq's radiological sources. Such	 
sources are used in medicine, industry, and research, but	 
unsecured sources could pose risks of radiation exposure, and	 
terrorists could use them to make "dirty bombs." This report	 
provides information on (1) the readiness of the Department of	 
Defense (DOD) to collect and secure sources, (2) the number of	 
sources DOD collected and secured, (3) U.S. assistance to help	 
regulate sources in Iraq, and (4) the lessons DOD and the	 
Department of Energy learned.					 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-672 					        
    ACCNO:   A35897						        
  TITLE:     Radiological Sources in Iraq: DOD Should Evaluate Its    
Source Recovery Effort and Apply Lessons Learned to Future	 
Recovery Missions						 
     DATE:   09/07/2005 
  SUBJECT:   Federal regulations				 
	     Foreign governments				 
	     International organizations			 
	     Policy evaluation					 
	     Radiation safety					 
	     Radioactive wastes 				 
	     Radiological warfare				 
	     Regulatory agencies				 
	     Safety standards					 
	     Strategic planning 				 
	     Weapons of mass destruction			 
	     DOD Operation Iraqi Freedom			 

******************************************************************
** This file contains an ASCII representation of the text of a  **
** GAO Product.                                                 **
**                                                              **
** No attempt has been made to display graphic images, although **
** figure captions are reproduced.  Tables are included, but    **
** may not resemble those in the printed version.               **
**                                                              **
** Please see the PDF (Portable Document Format) file, when     **
** available, for a complete electronic file of the printed     **
** document's contents.                                         **
**                                                              **
******************************************************************
GAO-05-672

                 United States Government Accountability Office

                     GAO Report to Congressional Committees

September 2005

RADIOLOGICAL SOURCES IN IRAQ

  DOD Should Evaluate Its Source Recovery Effort and Apply Lessons Learned to
                            Future Recovery Missions

                                       a

GAO-05-672

Highlights of GAO-05-672, a report to the Senate and House Committees on
Armed Services

Following the invasion of Iraq in March 2003, concerns were raised about
the security of Iraq's radiological sources. Such sources are used in
medicine, industry, and research, but unsecured sources could pose risks
of radiation exposure, and terrorists could use them to make "dirty
bombs." This report provides information on (1) the readiness of the
Department of Defense (DOD) to collect and secure sources, (2) the number
of sources DOD collected and secured, (3) U.S. assistance to help regulate
sources in Iraq, and (4) the lessons DOD and the Department of Energy
learned.

GAO recommends, among other things, that DOD (1) assess lessons learned
from securing sources in Iraq and (2) ensure that advanced planning occurs
prior to any future missions. DOD concurred or partially concurred with
most of our recommendations and did not concur with two of them, stating
that our report focused on the later phase of source recovery and that it
accepted our recommendations for that phase. Our recommendations apply to
all phases of the effort and we revised some to clarify this. The
Department of State provided clarifications regarding U.S. assistance to
Iraq and reasons for a delay in approval of export licensing. DOE had no
written comments but stated it would work with DOD to help define sources
of greatest risk.

www.gao.gov/cgi-bin/getrpt?GAO-05-672.

To view the full product, including the scope and methodology, click on
the link above. For more information, contact Gene Aloise at (202)
512-3841 or [email protected].

September 2005

RADIOLOGICAL SOURCES IN IRAQ

DOD Should Evaluate Its Source Recovery Effort and Apply Lessons Learned to
Future Recovery Missions

DOD was not ready to collect and secure radiological sources when the war
began in March 2003 and for about 6 months thereafter. Before DOD could
collect radiological sources, it had to specify criteria for which sources
should be collected and how to safely collect them, coordinate within DOD,
coordinate assistance from the Department of Energy (DOE), and resolve
contract issues. DOD did not issue guidance for collecting and securing
sources until July 2003 and did not finalize the terms of the contract to
collect sources until September 2003. Until radiological sources could be
collected, some sources were looted and scattered, and some troops were
diverted from their regular combat duties to guard sources in diverse
places.

In June 2004, DOD removed about 1,000 of the 1,400 radiological sources
collected in Iraq and sent them to the United States for disposal. DOD
left in place approximately 700 additional sources that it had judged were
adequately secured and being used properly by Iraqis. According to DOD and
Department of State officials, however, the total number of radiological
sources in Iraq remains unknown.

The United States assisted in establishing an Iraqi agency to regulate
radiological sources. Since June 2004, State and DOE have helped this new
agency develop an action plan with assistance from the International
Atomic Energy Agency. However, according to State officials, because of
uncertainties associated with the continuing formation of the Iraqi
government, State will have to monitor Iraqi efforts to ensure the
continued growth and success of an independent, competent, and sustainable
regulatory authority for the control of radioactive sources and materials.

Both DOD and DOE are considering improvements based on their Iraq
experiences. A 2004 study of lessons learned, requested by DOD,
recommended that DOD develop the capability to quickly eliminate weapons
of mass destruction in hostile environments, but it did not focus on the
narrower radiological source mission. In contrast, DOE has contracted for
a study to examine lessons from its role in removing radiological sources
from Iraq.

Bunker Where DOD Secured Radiological Sources, Tuwaitha, Iraq

Source: DTRA.

Contents

  Letter

Results in Brief
Background
DOD Was Not Ready to Collect and Secure Radiological Sources in

Iraq at the Start of the Hostilities in March 2003

DTRA Recovered or Left Secure in Place about 2,100 Radiological Sources,
but the Number of Unsecured Sources Remaining in Iraq Is Unknown

The United States Helped Create an Iraqi Agency to Regulate Sources, but
Future Assistance Is Uncertain DOD Has Not Assessed Its Source Recovery
Effort, but DOE Is

Considering Lessons Learned Conclusions Recommendations for Executive
Action Agency Comments and Our Evaluation

1 3 6

8

14

24

29 31 32 33

Appendixes

       Appendix I: Scope and Methodology 37 Appendix II: The National Defense
    University Study 41 Appendix III: Comments from the Department of Defense
     44 Appendix IV: Comments from the Department of State 48 Appendix V: GAO
                                         Contact and Staff Acknowledgments 51

Figures Figure 1:

Figure 2: Figure 3:

Figure 4:

Figure 5:

An Intact Pillar and a Looted Metal Pillar That Contained
Cobalt Sources 8
Sites from Which Unsecured Sources Were Collected 16
Bunker Where DTRA Secured Radiological Sources,
Tuwaitha, Iraq 17
Number of DTRA Contractor Missions and Number of
Insurgent Attacks throughout Iraq, June 2003 to May
2004 19
Protected Living Area for DOE Experts at the Tuwaitha
Nuclear Research Center 22

Contents

Abbreviations

DOD Department of Defense
DOE Department of Energy
DTRA Defense Threat Reduction Agency
IAEA International Atomic Energy Agency
IRSRA Iraqi Radiological Source Regulatory Authority
MOST Ministry of Science and Technology (Iraq)
NDU National Defense University
WMD weapons of mass destruction

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. However, 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.

A

United States Government Accountability Office Washington, D.C. 20548

September 7, 2005

The Honorable John Warner Chairman The Honorable Carl Levin Ranking
Minority Member Committee on Armed Services United States Senate

The Honorable Duncan Hunter Chairman The Honorable Ike Skelton Ranking
Minority Member Committee on Armed Services House of Representatives

In March 2003, citing the failure of Iraq to live up to agreements to
disarm itself of weapons of mass destruction (WMD), and other concerns,
the United States and its coalition allies invaded Iraq. This conflict is
known as Operation Iraqi Freedom. During late 2002 and early 2003, the
U.S. Department of Defense (DOD) had made plans to find and eliminate the
suspected WMD. DOD's Defense Threat Reduction Agency (DTRA) was to be
responsible for hiring a contractor to dispose of WMD and their component
materials, such as biological agents, chemicals, and radioactive
materials.1 The radioactive materials included (1) nuclear materials, such
as processed uranium, which could be used in a nuclear weapon, and (2)
radiological sources, which are widely used throughout the world in
medicine, agriculture, research, and industry and could be combined with
conventional explosives to create a radiological dispersion device, a
weapon known as a "dirty bomb." Thus, DOD's plan to eliminate WMD included
the removal of radiological sources, which are not weapons but could be
improvised by terrorists into dirty bombs.

The Department of Energy (DOE) and Department of State also had
responsibilities in the mission to secure radiological sources in Iraq. By
early 2003, DOD was planning for DOE to be involved in both removing and

1For information on DTRA's broader mission to address the threat of WMD,
see GAO, Weapons of Mass Destruction: Defense Threat Reduction Agency
Addresses Broad Range of Threats, but Performance Reporting Can Be
Improved, GAO-04-330 (Washington, D.C.: Feb. 13, 2004).

disposing of sources from Iraq. After the transfer of power from the
Coalition Provisional Authority2 to the interim Iraqi government in June
2004, State had lead responsibility for helping Iraq regulate the
radiological sources remaining in the country.

Although the United States did not find stockpiles of WMD in Iraq, U.S.
forces found partially processed uranium and radiological sources that the
International Atomic Energy Agency (IAEA) had previously secured at
nuclear facilities. In addition, U.S. forces found radiological sources
throughout Iraq, many of which were unsecured and in danger of being
looted. Citing media reports of looting at nuclear sites, IAEA and Members
of the Congress raised concerns about the security of nuclear materials
and radiological sources. Reflecting these concerns, during a July 2003
Senate Armed Services hearing, the Ranking Minority Member of the
Readiness and Management Support Subcommittee asked the Secretary of
Defense about the security of radiological sources in Iraq. DOD replied in
a January 2004 letter that numerous sources had been collected and that
efforts were under way to identify and secure others.

Shortly thereafter, the Ranking Minority Member's office asked us for an
update on the security of radiological sources in Iraq, and we initiated a
review of the effort to collect and secure these sources. Because of the
broad interest in this issue, we conducted this work under the authority
of the Comptroller General and are issuing this report to the Senate and
House Committees on Armed Services. This report (1) assesses DOD readiness
to collect and secure radiological sources in Iraq from the start of the
2003 war; (2) presents information on the number of radiological sources
DTRA had secured by the time of the June 2004 transition to the interim
Iraqi government; (3) describes the assistance the United States has
provided, and plans to provide in the future, to the Iraqi government to
help regulate radiological sources in Iraq; and (4) examines DOD and DOE
actions to assess their experiences in Iraq and apply any lessons learned
to possible future radiological source collection missions.

To assess DOD's readiness to collect and secure radiological sources, we
reviewed available policy guidance and reports on individual missions to
collect sources and interviewed DOD and contractor officials. To present
information on the number of radiological sources secured, we reviewed

2The Coalition Provisional Authority, led by the United States and the
United Kingdom, was responsible for temporarily governing Iraq.

DOD inventories of sources left in Iraq and sources collected, interviewed
officials about the reliability of these inventories, and reviewed
available mission guidance and other documents. We assessed the
reliability of DTRA's inventories of radiological sources, including
independently corroborating the information when possible, based on
discussions with those responsible for the inventories. With one
exception, we determined that the data were sufficiently reliable for the
purposes of this report. To describe U.S. efforts to help the interim
Iraqi government regulate sources, we examined the Department of State's
planning documents and a Coalition Provisional Authority order to
establish an Iraqi agency to regulate radiological sources. We also
discussed plans for assistance with State and DOE officials as well as
with Iraqi officials visiting the United States. Finally, to describe what
DOD and DOE have done to learn from their experience in Iraq, and how such
lessons might be applied in the future, we interviewed DOD and DOE
officials about their efforts to identify and document lessons learned and
examined draft and published documents on the mission to dispose of Iraqi
WMD. Because of the continuing hostilities, we did not travel to Iraq. We
performed our work from May 2004 through August 2005 in accordance with
generally accepted government auditing standards. Details of our
methodology are provided in appendix I.

Results in Brief	DOD was not ready to collect and secure radiological
sources when the war began in March 2003 and for about 6 months
thereafter. Although DOD's prewar plan included removing radiological
sources from Iraq, DOD did not issue guidance for collecting and securing
them until July 2003 and did not finalize the terms of the contract that
would allow the radiological sources to be collected and secured until
September 2003, 6 months after the beginning of the war. During this
6-month period, individual military commanders, who possessed limited
equipment to handle the radiological sources they were finding, had to
make decisions regarding which radiological sources should be secured and
how to safely collect them. Illustrating the readiness problems, one
commander, lacking the proper equipment, had to move highly radioactive
sources with an ice cooler that was lined with lead bricks. In other
instances, troops were diverted from their regular combat duties to guard
unsecured radiological sources at various places around the country until
the sources could be properly packaged and removed. According to one
officer, field commanders were concerned that their troops guarding
sources in some places were placed at greater risk for enemy attack. In
addition, the scattering of radiological sources by looters complicated
their collection. DTRA was responsible for

collecting radiological sources in Iraq. However, DTRA officials explained
that collecting these sources only gradually became a mission focus as it
became clear that the broader hunt for WMD was unsuccessful. Furthermore,
before DTRA could collect radiological sources, it had to specify criteria
regarding which sources should be collected and how to safely collect
them, coordinate within DOD for armed protection for DTRA's contractor as
they sought radiological sources, coordinate assistance from DOE, and
resolve legal liability issues regarding potential damages resulting from
its contractor's work to collect the radioactive sources.

By the end of June 2004, DTRA had removed about 1,000 of 1,400 collected
radiological sources from Iraq and sent them to the United States. DTRA
left in place approximately 700 additional sources that it had judged were
adequately secured and being used properly by Iraqis-for example, for
industrial and medical purposes. According to DOD and State officials,
however, the total number of unsecured radiological sources in Iraq
remains unknown. For instance, even after DTRA completed collecting and
securing sources, according to Department of State officials, a
neighboring country twice detected trucks leaving Iraq with unsecured
radiological sources. Despite the difficulties encountered in collecting
and securing radiological sources in Iraq during ongoing hostilities,
according to DOD officials, DTRA and its contractor successfully carried
out about 140 collection missions without fatalities or severe exposure to
radiation. However, for the removal of sources from Iraq, DOE had
difficulty obtaining accurate information from DOD regarding the type and
radioactivity of the sources. DOE needed this information to determine the
type and number of transportation containers needed to remove the sources.
According to DOE officials, the final disposition of the radiological
materials removed from Iraq may take longer and cost more than estimated
because a legal determination is needed regarding whether the United
States government owns the material or is merely serving as its custodian.
According to these officials, they raised this issue of ownership when the
removal mission was being planned, but it was never resolved.

The United States assisted in establishing an Iraqi agency to regulate
radiological sources. The Department of State worked with the Coalition
Provisional Authority and later with the interim government to create an
Iraqi agency to regulate radiological sources, the Iraqi Radiological
Source Regulatory Agency. In addition, State developed budget and
organizational plans for the regulatory agency and shared them with Iraqi
officials appointed by the Coalition Provisional Authority. Since the
political

transition to the interim Iraqi government in June 2004, State has helped
to firmly establish the agency by facilitating the transfer of DTRA
equipment to the new government and, with funding support from DOE,
coordinating meetings between Iraqi officials and the IAEA to create an
action plan. Further, State, DOE, and IAEA have agreed to offer additional
technical and financial support in such areas as regulation writing,
border control, and security upgrades. However, according to State
officials, because of uncertainties associated with the continuing
formation of the Iraqi government, State will have to monitor Iraqi
efforts to ensure the continued growth and success of an independent,
competent, and sustainable regulatory authority for the control of
radioactive sources and materials.

Both DOD and DOE are considering improvements based on their Iraq
experiences. However, DOD's assessment focuses on its intended WMD mission
rather than on the radiological source mission. DOD requested a study from
its National Defense University to assess lessons learned from the WMD
mission in Iraq and to recommend improvements for possible future
missions. The resulting report did not offer any observations or
recommendations regarding the mission to collect and secure radiological
sources in Iraq. However, it stated that DOD had not sufficiently planned
and prepared for the WMD mission; had shortfalls in the needed
transportation, military security, and logistics resources; and had
operational difficulties because of the extensive looting, public
disorder, and hostile security environment. The report recommended that
DOD develop the capability to quickly eliminate WMD in hostile
environments and develop a permanent organization to eliminate WMD.
Consistent with this recommendation, DOD assigned its Strategic Command
responsibility for planning and ensuring the capacity for possible future
missions to eliminate WMD, which a DOD Joint Staff officer told us would
include the elimination of radiological sealed sources. In contrast to
DOD's focus on the WMD mission, DOE has contracted for a study to examine
lessons from its radiological source removal mission. DOE considered
establishing a reserve of equipment to handle and package radiological
material to ensure rapid action in the future but decided that it could
not proceed because of current budget constraints.

To ensure that problems experienced with collecting and securing
radiological sources in Iraq are avoided to the extent possible in future
missions, we are recommending that the Secretary of Defense, among other
things, ensure that planning for such missions is completed prior to their
initiation. Such planning should include developing specific guidance for
collecting and securing radiological sources and coordinating any

needed assistance with DOE. Furthermore, we are recommending that the
Secretary of Defense comprehensively review DOD's experience with
collecting and securing radiological sources in Iraq for lessons learned
to apply to possible future missions.

We provided the Departments of Defense, State, and Energy with draft
copies of this report for their review and comment. DOD concurred or
partially concurred with most of our recommendations and did not concur
with two of them, stating that our report focused on the later phase of
source recovery and that it accepted our recommendations for that phase.
Our recommendations apply to all phases of the effort and we revised some
recommendations to clarify this. We also incorporated into the report
State's clarifications of (1) its current outlook for U.S. assistance to
Iraq on radioactive source regulation and (2) the reason for the delay in
State's approval of export licensing. DOE had no written comments on the
report but did state that it will work with DOD to determine criteria to
define which radiological sources are of greatest risk.

Background	Widespread looting-including looting of radiological
sources-became a major problem in Iraq after the March 2003 coalition
forces invasion, complicating U.S. efforts to secure and collect
radiological sources. Media reports of the looting at Iraq's Tuwaitha
Nuclear Research Center, for example, brought public attention to the
scattering of radioactive materials throughout populated areas, posing
health and safety risks to Iraqis. In May 2003, the IAEA, which had
inventoried nuclear and radiological materials at Tuwaitha, raised
concerns about Iraqi citizens' exposure to radiation and publicly asked
the United States to secure these materials.

Given the extensive looting, DOD could not assume that facilities and
items within them, including radiological sources, would remain intact or
in place for later collection without being secured. Many facilities that
were no longer under the control of Iraqis, such as abandoned government
research facilities and industrial complexes, were looted. For example, a
2004 government report on the search for WMD stated that looters often
destroyed sites after a coalition military unit moved through an area,
since the coalition did not have the forces available to secure the
various sites thought to be associated with WMD. According to one DTRA
official, the looting was more extensive than he had ever seen before. The
looting was reported to have included removing wiring and pipes from walls
and from the ground; stealing desks, windows, sinks, and floors; and even
dismantling and removing whole buildings. While some looting may have

been done to thwart the U.S. mission, according to DTRA officials, most of
it seemed to be related to selling or reusing common materials such as
scrap metal rather than seeking radiological or nuclear materials. At the
Tuwaitha facility, for example, looters dumped partially processed uranium
ore from large containers onto the floor and took the containers.

DOD found that fully securing sources from looters was challenging because
of their persistence. According to a DTRA official's personal assessment,
no amount of forces could have controlled the rampant looting. At the
Tuwaitha Nuclear Research Center, DOD concentrated security in those areas
where radiological and nuclear materials were stored, but looters
continued to penetrate the less secure areas of Tuwaitha, a large complex
of over 90 buildings.

The scattering of radiological sources by looters complicated the later
collection of those sources. In one dramatic instance, looters stole large
cobalt sources from an Iraqi radiological test site in early September
2003, when U.S. troops were guarding the site. The large, open site, which
was apparently designed for carrying out radiation exposure experiments in
the surrounding areas, contained eight metal pillars, each with a pulley
system to raise a cobalt source from a concrete storage pit to the
pillar's top. Looters tore down and removed three of these pillars and
also took the cobalt sources from two of them. (See fig. 1.) After several
days of extensive searches in the area, DTRA recovered both stolen
sources. According to a DTRA official, the metal pillars were probably the
looters' intended target, and the sources may have been taken
unintentionally when they became caught in the pulley mechanisms.

Figure 1: An Intact Pillar and a Looted Metal Pillar That Contained Cobalt
                                    Sources

                                 Source: DTRA.

DOD Was Not Ready to Collect and Secure Radiological Sources in Iraq at
the Start of the Hostilities in March 2003

For about the first 6 months after the war began in March 2003, military
commanders had insufficient guidance and equipment appropriate for
collecting and securing radiological sources that they discovered. As a
result, they were forced to make ad hoc decisions about recovering and
securing these sources. During this time, DTRA-the agency DOD had assigned
to the WMD elimination mission 12 days before the war began-was working to
fill gaps in preparations for the mission to collect and secure
radiological sources. It was not until September 2003 that DTRA finalized
the terms of the contract for collecting the radiological sources and
collections began throughout Iraq.

Insufficient Guidance and Equipment Left Military Commanders to Make Ad
Hoc Decisions about Collecting Radiological Sources from March to
September 2003

Military commanders in Iraq initially had no policy guidance on which
radiological sources to collect, and what to do with them once they were
collected. DOD did have some specialized teams with radiological
expertise, such as the 11-person Nuclear Disablement Team, which had been
set up to disable WMD and associated production facilities in Iraq. This
team had the expertise to move radiological sources, including packaging
radioactive material and designing safety procedures to minimize radiation
exposure. However, military commanders lacked sufficient equipment
appropriate for safely collecting and moving radiological sources.

Without adequate official guidance and equipment to handle the
radiological sources they encountered in Iraq, military commanders were
left to make ad hoc decisions about recovering and securing the sources.
They acted because they were concerned about the inherent health and
safety risks of radiological sources to coalition soldiers and the Iraqi
populace, as well as the potential for enemy or terrorist forces to use
the sources to construct dirty bombs. For example, lacking the proper
radiation shielding equipment, the Nuclear Disablement Team moved a
radiological source to Tuwaitha with improvised shielding because an
officer judged that the unshielded source posed the risk of radiation
exposure to Iraqis working in the vicinity. The team created what was
described as "field expedient" packaging by lining an ice chest with lead
bricks that were brought from the Tuwaitha Nuclear Research Center.
However, the container did not sufficiently shield the driver of the
military vehicle carrying the source from radiation exposure. Therefore,
the team further improvised shielding by placing metal sheets salvaged at
the site between the driver and the container in the back of the vehicle.
This additional shielding reduced the radiation at the driver's seat to a
level that just met the team's safety standard for exposure. However, the
radiation in the back of the vehicle still exceeded that standard.
Consequently, a second military vehicle followed the loaded vehicle at a
safe distance to prevent occupants of any other vehicles from following so
closely that they would be exposed to unsafe levels of radiation. On the
basis of his assessment of the team's experience with moving the source
described above, the commander of the Nuclear Disablement Team decided it
was too risky to allow his troops to move any more sources without proper
handling equipment and containers.

Because some military officers were reluctant to move radiological sources
to a single consolidation site without adequate handling and packaging
equipment or official guidance, coalition forces had their troops guarding

sources around Iraq. In some cases this posed health risks-for example,
some sources were secured in bases where U.S. troops were already
stationed, creating the need to protect the troops from accidental
exposure to radiation. When sources were secured outside controlled areas,
however, security risks resulted. For example, according to a DTRA
official, field commanders complained to him after he arrived in July 2003
that protecting radiological sources in some field locations exposed their
troops to increased risks of attacks. Estimates of how many soldiers were
removed from their military duties to guard sources were not available,
but we were told of instances in which troops were left guarding sources
for several months. According to a DOE expert involved in DTRA's later
collections, for example, a small group of troops had guarded sources at
an oil drilling operation from May until early September 2003.

While Military Commanders Improvised, DTRA Worked to Complete Preparations
for Collecting Radiological Sources

Between March and September 2003, as individual military commanders acted
independently to collect or secure radiological sources when they
discovered them, DTRA was working to fill gaps in preparations for the
mission to collect and secure radiological sources. According to DTRA
officials, they only gradually became concentrated on radiological sources
as their initial focus on eliminating WMD diminished because stockpiles of
chemical, biological, and nuclear weapons were not found. First, DTRA
tried to establish much-needed guidance on which radiological sources to
collect and where to consolidate them. According to a DTRA official, these
and other issues had been discussed in prewar planning in late 2002, but
guidance had not been issued. In July 2003, the DOD Office of Policy
issued guidance on collecting and securing radiological sources for field
commanders, which a DTRA official told us was all the policy guidance that
DTRA needed. However, DTRA still needed to specify standards for health
and safety as well as for transportation for its collection missions.
According to the DTRA commander who set up collection operations in Iraq,
DTRA used U.S. standards to ensure safety, but these standards were
modified for the Iraq situation. For example, instead of using radioactive
cargo placards on vehicles, which would be required by U.S. standards but
might attract an insurgent attack, DTRA notified local military commanders
along the route of its cargo when moving sources.

In addition, DTRA engaged in extensive, and ultimately unsuccessful,
coordination within DOD to provide protection for its contractor at the
Tuwaitha storage site through a contracted security force, but eventually
obtained protection for its collection mission through coalition forces
headquarters. This security force stood by for deployment to Iraq while
the

Department of Defense General Counsel, DOD's Central Command, and
coalition military headquarters considered DTRA's request to arm this
force. When this request was denied, DTRA decided in late 2003 that
sufficient protection could be provided by military forces. For each
collection mission, DTRA coordinated protection through the coalition
forces headquarters, and could draw upon a military police platoon for a
security escort.

Also, starting in March 2003, DTRA worked to coordinate arrangements with
DOE for its assistance with collecting radiological sources. DOE was to
send both technical experts from one of its national laboratories and
shipping containers to Iraq for the collection effort. However, the
arrangements were complicated by DOE's concerns about potential disposal
of collected sources at its U.S. facilities and about the safety of DOE
experts working in Iraq, as well as by communication difficulties. DOE had
concerns about potential lawsuits arising from disposing of sources at its
U.S. facilities. A DOE official told us that mislabeled or improperly
packaged containers could lead to lawsuits if, for example, a source in a
container was mislabeled and turned out to be a source that DOE's U.S.
site was not licensed to possess, or if poor packaging led to radiation
leakage in the United States. Consequently, DOE insisted that its
technical experts be present when the sources were collected to identify
and package them in Iraq, before they were transported to DOE's U.S.
facilities, and DTRA agreed. When collections began, however, the danger
of packaging sources in a hostile environment led DTRA to instead use
temporary packaging in the field, followed by interim packaging at the
Tuwaitha facility. The final packaging of the sources did not occur until
May 2004 when DOE experts packaged them for shipment to the United States.

DOE also had concerns about the safety of its experts while overseeing the
packaging of the sources in Iraq. Consequently, DOE proposed a contract
provision that required DTRA to make every reasonable effort to evacuate
DOE experts to a safe area if hostilities broke out. DTRA initially said
it could not accept this contract provision because it did not control the
troops who could provide such protection. Eventually the contract said
that the DOE experts would not be exposed to unreasonable risks, but,
according to a DOE official, the discussion about a military protection
clause held up the contract for a couple of weeks.

Unclear communications also affected the negotiations between DTRA and
DOE. For example, according to a DOE official, at one meeting DTRA told
DOE that DTRA either had shipping containers or could get them. But a few
weeks later, DTRA asked DOE to provide the containers. Then communication
about the number of containers needed became an issue because DTRA could
not know the number or type of radiological sources that would need to be
transported. Finally, the DOE expert preparing a contract proposal had
difficulty defining the scope of services to be provided to DTRA because
DTRA's plan was not clear to him. For example, he was not initially aware
that the DOE experts would have only an oversight role and that DTRA was
planning to use a contractor to do the collection work.

In addition, between March and September 2003, DTRA was also negotiating
with its contractor to collect sources. This process was delayed in large
part by the contractor's refusal to begin work until it obtained
protection from legal claims for damages that could result from their
work-that is, until they were given indemnification. Resolving this legal
indemnification issue was delayed, in part, because DTRA contracting
officials, who were uncertain about the infrequently used procedures for
granting indemnification for work done under potentially hostile
conditions, asked the contractor to provide what turned out to be
unnecessary detail on the various damage scenarios that indemnification
would cover. For example, one concern was that a convoy truck loaded with
radiological sources would be fired upon, resulting in the radiological
contamination of the area. In the end, DTRA decided that the
indemnification language would be general and provided the contractor with
indemnification in September 2003. Getting DOE experts working in Iraq was
also delayed by indemnification issues, but their indemnification was
settled earlier.

The contractor's acquisition of equipment, such as helmets and body armor,
was also delayed, although not as long as the indemnification. The State
Department approves the export of such U.S.-origin defense products to
other countries under the International Traffic in Arms Regulations;
approval took over 50 days in the case of one request by the DTRA
contractor. According to a State official, this delay occurred despite
procedures to expedite approval of export applications for Operation Iraqi
Freedom because this particular approval required congressional
notification, a requirement State could not meet until Congress returned
to session. As a result of these delays, according to a DTRA official,
DTRA's contractor wore helmets obtained from other countries because the

helmets could be obtained sooner. In addition, the contractor, which was
responsible for obtaining all needed equipment for the collection mission,
initially lacked some equipment. According to a DTRA official, in one
instance, the contractor did not allow its workers to perform a mission
because of concerns that heat at the work site exceeded safety standards
even though the contractor lacked the monitoring equipment to make that
determination. According to the contractor's project manager, some
necessary items were forgotten because the contractor team, which was
being created for the first time, did not have an established standard
equipment list for this mission.

Finally, DTRA's efforts to subcontract with Iraqis to help with
collections also took time. In July 2003, because of security concerns,
DOD's Office of Policy stopped Iraqis from the former Iraqi Atomic Energy
Commission from independently collecting sources and rescinded their
access to the secured bunker at Tuwaitha. By October 2003, DOD had decided
to authorize, and encourage the use of, experienced Iraqis to locate
sources, leave them secured in place when possible, and move unsecured
sources to Tuwaitha, but this was an unsuccessful strategy for quickly
increasing collection efforts. According to a DTRA official, DTRA tried
unsuccessfully to get Iraq's Coalition Provisional Authority to fund
Iraqis from the Ministry of Science and Technology to collect sources, but
restrictions on the Coalition Provisional Authority's funds did not allow
this. Eventually, DTRA arranged for its contractor that was collecting
sources to subcontract some tasks to these Iraqis, but it took time to
work out hiring, training, and procedures. For example, DTRA told us that
subcontracting with the Iraqis was challenging because of difficulties
with establishing banking procedures to ensure they got paid. By the time
procedures were developed, training was finished, and the Iraqis began
collection missions, it was February 2004, and DTRA's collection mission
was in its final months.

DTRA Recovered or Left Secure in Place about 2,100 Radiological Sources,
but the Number of Unsecured Sources Remaining in Iraq Is Unknown

Between September 2003 and May 2004, DTRA collected and secured about
1,400 radiological sources from sites throughout Iraq and left in place
another 700 that it deemed secure. To further secure the most dangerous
sources it had collected, in June 2004, DTRA and DOE together removed
about 1,000 of the 1,400 previously collected sources from Iraq. Despite
DTRA's efforts, however, the total number of radiological sources in Iraq
remains unknown.

DTRA Collected and Secured about 1,400 Radiological Sources and Left about
700 Sources in Place after Judging Them to Be Secure

During approximately 140 collection missions conducted between September
2003 and May 2004, DTRA and its contractor collected about 1,400 unsecured
radiological sources and inventoried and left in place about 700 sources
that DTRA deemed secure.3 To collect the 1,400 sources, DTRA identified
their locations, traveled to those locations and found the sources,
determined which sources to remove, transported those selected for removal
to Tuwaitha, and secured them in a bunker there. According to DTRA
officials, the collection missions were conducted safely, despite
increasing insurgent hostilities and exposure risks associated with
handling radioactive material.

About 450 of the 1,400 sources ultimately collected were removed from
radioactive lightning arrestors. Unlike conventional lightning arrestors,
radioactive ones use radiological sources to enhance the attraction of
lightning. One or more sources sat in a metal cylinder at the top of each
of the metal arrestor poles. Iraq had located these arrestors around its
munitions dumps, military bases, and industrial complexes to protect them
from lightning strikes. If these facilities were abandoned, the lightning
arrestors-including the radiological sources-would have been easily
accessible to looters. Coalition forces also found sources used in
commercial activities, such as oil exploration, agriculture, and
scientific

3The count of approximately 700 sources left in place may be an undercount
because devices with radiological sources, such as medical equipment, were
counted as one source in DTRA's inventory, but could possibly include more
than one source inside. Appendix I includes a discussion of the
reliability of the data on sources.

research. The uses of many other unsecured sources DTRA collected were
unknown.

As figure 2 shows, DTRA collected unsecured radiological sources from
locations across Iraq, from the north at the Turkish border to the south
near Al Basrah. However, many of the sources were collected at the
Tuwaitha Nuclear Research Center, located about 25 miles from DTRA's base
camp near Baghdad International Airport.

that looters apparently valued the metal lightning arrestor poles and
copper wire inside them more than the radiological sources. At other
times, DTRA and its contractor did not find the expected sources at all,
which the contractor's mission reports sometimes attributed to faulty
intelligence or looting.

If the radiological sources DTRA found were at an abandoned site or
otherwise not under legitimate control of the Iraqis, DTRA collected them.
For example, DTRA collected two large cesium sources from a factory that
was largely abandoned. Similarly, if a lightning arrestor was damaged and
the radiological source potentially subject to looting, DTRA would collect
the source, according to a DTRA commander.

After collecting and packaging the radiological sources, DTRA secured them
by transporting them to a protected bunker at Tuwaitha. According to DTRA
officials, DTRA had found a bunker at Tuwaitha that had blast-proof doors.
DTRA further improved the bunker's security, investing over $1 million in
improvements such as a chain link fence, gate, and security system. In
addition, DTRA placed an armored unit outside the bunker to guard it.
Figure 3 shows the protected bunker, under a mound of earth at the
Tuwaitha Nuclear Research Center.

Figure 3: Bunker Where DTRA Secured Radiological Sources, Tuwaitha, Iraq

Source: DTRA.

In addition to the about 1,400 radiological sources DTRA collected during
its mission, DTRA left about 700 sources or source devices in place after
it determined that they were properly secured and in the custody of

responsible personnel. According to DOD's guidance, coalition forces and
DTRA could leave sources in place if they

o  had medical, agricultural, industrial, or other peaceful uses;

o  were properly contained and adequately secured; and

o 	were in the custody of trained personnel acting in a professional
capacity, such as hospital staff or agricultural ministry personnel.

DTRA relied on this guidance to determine whether radiological sources it
found could be left in place. In line with the guidance, when DTRA left
sources in place, it recorded information such as location, use, and
responsible institution or individual. Although the guidance did not
elaborate on the standard for adequate security, a DTRA commander told us
that the guidance was sufficient for DTRA to decide which sources were
secure enough to be left in place.

DTRA's initial planning had assumed that the war would be over when its
contractor went to work and, therefore, it would be collecting sources in
a peaceful environment. Instead, with insurgent attacks continuing after
major combat operations were declared over, the contractor's staff was
consistently exposed to danger. In fact, insurgent attacks throughout Iraq
significantly increased during the collection period and generally became
more sophisticated, widespread, and effective (see fig. 4).

Figure 4: Number of DTRA Contractor Missions and Number of Insurgent
Attacks throughout Iraq, June 2003 to May 2004

Number of attacks

                               Number of missions

2,000 1,500

1,000 500 0

          June July Aug. Sept. Oct. Nov. Dec. Jan. Feb. Mar. Apr. May

2003 2004

Year

Monthly attacks

U.S. contractor missions

Iraqi subcontractor missions

Source: GAO analysis of DOD data.

Notes: Attacks were against infrastructure, Iraqi Security Forces,
civilians, or coalition forces.

The initial August 2003 missions were done only at Tuwaitha, as contractor
staff waited for indemnity to be granted.

Although some areas were known as particularly dangerous for travel,
attacks were unpredictable and occurred in many places. For example,
according to a DTRA commander, during the first day of a mission in the
Sunni triangle, the DTRA team came under mortar and sniper attack; during
the second day, a helicopter involved in the mission experienced a
rocket-propelled grenade attack. On another occasion, a DTRA convoy
traveling through Baghdad was delayed by an explosion that left a burning
vehicle in the road. Even within the relative security of the Tuwaitha
Nuclear Research Center, DTRA's contractor reported hearing shots fired
and found an improvised bomb on the road.

To help decrease the danger, DTRA planned armed security for each of its
missions. DTRA officers told us they assessed the potential danger
associated with a particular mission and, if the anticipated security risk
was higher than usual, they increased the size of the security force. For
example, the number of vehicles with mounted weapons might be increased
from two to four. When the risks seemed particularly high, missions were
at times postponed. DTRA's security plan also specified the route of the
convoy, so its location could be tracked with a communication system and a
quick-response military team could be sent if needed. In addition,
military troops sometimes secured the area around the source before the
arrival of DTRA's contractor staff.4

Despite the attacks and the risk of exposure to radiation when collecting
radiological sources, DTRA officials reported that the agency's missions
to collect and secure radiological sources from September 2003 to May 2004
were conducted safely. According to DTRA officials, although the risks
from hostilities were often greater than the risks from handling the
radiological sources, DTRA's team did not sustain casualties during its
collection missions. However, two contractor staff were injured-one
seriously-in a mortar attack at DTRA's home base near Baghdad
International Airport, but not during a collection mission. With regard to
radiation exposure, the contractor's plan called for keeping the effect of
individual exposures on a person as low as reasonably achievable and
cumulative exposures over the mission below specified limits. Although six
team members' hands or feet were contaminated with radioactive powder in
one instance, according to DTRA and contractor officials, DTRA personnel
and contractor staff remained under the cumulative standard throughout the
overall mission.

DOE and DTRA Removed about 1,000 of the Most Dangerous Sources from Iraq

In March 2004, a National Security Council interagency policy committee
that included DOD and DOE made the final decision to remove the most
dangerous radiological sources from Iraq before the Coalition Provisional
Authority handed power over to the interim Iraqi government at the end of
June 2004. In the case of Iraq, DOE selected radiological sources for
removal based on its criteria for determining which radioactive material
posed a significant risk as dirty bomb material. Normally, DOE applies its
criteria to individual sources in determining the risk. In this case, DOE

4Iraqi subcontractors provided their own armed security during their
missions to collect sources or document sources left in place.

consolidated some of these sources that, individually would not have met
the risk criteria, but did meet the criteria once they were consolidated
into waste shipment containers. According to a DOE official, using the
criteria this way was warranted because the consolidation of the sources
in the storage bunker created a potential public health risk or a target
for theft, and Iraq had ongoing hostilities. As a result of applying its
criteria in this way, DOE removed from Iraq about 1,000 of the 1,400
collected sources, accounting for a total of almost 2,000 curies, or over
99 percent of the radioactivity of the collected sources. The remaining
radiological sources were generally small, accounting for a few curies of
radioactivity in total.

After the National Security Council approved the removal mission in March
2004, final preparations for the mission were completed in about 2-1/2
months and the mission was finished in about 1 month. In late May 2004,
DOE sent a team of 20 experts to Iraq to identify the type and radioactive
strength of each collected source and package the sources for shipment to
the United States. Given the escalating hostilities, DTRA hired a
contractor to create a protected living area for the DOE team at the
Tuwaitha site to reduce the exposure to attacks that would have resulted
from traveling daily from a base camp to work at Tuwaitha. Figure 5 shows
this living area and the concrete barriers placed at the perimeter.

Figure 5: Protected Living Area for DOE Experts at the Tuwaitha Nuclear
Research Center

Source: DOE.

DOE had difficulties coordinating with DTRA to get all the information
needed to determine the number and types of shipping containers for the
source recovery mission. DTRA constructed its inventory information on
radiological sources collected at the Tuwaitha bunker to try to meet DOE's
needs. However, DOE experts told us DTRA's information never fully met
DOE's expectations. Specifically, DOE wanted comprehensive information on
the type of isotope and radioactivity of the sources to determine the
number and types of containers needed to safely ship the sources to the
United States, as well as to do other planning tasks, such as an
environmental impact assessment. According to DOE experts, DTRA could
never provide, for example, complete and accurate information on
radioactivity. Deciding that full information would not be forthcoming,
the DOE experts overestimated radioactivity to ensure that DOE would bring
enough containers from the United States to ship the radiological sources
back safely.

Ultimately, DTRA and DOE were able to complete the task of analyzing,
packaging, and loading the containers into trucks in about 25 days. DTRA
and DOE successfully removed about 1,000 radiological sources and about
1.7 metric tons of low-enriched uranium from Iraq on June 23, 2004, 5 days

before the transfer of power from the Coalition Provisional Authority to
the interim Iraqi government. DTRA and DOE transported the sources in a
heavily guarded convoy to a military airfield, and then departed from Iraq
by military air transport. These materials were taken to a DOE site within
the United States and are being evaluated for either reuse or permanent
disposal. The disposal activities, funded by both DTRA and DOE at an
estimated $4.2 million, are expected to continue through late fiscal year
2006.

According to DOE officials, the final disposition of the radiological
materials removed from Iraq may take longer and cost more than estimated
because a legal determination is needed regarding whether the United
States government owns the material or is merely serving as its custodian.
Currently, DOE is storing the sources temporarily at one of its sites, but
it is waiting for an interagency determination before deciding on how to
dispose of the material. According to DOE officials, they raised this
issue of ownership when the removal mission was being planned, but it was
never resolved. As of mid-April 2005, DOE was prepared to start shipping
sources to disposal facilities, but DOE disposal facilities are unwilling
to take possession of the sources until ownership has been determined.
Thus, DOE will hold the sources in temporary storage longer than
anticipated, leading to increased storage costs.

An Unknown Number of Radiological Sources Remain Unsecured In Iraq

Although DTRA's effort to collect unsecured sources and leave secured
sources in place identified about 2,100 radiological sources in Iraq, it
is likely that other sources remain unsecured in Iraq for three reasons.
First, the number and location of all sources in Iraq before the war were
not known. Second, DOD did not search in all places in Iraq where sources
might be found. Third, since the end of DTRA's mission in June 2004, other
unsecured sources have been found, including at Iraq's borders.

The number of sources in Iraq prior to Operation Iraqi Freedom was not
precisely known because the former government of Iraq did not maintain an
inventory of radiological sources around the country. Around the time that
major combat operations were declared over in May 2003, DOD received
information on radiological sources in Iraq, but DOD and State officials
told us that this information was not reliable for the purpose of locating
and securing sources. For instance, DTRA officials told us that the
information on sources and their locations was not precise because the
names of locations were not clear, some sources were reported twice at the
same location, and the information was sometimes outdated. However,

DTRA used this information as a general guide to where sources might be
found. Lacking more reliable information about the number and location of
sources in Iraq at the beginning of the war, DTRA first collected sources
discovered by coalition forces and then searched for other sources.

Because DOD and DTRA did not search all locations where radiological
sources might be found, it is likely that unknown sources remain unsecured
in Iraq. One DTRA official told us that DTRA was not tasked to search all
locations where sources might be found. In addition, DTRA found evidence
that sources had been taken from some locations before DTRA arrived.
According to State officials, neighboring countries detected elevated
radiation readings from cargo on trucks leaving Iraq starting at least by
September 2003, and some of these trucks were turned back at the border.
Although many of these incidents involved radioactively contaminated scrap
metal, some cargo included sources. State officials said they did not know
where the trucks and their cargo went after returning to Iraq, but the
State Department sought to improve coordination with neighboring countries
to manage these border incidents. Because of the lack of a complete search
for sources in Iraq, officials of the interim Iraqi government told us
that it intended to perform a more comprehensive search.

Finally, sources continued to be found in Iraq and at its border after
DTRA completed its collection and removal mission in June 2004. In
addition, according to State officials, radioactive materials, primarily
contaminated scrap metal but also some sources, continued to be detected
on trucks leaving Iraq after that time. Separately, in August and
September 2004, for example, a country bordering Iraq found radioactive
sources on trucks leaving Iraq. Also, a U.S. Army officer responsible for
nuclear, biological, chemical, and radiological issues in Iraq told us
that, in at least one case, an unsecured source or sources from lightning
arrestors had been discovered by U.S. troops since the end of DTRA's
mission in Iraq.

The United States The Department of State supported the Coalition
Provisional Authority in

creating an independent Iraqi agency, the Iraqi Radiological SourceHelped
Create an Iraqi Regulatory Authority (IRSRA), to regulate sources, and
State and DOE are Agency to Regulate assisting the new agency by providing
equipment, technical assistance, and Sources, but Future funding. However,
the evolving Iraqi government-including the

transitional government formed after the January 2005 election and
theAssistance Is Uncertain permanent government to be formed through an
upcoming election-and

the ongoing insurgency are creating uncertainties for both IRSRA and U.S.
assistance.

State Facilitated the Creation of an Iraqi Radiological Source Regulatory
Agency

Before the transition to the interim Iraqi government in June 2004,
State's Bureau of Nonproliferation encouraged the creation of IRSRA. It
saw this effort as an extension of U.S. support for international
standards for safe and secure management of radiological sources, such as
those coordinated and administered by IAEA. Specifically, IRSRA will
further several U.S. foreign policy goals. First, an Iraqi agency that
controls radiological materials will promote the health and safety of
Iraqis, as well as provide the capability for Iraq to meet international
commitments for the safe and secure management of radiological sources.
Second, an effective Iraqi agency for regulating sources will promote U.S.
national security goals by decreasing the likelihood of terrorists
trafficking in or deliberately releasing radioactive material. Third, the
new agency will employ former Iraqi scientists who might otherwise seek
employment with terrorists or countries seeking WMD expertise.

State officials enlisted Iraqi officials within the Coalition Provisional
Authority to support the formation of IRSRA. In particular, State
negotiated with the Minister of the Ministry of Science and Technology
(MOST), who played a leading part in supporting the creation of IRSRA. The
Minister agreed to allow IRSRA to regulate Iraq's radiological sources,
while MOST will retain ownership and control of secured nuclear and
radiological materials at research facilities. The Minister also agreed to
continue DTRA's efforts to find and collect unsecured radioactive sources,
but under contract with IRSRA. The Minister further agreed that IRSRA
would be legally and financially independent-a key element in State's plan
for IRSRA. According to State officials, IRSRA was designed as an
independent agency to avoid conflicts of interest. While Iraqi ministries,
such as the Ministry of Health, the Ministry of Oil, and MOST, own or
track many of the radiological sources in Iraq, their activities will be
subject to the regulation of IRSRA, which will inspect, inventory, and
regulate all sources in Iraq.

In addition, through discussions with Iraqi and Coalition Provisional
Authority officials, State helped draft the 2004 budget plan and the
organizational structure of IRSRA. The plan included providing $7.5
million to the new agency within the Iraqi Government Budget developed by
the Coalition Provisional Authority for fiscal year 2004. These funds are
to be spent on salaries, the search for sources, assistance from U.S.
experts, office space, and facility security. State's organizational plans
for IRSRA

identified the departments and staffing needed to accomplish agency tasks,
such as regulating radiological sources in use, managing unwanted
radiological sources, and creating regulations in cooperation with IAEA
and other experts. In addition, to further State's efforts, DTRA trained
Iraqis to collect, store, and secure radiological sources during its own
collection operations and subsequently provided Iraqis with an upgraded
secure storage facility and its inventories of sources removed from the
country, left at the facility, or identified around Iraq.

In June 2004, the Coalition Provisional Authority issued an order
establishing IRSRA.5 According to the order, IRSRA will promulgate and
enforce regulations to allow for beneficial uses of radioactive sources,
provide for adequate protection of humans against the harmful effects of
radiation, and ensure the safety and security of radiological sources. For
example, it will require hospitals, universities, oil production
facilities, and others to obtain licenses to possess radiological sources,
which will enable the agency to maintain records on radiological sources
in the country. Licensees will be obliged to follow procedures and
regulations that define how they will secure, inventory, and work with
their licensed radiological sources. In addition, IRSRA is responsible for
collecting unsecured sources when they are found, creating radiation
health and safety criteria, and researching the possibility of
constructing a low-level radioactive waste disposal facility in Iraq. The
Coalition Provisional Authority disbanded shortly after it created IRSRA,
but its order will continue to have legal authority in Iraq until it is
amended or changed by the Iraqi government, according to State officials.

By the summer of 2005, State officials told us, they perceived signs that
IRSRA was beginning to function and was becoming more established as part
of the Iraqi government. For example, IRSRA had started drafting
regulations and was requiring ministries to notify it about their
radiological sources. Moreover, it had an appointed chairman, developed a
budget, and obtained its own building and office space, as well as about
50 staff.

5Coalition Provisional Authority Order Number 72, "Iraqi Radioactive
Source Regulatory Authority," CPA/ORD/10 June 2004/72 (June 10, 2004).

State and DOE Are Providing Assistance to the New Regulatory Agency

In addition, State and DOE are assisting IRSRA by providing equipment,
facilitating technical assistance, and providing funding. First, to help
the Iraqis collect unsecured sources under the direction of IRSRA, State
has initiated an effort to transfer to Iraqi agencies equipment that had
been purchased by DTRA to collect sources. This equipment includes
radiological handling, measurement, and protective equipment, such as
radiation meters, respirators, and protective clothing. According to State
officials, preparations for the transfer of this equipment began in
mid-2004; as of early 2005, State and DOD were discussing how this
equipment would be transferred to the Iraqis. In the meantime, this
equipment has been made available to MOST for collecting radiological
materials.

State is also facilitating technical assistance. With funding and
logistical support from DOE, State coordinated several meetings in Amman,
Jordan, in December 2004 to provide IRSRA personnel training by IAEA staff
and to help them draft an action plan for regulating radiological sources.
IRSRA's action plan is based on the IAEA Model Project program, through
which IAEA is helping about 100 developing countries establish effective
regulatory controls for radioactive sources. Under the Model Project
program, developing countries adopt action plans to help them establish or
strengthen radiation protection infrastructures in order to meet
international standards and to follow the guidance in the IAEA Code of
Conduct on the Safety and Security of Radioactive Sources.

Under the action plan, which was finalized in March 2005 meetings in
Washington, D.C., IRSRA will establish a regulatory framework; work to
control radiation exposure in occupational, medical, and public settings;
and set up emergency preparedness and response capabilities. IAEA plans to
provide expert assistance to help IRSRA meet these goals. In addition, to
help IRSRA find unsecured sources, IAEA will offer radiation detection
equipment and training in border control. To complement the action plan,
IAEA is sharing with IRSRA a computer program designed to track
information about radiological sources' locations, radioactive strengths,
licensing, and responsible parties. IRSRA intends to use this program to
manage information it gathers on Iraqi radiological sources.

In addition, in coordination with IRSRA's action plan, DOE is offering
IRSRA technical assistance to help ensure the security of radiological
sources. For example, DOE plans to provide experts to review draft Iraqi
laws and regulations for their relevance to security. DOE also plans to
assist IRSRA with facility upgrades to address security vulnerabilities of
sources used for medical, industrial, or other peaceful purposes.
Moreover,

in conjunction with IAEA, DOE may also offer field equipment and training
workshops for inspecting the security of sources.

Finally, to financially support IRSRA's action plan, State intends to use
$1.25 million from its Nonproliferation and Disarmament Fund, which
provides funding for projects to prevent the spread of WMD. State plans to
provide part of these funds to IAEA for training and other assistance to
IRSRA, including an IAEA review of Iraq's draft laws and regulations.
State plans to also use the funds to purchase a specially equipped vehicle
that can be driven through neighborhoods to detect unsecured radiological
sources. In addition, State plans to hire a contractor to coordinate
security matters with coalition forces to minimize the risk of attacks,
while the Iraqis are working to control sources.

Iraq's Political Transition and Continuing Hostilities Are Creating
Uncertainties for IRSRA and U.S. Assistance

According to State officials, because of uncertainties associated with the
continuing formation of the Iraqi government, State will have to monitor
Iraqi efforts to ensure the continued growth and success of an
independent, competent, and sustainable regulatory authority for the
control of radioactive sources and materials. According to these
officials, the ongoing formation of the Iraqi government could affect the
future of IRSRA in several ways. First, potential changes to the
government's organization or personnel could affect IRSRA's funding and
enforcement powers. For example, the transitional government formed from
the January 2005 election chose new government ministers-including
replacing the Minister of Science and Technology, who had aided the
formation of IRSRA. In addition, according to State and Iraqi officials,
in early 2005, the Iraqi government froze all new expenditures until the
transitional government takes action on the budget. Therefore, the funds
for the IRSRA contract with the ministry to search and recover sources
were not available. However, State officials told us the collection
missions are important for public safety and would go forward in
anticipation of later payment. Finally, the Iraqi government will have to
enact the laws and regulations that IRSRA will be drafting under its
action plan.

In addition, State officials told us that the evolving relationship of the
northern Kurdish-controlled territories with the rest of Iraq could affect
IRSRA's operation. Before Operation Iraqi Freedom, the Kurds enjoyed some
independence from the former Iraqi regime, and State officials told us
that this partial independence has continued. IRSRA and Kurdish officials
will be discussing whether and how IRSRA will operate in
Kurdish-controlled territory. According to the Chairman of IRSRA, Kurdish

officials are likely to accept a proposal to create a branch office of
IRSRA in Kurdish territory. This proposed office would be staffed by
Kurds, but IRSRA would provide equipment, training, and protocols.

Finally, the continuing insurgency is hindering IRSRA's ability to find
and collect unsecured radiological sources as well as the ability of the
United States to provide assistance. Iraqi and State officials are
concerned that insurgents will target Iraqis who are seen associating with
coalition forces on their official duties. For example, a MOST official
told us that Iraqi workers entering a U.S. military base to collect
sources would likely be ambushed by insurgents upon leaving the military
base. The hostile environment also impairs the ability of the United
States to provide certain kinds of assistance. For example, DOE has
decided not to send its experts into Iraq because of the ongoing
hostilities, according to a DOE official. However, State and DOE are
devising ways to assist without going to Iraq, such as organizing training
for Iraqis at sites outside of the country.

DOD Has Not Assessed Although DOD has assessed its overall WMD mission in
Iraq, the agency

has not assessed its narrower mission to collect and secure
radiologicalIts Source Recovery sources. In contrast, DOE has considered
actions to address specific Effort, but DOE Is lessons learned from its
experience in removing radiological sources from

Considering Lessons Iraq.

Learned

DOD Has Assessed Its Broader WMD Mission but Has Not Focused on the
Radiological Sources Effort

DOD asked its National Defense University (NDU) to study DOD's overall
mission to find and eliminate WMD in Iraq, determine what lessons could be
learned from it, and recommend improvements. The resulting report stated
that DOD had not sufficiently planned and prepared for the WMD mission;
had shortfalls in the needed transportation, military security, and
logistics resources; and had operational difficulties arising from the
extensive looting, public disorder, and hostile security environment. The
report recommended that DOD develop the capability to quickly eliminate
WMD in hostile environments and establish a permanent organization for
eliminating WMD. (See app. II for more information on the report.) DOD is
responding to the report, in part, by seeking stronger planning and
capacity for eliminating WMD, which a DOD Joint Staff officer told us
would include the elimination of radiological materials. Specifically,
DOD's Strategic Command, which was assigned responsibility for this
planning in January

2005 by the Secretary of Defense, will first determine the needed
capacities.

The NDU report did not, however, offer any observations or recommendations
regarding the narrower mission to collect and secure radiological sources
in Iraq, in part because this was not the main focus of the original WMD
mission in Iraq. Nevertheless, the author of the NDU report and a DOD
Joint Staff officer told us that DOD's efforts to solve overarching issues
with its preparation for eliminating WMD will also address problems
experienced with the mission to collect and dispose of radiological
sources.

DOE Is Considering Lessons Learned from Removal of Iraqi Radiological
Sources

DOE asked its contractor at one of its national laboratories to analyze
the removal mission to identify lessons learned and recommend
improvements. The resulting analysis highlights the lessons that timing of
funds and availability of equipment hindered rapid preparation for the
mission.6 First, the contractor noted that the short amount of time
between when the project was funded and when the team left for Iraq meant
that almost every preparation task had to be conducted in emergency mode.
DTRA funding became available in March 2004 after the National Security
Council approved the mission, leaving less than 2-1/2 months for the team
of DOE experts to complete all preparations in the United States. Needed
preparations included establishing a liaison with DTRA in Iraq;
determining the list of sources to be removed based on DTRA's inventory;
developing safety and handling procedures for those specific sources;
completing safety assessments for those procedures; determining the need
for, and obtaining, a National Security Exemption to bring some of the
radioactive sources to the United States; recruiting the remainder of the
team members; cross training team members to be able to complete another
member's work if necessary; getting the DOD training and authority
necessary for the team to enter Iraq; obtaining contractor indemnification
for the mission; preparing a U.S. staging facility for equipment; and
procuring, testing, and packaging such equipment as protective clothing,
tents, and communication equipment.

In addition, according to the contractor, preparation for the mission was
almost critically delayed by difficulties in acquiring containers for

6The analysis does not address DTRA's contracting of DOE experts for the
collection mission, which was conducted before the joint DOE and DTRA
removal mission.

transporting the radiological sources. DOE and its laboratories did not
have a sufficient number and variety to meet the projected needs of the
removal mission-a shortfall that proved challenging to overcome in time to
successfully conduct the mission. Specifically, certain special containers
could not be procured in time from U.S. domestic suppliers as a result of
shortages. Consequently, DOE arranged to lease four of these special
containers from a foreign company by agreeing to provide the company
blanket indemnity with up to approximately $1 billion in liability
coverage in case of an accident involving the containers. The containers
arrived a few days before the team and its equipment were to leave for
Iraq. According to the contractor, if DOE's negotiations to get the
special containers had failed, the removal mission would have been
delayed, and it is likely that many radiological sources with high
radiation levels would not have been able to be removed.

To support timely action in future removal operations, the contractor
recommended that DOE seek ways to ensure the existence of advanced funding
and maintain a small fleet of versatile containers. DOE officials told us
they saw merit in having a way to quickly fund future missions, although
their agency's funding-used solely for the disposal rather than the
removal of the sources-was available early enough in the case of Iraq.
With regard to maintaining a reserve of containers and other equipment,
the officials solicited proposals and cost estimates from their national
laboratories and have determined they cannot pursue this option given
current budget constraints.

Conclusions	Because DOD has not comprehensively reviewed its experiences
in collecting and securing radiological sources in Iraq, its current
efforts to improve its preparations to secure or destroy WMD in future
missions will not benefit from important lessons learned from its
radiological source mission. Reviewing such experiences and identifying
lessons learned would help prepare for any future missions involving
similar circumstances.

In addition, DOD's lack of readiness to quickly collect and secure sources
after the war began indicates that additional planning and preparation
could have been completed in advance of the mission. Specifically, DOD had
not

o 	planned to collect sources in a hostile environment and thus had to act
during the operation to integrate the objective of collecting and securing
sources with military combat objectives;

o 	established criteria to determine which radiological sources needed to
be collected, which were being properly used and thus could be left in
place, and which posed minimal threat and thus did not need to be
collected;

o 	specified health and safety standards for handling, securing,
transporting, and disposing of sources;

o 	specified the organization responsible for collecting and securing
sources in Iraq until shortly before the invasion of Iraq, nor established
agreements within DOD regarding issues such as using armed private
security forces to protect contractors involved in collecting and securing
sources;

o 	established agreements or points of contact with DOE to determine the
support that DOE could provide, including the type of expertise,
equipment, and disposal facilities;

o 	identified and addressed the legal and contractual issues associated
with using private contractors to assist in collecting and securing
sources, including using such contractors in hostile environments; and

o 	established guidelines to utilize the skills and address security
concerns associated with the use of Iraqi radiological experts.

Recommendations for Executive Action

To ensure that the types of problems experienced with the planning and
preparing for securing Iraqi radiological sources do not recur, we
recommend that the Secretary of Defense comprehensively review DOD's
experience for lessons learned for potential future missions.

In addition, to ensure that planning and preparing for potential future
missions is carried out in advance, we recommend that the Secretary of
Defense provide specific guidance for collecting and securing radiological
sources, including

o 	integrating the objective of collecting and securing radiological
sources with military combat objectives, including specifying how security

protection, if needed, would be provided to the organization with
responsibility for managing radiological sources and whether combat troops
would be required to secure sources and provide protection for operations
to collect and secure radiological sources;

o 	determining criteria to define which radiological sources (1) are of
greatest risk and should be collected, (2) are being properly used and
secured and thus can be left in place, and (3) pose minimal threat and
thus do not need to be collected;

o 	specifying the health and safety standards, after considering how U.S.
standards for handling, securing, transporting, and disposing of
radiological sources were modified for use in Iraq;

o 	officially designating the organization responsible within DOD for
collecting, securing, and disposing of sources and establishing agreements
between that organization and other DOD organizations that may be involved
with these efforts;

o 	establishing agreements and points of contact with DOE and other
federal agencies, as needed, to specify the coordination, technical
expertise, equipment, and facilities that may be needed to collect and
secure sources in, or remove them from, a foreign country;

o 	identifying under which circumstances and for what purposes DOD will
contract with private firms to conduct activities to collect and secure
radiological sources, and address legal and contracting issues to ensure
the timely use of contractors; and

o 	establishing guidelines concerning the role of radiological experts
from the country where sources need to be collected and secured.

Agency Comments and Our Evaluation

We provided the Departments of Defense, State, and Energy with draft
copies of this report for their review and comment.

DOD agreed with four of our recommendations, partially concurred with two,
and did not concur with two. DOD stated that it had previously addressed a
number of issues identified in the recommendations and is currently
addressing the others. DOD also stated that the draft report did not
adequately address those efforts of the Nuclear Disablement Team (NDT)
during the earlier operations in Operation Iraqi Freedom involving

radiological source recovery operations. DOD stated that the focus of the
draft report appeared to be largely on the elimination phase of the
operation and that it accepted our recommendations in that area. Our
report assessed all phases of DOD's planning and preparing for this
mission, including the experiences of the NDT and its decision to forgo
collecting sources because it lacked the proper equipment. We believe our
report was appropriately focused on the elimination phase because that was
when most sources were collected from around Iraq.

DOD partially concurred with our recommendation to develop lessons
learned, indicating that lessons learned have been developed from the
NDT's experiences for the phase of the operation before DTRA began to
collect sources. That effort is in line with our recommendation, but
unless DOD completes a more comprehensive review, we are concerned that it
will miss the experience of all relevant DOD organizations and the full
range of lessons learned.

DOD also partially concurred with our recommendation about integrating the
objective for securing radiological sources with military combat
objectives, saying that this recommendation applies only to the later
phase involving DTRA's work. However, we disagree that our recommendation
applies only to DTRA's work. As our report points out, there were problems
with integrating the mission of collecting and securing sources with
military combat objectives during the NDT phase of operations as well.
Specifically, our report notes that during the NDT phase of operations,
military commanders were left to make ad hoc decisions about recovering
and securing sources, including using combat troops to guard sources.
DOD's response to this recommendation also noted problems DOD encountered
in obtaining support from DOE. We believe our report adequately discusses
problems DOD encountered in obtaining DOE assistance in collecting
radiological sources-these problems stemmed from the lack of advanced
coordination that our report recommends DOD resolve prior to any future
missions. DOD also commented that our recommendation demonstrated a lack
of understanding by suggesting that combat troops should be involved in
handling radioactive materials. We revised our recommendation to more
clearly indicate that DOD should decide whether combat troops would again
be required to secure sources and protect missions to collect sources, as
they did in Iraq.

DOD did not concur with our recommendation concerning health and safety
criteria and suggested that our recommendation was too broad and ill
defined. DOD's rationale for this response is not clear. First, DOD said

that guidance is and always has been available. Then, DOD said that since
Operation Iraqi Freedom was the first time in recent history that a
capability was developed and deployed to counter a WMD threat, no unit
level standard operating procedures existed. DOD then said that the NDT
did develop procedures to "address all these issues" and that the NDT
continues to work to develop changes to existing regulations to "address
all these particulars." We have clarified our recommendation to indicate
that DOD, in specifying health and safety standards, should consider how
U.S. health and safety standards were modified in Iraq during the mission
to collect and secure sources. We continue to believe that DOD should
fully implement our recommendation.

Finally, DOD did not concur with our recommendation to establish the
organization responsible within DOD for collecting, securing, and
disposing of sources. DOD said that it had already identified this
organization as the NDT and that the Commander of Strategic Command has
overall responsibility for issues related to WMD, a subset of which is
collecting, securing, and disposing of sources. However, based on a
conversation we had in August 2005 with a DOD Joint Staff officer,
Strategic Command has not yet issued its plan for combating WMD, in which
the specific organization responsible for collecting, securing, and
disposing of sources will be officially designated. DOD's complete
comments are reprinted in appendix III.

State suggested clarifications of its current outlook for U.S. assistance
to Iraq for radioactive source regulation and the reason for the delay in
State's approval of export licensing, which we have incorporated into this
report. Separately, State provided technical comments, which we
incorporated as appropriate. State's written comments are reproduced in
appendix IV.

DOE had no written comments on the report but did state that it will work
with DOD to determine criteria to define which radiological sources are of
greatest risk.

We are sending copies of this report to the Secretary of Defense, the
Secretary of Energy, the Secretary of State, and interested congressional
committees. We will also make copies available to others upon request. In
addition, this report will be available at no charge on the GAO Web site
at http://www.gao.gov.

If you or your staff have any questions about this report, please contact
me at (202) 512-3841 or [email protected]. 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 V.

Gene Aloise Director, Natural Resources and Environment

Appendix I

Scope and Methodology

This report (1) assesses Department of Defense (DOD) readiness to collect
and secure radiological sources in Iraq from the start of the 2003 war,
(2) presents information on the number of radiological sources the Defense
Threat Reduction Agency (DTRA) secured by the time of the June 2004
transition to the interim Iraqi government, (3) describes the assistance
the United States has provided, and plans to provide in the future, to the
Iraqi government to help regulate radiological sources in Iraq, and (4)
examines DOD and Department of Energy (DOE) actions to assess their
experiences in Iraq and apply any lessons learned to possible future
radiological source collection missions.

For our first objective, to assess DOD's readiness to collect and secure
radiological sources, we reviewed planning efforts before the war began in
March 2003; concerns and efforts regarding radiological sources before
DTRA began its collection mission in late 2003; relevant policy guidance;
and DTRA's preparations to collect unsecured sources in Iraq. To
understand DTRA's prewar plans, we interviewed a division chief of DTRA's
Combat Support Directorate, who prepared these plans, and other DOD
officials involved in planning before the war. For concerns and efforts
before DTRA began to collect sources, we interviewed the Nuclear
Disablement Team commander and other team members and reviewed an
unclassified report on their activities in Iraq. We also interviewed the
senior chemical officer for the commander of coalition land forces who
secured radiological sources in Iraq. For policy guidance, we examined two
DOD policy memorandums on radiological sources in Iraq and interviewed
DTRA and DOD officials involved with the development of the guidance. For
specific preparations to collect sources, we interviewed DTRA officials
who prepared for the mission, including the two commanders who
sequentially prepared for the mission in Iraq and the DTRA director
responsible for the mission. We also reviewed the contract between DTRA
and its contractor, and the contract agreement between DTRA and DOE. We
interviewed DTRA officials who developed and managed the contract, the DOE
official who facilitated the development and execution of the contracts,
and contractor's project managers and staff.

For our second objective, to present information on the number of
radiological sources secured, we assessed the data reliability of five
inventories of radiological sources in Iraq and summary data about the
sources' radioactivity. We asked those responsible for creating or
maintaining the inventories a series of questions focused on data
reliability, covering issues such as internal control procedures and the
accuracy and completeness of the data. Our assessment follows:

Appendix I Scope and Methodology

1.	We assessed the reliability of an inventory of the location, number,
and type of sources in Iraq at the beginning of the war that DTRA received
during its mission, and based on our work, we determined that these data
were not sufficiently reliable for the purposes of this report to specify
the number of sources at the beginning of the war. Because the source of
this information is sensitive, we did not report its origin. DTRA
officials told us they found this data to be unreliable, but it did match
well with sources found at some sites. For our assessment of the data, we
reviewed the inventory and interviewed key DTRA and contractor staff who
worked with this information. We found major discrepancies, including
duplications resulting in multiple counts of the same sources and evidence
of incomplete data. Therefore, we did not use this data in our report.

2.	We assessed the reliability of a May 2004 inventory of sources
collected in Iraq that DTRA had created before the removal mission, and we
determined that, for the purposes of this report, the inventory was not
sufficiently reliable to ascertain the number and types of sources, but
the inventory was reliable enough to identify the general locations of
places where sources were found. To assess this data, we obtained
responses to questions regarding data reliability by interviewing key DTRA
and contractor staff who worked with this information. We also
corroborated the data whenever possible with DOE experts and DOE's
inventories of collected sources taken to the United States and those left
in Iraq. DTRA's contractor staff told us they were unable to open some
containers and counted each of them as one source. However, when DOE
experts opened these containers, they found that some containers held
multiple sources, increasing the count of sources from about 700 sources
to about 1,400 sources. Also in the DTRA inventory, the type of
radiological material was misidentified for some sources, according to DOE
experts and documents. Therefore, we reported the number of sources based
on DOE's work.

3.	We assessed the reliability of DOE's inventory of the approximately
1,000 sources collected in Iraq and taken to the United States, and
determined that these data were sufficiently reliable for the purposes of
this report. To assess this data, we obtained responses to questions
regarding data reliability by interviewing key DOE experts who worked with
this information. We were told that the number of sources taken to the
United States may be a close approximation, due to some instances where
DOE experts relied on counts by DTRA, and therefore we reported them
approximately.

Appendix I Scope and Methodology

4.	We assessed the reliability of a DOE inventory of the approximately 400
sources collected in Iraq and remaining in Iraqi custody, and determined
that these data were sufficiently reliable for the purposes of this
report. To assess this data, we obtained responses to questions regarding
data reliability by interviewing key DOE experts who worked with this
information. They told us that the number is a close approximation, and
therefore we reported it approximately.

5.	We assessed the reliability of a DTRA inventory of the approximately
700 sources determined to be secured and in use in Iraq, and determined
that these data were sufficiently reliable for the purposes of this
report. To assess this data, we obtained responses to questions regarding
data reliability by interviewing key DTRA and contractor staff who worked
with this information. DTRA's contractor staff told us they did not open
the devices that contained sources and, therefore, depended on the
labeling and documentation of the devices, if available, to record
information about their number, type, and radioactive strength. The
inventory assumed that there was one source per device, but contractor
staff told us that some of these devices may have had multiple sources,
and therefore we reported them approximately.

To report the radioactivity of sources collected in Iraq and taken to the
United States or remaining in Iraq, we depended on information provided to
us in a DOE summary of the sources removed from Iraq, and determined that
these data were sufficiently reliable for the purposes of this report. We
discussed this data with DOE experts who worked with this information.
They told us that the radioactivity of the sources taken from Iraq was
accurate to within 10 percent to 20 percent of the total reported, and we
therefore reported the total approximately. They also told us that the
radioactivity of the collected sources remaining in Iraq was somewhat more
accurate because these less-radioactive sources could be handled and
measured individually, but that the total was an approximation. Therefore,
we reported the total approximately.

To present information on the missions performed to collect and remove
radiological sources, we examined the available contractor reports on the
approximately 140 missions to find and collect sources in Iraq, as well as
contractor reports on the mission to remove sources from Iraq. We
interviewed DTRA officers and staff and DOE experts who accompanied these
missions. We also interviewed contractor staff who performed this mission
and the contractor's project manager for the mission in Iraq.

Appendix I Scope and Methodology

For our third objective, to describe U.S. efforts to help the new Iraqi
government regulate sources, we examined Department of State planning
documents and a Coalition Provisional Authority order to establish an
Iraqi agency to regulate radiological sources. We discussed assistance, as
well as uncertainties and challenges for assisting Iraq, with officials
from State and DOE. In addition, we discussed DTRA's actions to support
State's effort to assist Iraq with DTRA officials. We also discussed
efforts to secure radiological sources with the Chairman of the Iraqi
Radiological Source Regulatory Authority during his visit to Washington,
D.C., in March 2005; at the same meeting, we discussed efforts to search
for unsecured sources with an Iraqi program director from the Ministry of
Science and Technology. We interviewed State and DOE officials about their
current and intended contributions to the action plan drafted in December
2004 and further discussed in March 2005 meetings.

For our fourth objective, to describe what DOD and DOE have done to learn
from their experience in Iraq, and how such lessons might be applied in
the future, we interviewed DOD and DOE officials about their efforts to
document lessons learned. We also reviewed a February 2004 National
Defense University study of lessons learned from the mission to eliminate
weapons of mass destruction (WMD), and discussed the study with its
author. We discussed DOD's work to assess its capability to interdict and
eliminate WMD materials, including radiological sources, and reviewed the
DOD memorandum initiating this effort, and held discussions with DOD
planning officials. We also examined DOE's preliminary analysis of lessons
learned with DOE officials and interviewed the DOE expert who prepared it.

Because of the continuing hostilities, we did not travel to Iraq. We
performed our work from May 2004 through August 2005 in accordance with
generally accepted government auditing standards.

Appendix II

                     The National Defense University Study

The Center for the Study of Weapons of Mass Destruction (WMD Center) at
the National Defense University (NDU) has developed lessons and
recommendations for WMD elimination operations, as the result of the
Department of Defense's (DOD) request for this study in late 2002. The WMD
Center conducted meetings with DOD and interagency personnel to discuss
elimination operations, and also examined prewar planning and its
execution in Iraq. In February 2004, the WMD Center hosted a conference
with those who had been engaged in the elimination mission in Iraq to
identify lessons learned and ways to institutionalize WMD elimination
capacity for the future. Major findings and key recommendations from the
study were subsequently published in an NDU report.1

The NDU report suggests three wrong lessons from the Iraq experience that
should be avoided to arrive at the correct lessons. A first wrong lesson
is that Iraq is a rare situation. According to the report, since most of
the United States' potential adversaries have actual or suspected WMD
capabilities and terrorists appear committed to acquiring WMD from weak,
poor, or failed states, the U.S. military will likely confront WMD
elimination missions as often as it engages in war. A second wrong lesson
is that the failure of intelligence on WMD explains all of the failures of
the WMD elimination mission. While faulty intelligence contributed to
problems, the Iraq experience revealed substantial problems with DOD's
ability to eliminate WMD, including problems in planning, training and
exercises, capabilities, and resources. A third wrong lesson is that
elimination should not be a DOD mission, but rather should mostly be done
by civilian or international organizations with the proper expertise after
the military minimally secures WMD sites. Instead, the Iraq experience
suggests that the U.S. military must quickly attend to finding, securing,
and disposing of WMD to prevent the loss of information about WMD programs
and the potential dispersal of WMD occurring in the chaos following an
invasion.

Even though WMD was not found, the report suggests that the Iraq
experience reveals that major improvements must be made if the United
States is to succeed in a possible future WMD elimination mission. For
example, according to the study, DOD had not sufficiently planned and
prepared for the mission to locate, secure, and dispose of WMD, in part,
because DOD only began to rapidly plan for operations and develop

1Rebecca K.C. Hersman, "Eliminating Adversary Weapons of Mass Destruction:
What's at Stake?" (occasional paper, National Defense University Press,
Washington, D.C., December 2004).

Appendix II
The National Defense University Study

capacities for the elimination mission in late 2002. Before the end of
major combat operations, the study observed that the teams searching for
WMD experienced important operational problems. One key problem was that
operations had to be adjusted because existing intelligence was directing
teams to suspected sites that proved to have little evidence of WMD
activity. Operations thus shifted from the expected focus on WMD to a more
geographically dispersed investigation of potential WMD sites. Operations
also shifted toward gathering information about WMD programs, but most
teams lacked sufficient training and expertise for retrieving important
information contained in documents and computers as well as for
interviewing Iraqis who might be knowledgeable about WMD programs.
Further, the organization responsible for searching for WMD was dependent
on other military commands for capabilities such as transportation,
logistics, communications, linguists, and security. When these other
military commands experienced competing priorities for these capabilities,
shortfalls for these capabilities occurred and the search for WMD was
delayed. Additionally, the extensive looting, public disorder, and
uncertain security environment made the search for WMD complex, resource
intensive, and dangerous.

Based on the Iraq experience, the NDU report recommended that DOD develop
and maintain the capability to quickly eliminate WMD in hostile
environments. More specifically, the report included eight key
recommendations: (1) DOD should institutionalize the WMD elimination
mission, embedding it into the planning and budget process along with
other tasks undertaken in combat operations. (2) To have a clear
organization responsibility, DOD should create a standing military
organization that is ready to perform the WMD elimination mission,
including in a combat situation. Although this organization should be
military, it should develop strong links with interagency and
international partners, civilian experts, and the private sector. (3) DOD
should be prepared to conduct this mission in an inhospitable environment
and as quickly as possibly-concurrently with major combat operations, if
necessary. (4) Elimination planning must assume imperfect intelligence on
WMD, operations should be prepared to respond to emerging intelligence,
and intelligence sharing must be improved. (5) To test plans as well as
identify and address problems with procedures, the organization with WMD
elimination responsibility should conduct training and exercises. (6)
Rather than focusing on WMD sites, as initially occurred in Iraq, future
elimination missions should target WMD programs, using a balanced
examination of WMD sites, people, and documentation. (7) DOD should seek
technical innovations to improve the efficiency, speed, and overall

Appendix II
The National Defense University Study

effectiveness of elimination operations. The objective is to reduce the
needed manpower because it is in extreme demand before, during, and after
a war, as shown in Iraq, and to address technical issues in Iraq
operations, such as false readings on chemical detectors and electronic
communication limitations. (8) Finally, senior-level government advocates
are necessary to ensure adequate and sustained funding and prioritization
to develop a significant WMD elimination capacity.

                                  Appendix III

                    Comments from the Department of Defense

Appendix III
Comments from the Department of Defense

Now on p. 32.

                               Now on pp. 32-33.

Appendix III
Comments from the Department of Defense

                                 Now on p. 33.

                                 Now on p. 33.

                                 Now on p. 33.

                                 Now on p. 33.

                                 Now on p. 33.

Appendix III
Comments from the Department of Defense

                                 Now on p. 33.

                                  Appendix IV

                     Comments from the Department of State

Appendix IV
Comments from the Department of State

Now on Highlights and on pp. 5 and 28.

Now on p. 28.

Now on para. 3, p. 12.

Appendix IV
Comments from the Department of State

Appendix V

                     GAO Contact and Staff Acknowledgments

                    GAO Contact Gene Aloise, (202) 512-3841

Staff 	In addition to the contact named above, Lee Carroll, Nancy
Crothers, Davi M. D'Agostino, Dan Feehan, Peter Grana, Terry Hanford, Dave
Maurer,

Acknowledgments	Judy Pagano, and Keith Rhodes (GAO's Chief Technologist)
made key contributions to this report.

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

Obtaining Copies of The fastest and easiest way to obtain copies of GAO
documents at no cost

is through GAO's Web site (www.gao.gov). Each weekday, GAO postsGAO
Reports and newly released reports, testimony, and correspondence on its
Web site. To Testimony have GAO e-mail you a list of newly posted products
every afternoon, go to

www.gao.gov and select "Subscribe to Updates."

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, Contact:
Waste, and Abuse in Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: [email protected] Programs Automated answering system: (800)
424-5454 or (202) 512-7470

Congressional	Gloria Jarmon, Managing Director, [email protected] (202)
512-4400 U.S. Government Accountability Office, 441 G Street NW, Room 7125

Relations Washington, D.C. 20548

Public Affairs	Paul Anderson, Managing Director, [email protected] (202)
512-4800 U.S. Government Accountability Office, 441 G Street NW, Room 7149
Washington, D.C. 20548
*** End of document. ***