Combating Nuclear Smuggling: DHS Has Made Progress Deploying
Radiation Detection Equipment at U.S. Ports-of-Entry, but
Concerns Remain (22-MAR-06, GAO-06-389).
Preventing radioactive material from being smuggled into the
United States is a key national security objective. To help
address this threat, in October 2002, DHS began deploying
radiation detection equipment at U.S. ports-of-entry. This report
reviews recent progress DHS has made (1) deploying radiation
detection equipment, (2) using radiation detection equipment, (3)
improving the capabilities and testing of this equipment, and (4)
increasing cooperation between DHS and other federal agencies in
conducting radiation detection programs.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-06-389
ACCNO: A49857
TITLE: Combating Nuclear Smuggling: DHS Has Made Progress
Deploying Radiation Detection Equipment at U.S. Ports-of-Entry,
but Concerns Remain
DATE: 03/22/2006
SUBJECT: Cargo security
Cost effectiveness analysis
Cost overruns
Counterterrorism
Crime prevention
Dirty bombs
Harbors
Hazardous substances
Homeland security
Inspection
Interagency relations
Nuclear weapons
Operational testing
Program evaluation
Radiation monitoring
Schedule slippages
Smuggling
Strategic planning
Cost estimates
Program goals or objectives
Radiation detection
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GAO-06-389
* Report to Congressional Requesters
* March 2006
* COMBATING NUCLEAR SMUGGLING
* DHS Has Made Progress Deploying Radiation Detection Equipment at
U.S. Ports-of-Entry, but Concerns Remain
* Contents
* Results in Brief
* Background
* DHS Has Made Progress in Deploying Radiation Detection Equipment,
but the Agency's Program Goals Are Unrealistic and the Cost
Estimate Is Uncertain
* The Program to Install Portal Monitors Has Fallen Behind
Schedule
* Funding Issues
* Delays in Gaining Agreements Have Slowed Seaport
Deployments
* Screening Rail Cars in Seaports Presents Unique
Problems
* Other Factors Have Delayed Portal Monitor Deployments
* DHS's Portal Monitor Deployment Program Cost Estimate Is
Uncertain and Overly Optimistic
* CBP Does Not Know If PNNL's Cost and Schedule Data Are
Reliable
* CBP Officers Have Made Progress in Using Radiation Detection
Equipment Correctly and Adhering to Inspection Guidelines, but
There Are Potential Issues with Agency Procedures
* CBP Officers Appeared to Use Equipment Correctly and Follow
Procedures
* Potential Issues in CBP's Inspection Procedures Could Be
Mitigated to Improve Detection Capabilities
* DHS Is Working to Improve the Capabilities of Currently-fielded
and New Radiation Detection Equipment, but Much Work Remains to
Achieve Better Equipment Performance
* Currently-fielded Radiation Detection Equipment Has Inherent
Limitations
* DHS Has Sponsored Research and Development to Improve the
Capabilities of Current Technology and to Develop New
Technology but Much Work Remains
* DHS Sponsors Test Facilities in Nevada, New York, and New
Jersey to Support Efforts to Improve Detection Capabilities
* The Newly Created Domestic Nuclear Detection Office Is Structured
to Improve Coordination of Executive Branch Radiation Detection
Programs
* DNDO Attempts to Improve Cooperation Among Other DHS
Offices, DOE, DOD, and Other Agencies in Deploying and
Operating Equipment
* DNDO Is Cooperating with Other Agencies to Develop a Global
Nuclear Detection System
* Conclusions
* Recommendations for Executive Action
* Agency Comments and Our Evaluation
* Scope and Methodology
* GAO Contact and Staff knowledgments
* Related GAO Products
Report to Congressional Requesters
March 2006
COMBATING NUCLEAR SMUGGLING
DHS Has Made Progress Deploying Radiation Detection Equipment at U.S.
Ports-of-Entry, but Concerns Remain
Contents
Tables
Figures
March 22, 2006Letter
Congressional Requesters
Since the attacks of September 11, 2001, combating terrorism has been one
of the nation's highest priorities. As part of that effort, preventing
radioactive material from being smuggled into the United States-perhaps to
be used by terrorists in a nuclear weapon or in a radiological dispersal
device (a "dirty bomb")-has become a key national security objective. The
Department of Homeland Security (DHS) is responsible for providing
radiation detection capabilities at U.S. ports-of-entry.1 Until April
2005, U.S. Customs and Border Protection (CBP) managed this program.
However, on April 15, 2005, the president directed the establishment,
within DHS, of the Domestic Nuclear Detection Office (DNDO), whose duties
include acquiring and supporting the deployment of radiation detection
equipment.2 CBP continues its traditional screening function at
ports-of-entry to prevent illegal immigration and to interdict contraband,
including the operation of radiation detection equipment. The Pacific
Northwest National Laboratory (PNNL), one of the Department of Energy's
(DOE) national laboratories, manages the deployment of radiation detection
equipment for DHS.3
DHS's program to deploy radiation detection equipment at U.S.
ports-of-entry has two goals. The first is to use this equipment to screen
all cargo, vehicles, and individuals coming into the United States. The
United States has over 380 border sites at which DHS plans to deploy
radiation detection equipment. The volume of traffic entering the United
States also adds to the size and complexity of the job. For example, each
day, DHS processes about 64,000 containers arriving in the United States
via ships, trucks, and rail cars; 365,000 vehicles; and more than 1.1
million people. The second goal of the program is to screen all of this
traffic without delaying its movement into the nation. To illustrate the
difficulty of achieving this second goal, CBP's port director at the San
Ysidro, California, land border crossing estimated that prior to
initiating radiation screening, the volume of traffic through the
port-of-entry was so great that, at times, the wait to enter the United
States from Mexico was about 2.5 hours. He noted that had radiation
detection screening added a mere 20 seconds to the wait of each vehicle,
the wait during those peak times could have increased to about 3.5 or 4
hours-an unacceptable outcome in his view. DHS's current plans call for
completing deployments of radiation detection equipment at U.S.
ports-of-entry by September 2009.
To screen commerce for radiation, CBP uses several types of detection
equipment and a system of standard operating procedures. Current detection
equipment includes radiation portal monitors, which can detect gamma
radiation (emitted by all of the materials of greatest concern) and
neutrons (emitted by only a limited number of materials, including
plutonium-a material that can be used to make a nuclear weapon). CBP
officers also carry personal radiation detectors-commonly referred to as
"pagers"-small handheld devices that detect gamma radiation, but not
neutrons. For the most part, pagers are meant to be personal safety
devices, although they are used in some locations to assist with
inspections. Finally, CBP officers also use radioactive isotope
identification devices, which are handheld devices designed to determine
the identity of radioactive material-that is, whether it is a nuclear
material used in medicine or industry, a naturally occurring source of
radiation, or weapons-grade material. All of these devices have
limitations in their ability to detect and identify nuclear material.
Generally, CBP's standard procedures direct vehicles, containers, and
people coming into the country to pass through portal monitors to screen
for the presence of radiation. This "primary inspection" serves to alert
CBP officers that a radioactive threat might be present. All traffic that
causes an alarm during primary inspection is to undergo a "secondary
inspection" that consists of screening with another portal monitor to
confirm the presence of radiation, and includes CBP officers using
radiation isotope identification devices to determine the source of
radiation being emitted, (e.g., harmless sources, such as ceramics, or
dangerous sources, such as weapons-grade nuclear material). If CBP
officers identify a nuclear or radiological threat during a secondary
inspection, or if the officers' pagers register a dangerously high level
of radiation, then officers are to establish a safe perimeter around the
nuclear material and contact scientists in CBP's Laboratories and
Scientific Services (LSS) for further guidance.4 In some cases, CBP
identifies incoming sea-bound cargo containers through a system that
targets some containers for inspection based on their perceived level of
risk. In these situations, CBP works with seaport terminals to have
containers moved to an agreed-upon location for inspection. These
inspections include the use of active imaging, such as an x-ray, and
passive radiation detection, such as a radiation isotope identification
device. Typically, if CBP officers find irregularities, physical
examinations are conducted.
In September 2003, we reported on CBP's progress in completing domestic
deployments. In particular, we reported that certain aspects of CBP's
installation and use of the equipment diminished its effectiveness and
that coordination among agencies on long-term research issues was limited.
Since the issuance of our 2003 report, questions have arisen about the
efficacy of the detection equipment CBP has deployed-in particular, its
purported inability to distinguish naturally occurring radioactive
materials from a nuclear bomb.
Because of the complexity and importance of these issues, you asked us to
assess the progress made in (1) deploying radiation detection equipment at
U.S. ports-of-entry and any problems associated with that deployment, (2)
using radiation detection equipment at U.S. ports-of-entry and any
problems associated with that use, (3) improving the capabilities and
testing of this equipment, and (4) increasing the level of cooperation
between DHS and other federal agencies in conducting radiation detection
programs.
To address these objectives, we (1) analyzed CBP's project plan, including
the project's costs and deployment schedules, to deploy radiation
detection equipment at U.S. ports-of-entry; (2) visited several
ports-of-entry, including two international mail and express courier
facilities, five seaports, and three land border crossings; (3)
participated in radiation detection training for CBP officers; and (4)
visited four national laboratories, the Nevada Test Site, and an Air Force
base involved with testing and deploying radiation detection equipment. We
focused primarily on the issues surrounding radiation portal monitors
because they are a major tool in the federal government's efforts to
thwart nuclear smuggling. We also focused on this equipment because its
procurement and installation cost far exceeds the cost of procuring and
deploying other radiation detection equipment such as handheld equipment
also used at U.S. ports-of-entry. We reviewed documentation, such as
deployment and cost figures, equipment test plans and results, and agency
agreements to cooperate in detecting radiation. We also interviewed key
program officials at each of these agencies to discuss the deployment of
radiation detection equipment, attempts to improve the equipment's
capabilities, and cooperation among agencies to protect the United States
from nuclear terrorism. We performed a data reliability assessment of the
data we received, and interviewed knowledgeable agency officials on the
reliability of the data. We determined the data were sufficiently reliable
for the purposes of this report. More details on our scope and methodology
appear in appendix I. We conducted our review from March 2005 to February
2006 in accordance with generally accepted government auditing standards.
Results in Brief
Between October 2000 and October 2005, the United States spent about $286
million to deploy radiation detection equipment at domestic
ports-of-entry. However, the deployment of portal monitors has fallen
behind schedule, making DHS's goal of deploying 3,034 by 2009 unlikely. To
meet its long-term goal, DHS would have to deploy about 52 portal monitors
a month for the next 4 years-a rate that far exceeds the 2005 rate of
about 22 per month. Moreover, the program's estimated total cost of $1.3
billion is highly uncertain. Several factors have contributed to the slow
pace of deployment. First, program officials typically disburse funds to
the contractor managing the deployment late in the fiscal year. For
example, the contractor did not receive its fiscal year 2005 allocation
until September 2005. These delays have caused the contractor to postpone
or cancel contracts, sometimes delaying deployments. According to the
House Appropriations Committee report on the CBP portion of DHS's fiscal
year 2005 budget, CBP should provide the Congress with an acquisition and
deployment plan for the portal monitor program prior to funding Pacific
Northwest National Laboratory (PNNL). This plan took many months to
finalize, mostly because it required multiple approvals within DHS and the
Office of Management and Budget (OMB) prior to being submitted to the
Congress. The lengthy review process delayed the release of funds and, in
some cases, disrupted and delayed deployment. In fiscal year 2005, this
process was further delayed by the creation of DNDO, and the uncertainty
regarding the new office's responsibilities. Second, negotiations with
seaport operators to deploy portal monitors have taken longer than
anticipated because some operators believe screening for radiation will
adversely affect the flow of commerce through their ports. DHS has adopted
a deployment policy designed to achieve cooperation with seaport operators
because agency officials believe such arrangements are more efficient and,
in the long term, probably more timely. Third, devising an effective way
to conduct secondary inspections of rail traffic departing seaports
without disrupting commerce has delayed deployments. This problem may
worsen because the Department of Transportation (DOT) has forecast that
the use of rail transit out of seaports will probably increase in the near
future. Addressing and solving the problems with screening rail transport
is critical to the successful completion of the DHS program.
Regarding the total cost of the project, CBP's $1.3 billion estimate is
highly uncertain and overly optimistic. The estimate is based on CBP's
plans for widespread deployment of advanced technology portal monitors
currently being developed. However, the prototypes of this equipment have
not yet been shown to be more effective than the portal monitors now in
use, and DHS officials say they will not purchase the advanced portal
monitors unless they are proven to be superior. Moreover, when the
advanced technology portal monitors become commercially available, experts
estimate that they will cost between about $330,000 and $460,000 each-far
more than the currently-used portal monitors which cost between $49,000
and $60,000. The installation cost for both types of portal monitor is
roughly $200,000. Even if future test results indicate better detection
capabilities, without a detailed comparison of the two technologies'
capabilities it is not clear that the dramatically higher cost for this
new equipment would be worth the investment. Finally, our analysis of
CBP's deployment data indicates that the program will probably experience
a significant cost overrun of between $88 million and $596 million, with a
$342 million overrun most likely.
The CBP officers we observed conducting primary and secondary inspections
appeared to use radiation detection equipment correctly and to follow
inspection procedures. In contrast, in 2003 we reported that CBP officers
sometimes used radiation detection equipment in ways that reduced its
effectiveness and sometimes did not follow agency procedures. Generally,
CBP requires that its officers receive formal training in using radiation
detection equipment, and many officers have gained experience and
proficiency in using the equipment since the program's inception. However,
we also identified two potential issues in CBP inspection procedures that,
if addressed, could strengthen the nation's defenses against nuclear
smuggling. For example, individuals and organizations shipping
radiological materials to the United States generally must acquire a
Nuclear Regulatory Commission (NRC) license, but regulations do not
require that the license accompany the shipment. Further, according to CBP
officials, CBP officers lack access to NRC license data that could be used
to verify that shippers of radiological material actually obtained
required licenses, and to authenticate licenses that accompany shipments.
The second potential issue pertains to CBP's guidance for conducting
secondary inspections. Currently, CBP procedures require only that
officers locate, isolate, and identify radiological material. Typically,
officers perform an external examination by scanning the sides of cargo
containers with a radiation isotope identification device during secondary
inspections. The guidance does not specifically require officers to open
containers and inspect their interiors, even when an external examination
cannot unambiguously resolve an alarm. However, at one port-of-entry we
visited, CBP officers routinely opened and entered commercial truck
trailers to conduct secondary inspections when an external inspection
could not locate and identify the radiological source. This approach
increases the chances that the source of the radioactivity that originally
set off the alarm will be correctly located and identified. According to
senior CBP officials at this port-of-entry, this additional procedure has
had little negative impact on the flow of commerce and has not increased
the cost of CBP inspections, despite being implemented at one of the
busiest commercial ports-of-entry in the nation.
DHS would like to improve the capabilities of currently-fielded radiation
detection equipment. Today's equipment lacks a refined capability to
rapidly determine the type of radioactive materials they detect, which
means that CBP officers often conduct secondary inspections of containers
carrying non-threatening material. To address this limitation, DHS has
sponsored research, development, and testing activities that attempt to
improve the capabilities of existing radiation portal monitors and to
produce new, advanced technologies with even greater detection and
identification enhancements. However, much work remains for the agency to
achieve consistently better detection capabilities, as the efforts
undertaken so far have had only mixed results. For example, DHS sponsored
the development of a software package designed to reduce the number of
false alarms from portal monitors already in widespread use. However,
tests of the software have been largely inconclusive. In some test
scenarios, there was little difference in detection capability between
portal monitors equipped with-and without-the new software. Experts have
recommended further testing to improve the software's capabilities.
Further, DHS is testing new, advanced portal monitors that use a
technology designed to both detect the presence of radiation and identify
its source. However, in tests performed during 2005, the detection
capabilities of the advanced technology prototypes demonstrated mixed
results-in some cases they worked better, but in other cases, they worked
about the same as already deployed systems. In addition, DHS also sponsors
a long-range research program aimed at developing innovative technologies
designed to improve the capabilities of radiation detection equipment. For
example, DHS is supporting research at two national laboratories on a new
system designed to better detect radiation sources, even when shielded
with materials designed to hide their presence. The two laboratories have
constructed several prototypes, but currently the high cost of this
technology limits its commercial attractiveness. Finally, DHS plans to use
its new testing facility being built at the Nevada Test Site to improve on
existing test capabilities and to support the agency's development,
testing, acquisition, and deployment of radiation detection technologies.
Historically, cooperation between agencies conducting radiation detection
programs has been limited. Currently DHS, largely through DNDO, cooperates
with DOE, the Department of Defense (DOD), and other agencies to
coordinate these programs; however, because DNDO was created less than 1
year ago, its cooperative efforts-and its working relationships with other
federal agencies-are in their early stages of development and
implementation. Currently, other federal agencies are providing staff to
work directly with DNDO. However, it is too soon to determine the overall
effectiveness of these efforts. DHS also works with other agencies to make
current detection efforts more efficient and effective. For example, in
April 2005, DHS and DOE entered into a memorandum of understanding to,
among other things, exchange information on radiation detection
technologies to improve the effectiveness of their deployment; the
agencies also agreed to share lessons learned from operational
experiences, and data received from radiation detection equipment deployed
at U.S. and foreign ports. Also in April 2005, DHS entered into an
agreement with the Port Authority of New York and New Jersey to, among
other things, integrate lessons learned from field experience into
domestic radiation detection efforts. In the future, DNDO intends to
develop an integrated worldwide system. The resulting "global
architecture," as it is being called by DNDO officials, would be a
multi-layered defense strategy that includes programs that attempt to
secure nuclear materials and detect their movements overseas, such as
DOE's Second Line of Defense program; to develop intelligence information
on nuclear materials' trans-shipments and possible movement to the United
States; and to integrate these elements with domestic radiation detection
efforts undertaken by governments-federal, state, local, and tribal-and
the private sector.
We are recommending a series of actions designed to help DHS speed up the
pace of portal monitor deployments, better account for schedule delays and
cost uncertainties, make the most efficient use of program resources, and
improve its ability to interdict illicit nuclear materials.
We provided a draft of this report to DHS for its review and comment. DHS
stated that it agreed with, and will implement, our recommendations.
Background
Initial concerns about the threat posed by nuclear smuggling were focused
on nuclear materials originating in the former Soviet Union. As a result,
the first major initiatives concentrated on deploying radiation detection
equipment at borders in countries of the former Soviet Union and in
Central and Eastern Europe. In particular, in 1998, DOE established the
Second Line of Defense program, which, through the end of fiscal year
2005, had installed equipment at 83 sites mostly in Russia.5 In 2003, DOE
implemented a second program, the Megaports Initiative,6 to focus on the
threat posed by nuclear smuggling overseas by installing radiation
detection equipment at major seaports around the world.7 In the United
States, the U.S. Customs Service began providing its inspectors with
portable radiation detection devices in 1998. After September 11, 2001,
the agency expanded its efforts to include the deployment of portal
monitors-large-scale radiation detectors that can be used to screen
vehicles and cargo.8 In March 2003, the U.S. Customs Service was
transferred to DHS, and the border inspection functions of the Customs
Service, including radiation detection, became the responsibility of CBP.9
Deploying radiation detection equipment at U.S. borders is part of DHS's
strategy for addressing the threat of nuclear and radiological terrorism.
DHS's strategy includes: (1) countering proliferation at the source by
assisting foreign governments in their efforts to detect and interdict
nuclear and radiological smuggling; (2) controlling the illegal export of
technology and equipment from the United States that terrorists could use
to develop a nuclear or radiological weapon; (3) detecting and
interdicting potential smuggling attempts before they reach the United
States; and (4) securing U.S. ports-of-entry through multiple technologies
that include radiation detection and nonintrusive inspections to view
images of cargo in sea containers.
CBP plans to deploy radiation portal monitors in five phases, or
"categories of entry": (1) international mail and express courier
facilities; (2) major northern border crossings; (3) major seaports; (4)
southwestern border crossings; and (5) all other categories, including
international airports, remaining northern border crossings and seaports,
and all rail crossings. In this final phase, CBP also plans to replace the
currently-fielded portal monitors with newer, more advanced technology.
Generally, CBP prioritized these categories according to their perceived
vulnerability to the threat of nuclear smuggling. CBP did not, however,
conduct a formal threat assessment. International mail and express courier
facilities present a potential vulnerability because mail and packages
arrive with no advance notice or screening. Northern border crossings are
also vulnerable, according to CBP, because of the possible presence of
terrorist cells operating in Canada. The third category, major seaports,
is considered vulnerable because sea cargo containers are suitable for
smuggling and because of the large volume of such cargo. Seaports account
for over 95 percent of the cargo entering the United States. Southwestern
borders are vulnerable because of the high volume of traffic and because
of the smuggling that already occurs there. Although airlines can quickly
ship and deliver air cargo, CBP considers air cargo to be a slightly
lesser risk because the industry is highly regulated.
In deploying radiation detection equipment at U.S. borders, CBP identified
the types of nuclear materials that might be smuggled, and the equipment
needed to detect its presence. The radiological materials of concern
include assembled nuclear weapons; nuclear material that could be used in
a nuclear weapon but that is not actually assembled into a weapon
("weapons-grade nuclear material"); radiological disbursal devices,
commonly called "dirty bombs;" and other illicit radioactive material,
such as contaminated steel or inappropriately marked or manifested
material. Detecting actual cases of attempted nuclear smuggling is
difficult because there are many sources of radiation that are legal and
not harmful when used as intended. These materials can trigger alarms
(known as "nuisance alarms") that are indistinguishable from those alarms
that could sound in the event of a true case of nuclear smuggling.
Nuisance alarms are caused by patients who have recently had radiological
treatment; a wide range of cargo with naturally occurring radiation, such
as fertilizer, ceramics, and food products; and legitimate shipments of
radiological sources for use in medicine and industry. In addition,
detecting highly-enriched uranium, in particular, is difficult because of
its relatively low level of radioactivity. Furthermore, a potential
terrorist would likely attempt to shield the material to reduce the amount
of radiation reaching the detector and thereby decrease the probability of
detection.
The process of deploying portal monitors begins with a site survey to
identify the best location at an entry point for installing the equipment.
While in some cases the choice may be obvious, operational considerations
at many entry points require analysis to find a location where all or most
of the cargo and vehicles can pass through the portal monitor without
interfering with the flow of commerce. After identifying the best option,
CBP works with local government and private entities to get their support.
At many U.S. entry points, the federal government does not own the
property and therefore collaborates with these entities to deploy the
equipment. It is CBP's policy to depend exclusively on such negotiations,
rather than to use any kind of eminent domain or condemnation proceeding.
The actual installation of the portal monitors involves a number of tasks
such as pouring concrete, laying electrical groundwork, and hooking up the
portal monitors to alarm systems that alert officers when radiation is
detected. Finally, PNNL tests the equipment and trains CBP officers on its
operation, including how to respond to alarms.
To coordinate the national effort to protect the United States from
nuclear and radiological threats, in April 2005, the president directed
the establishment of DNDO within DHS. The new office's mission covers a
broad spectrum of responsibilities and activities, but is focused
primarily on providing a single accountable organization to develop a
layered defense system. This system is intended to integrate the federal
government's nuclear detection, notification, and response systems. In
addition, under the directive, DNDO is to acquire, develop, and support
the deployment of detection equipment in the United States, as well as to
coordinate the nation's nuclear detection research and development
efforts. For fiscal year 2006, DNDO's total budget is approximately $318
million, which includes at least $81 million for research and development
of advanced nuclear detection technologies and $125 million for portal
monitor purchase and deployment.
The Homeland Security Act of 2002 gave DHS responsibility for managing the
research, development, and testing of technologies to improve the U.S.
capability to detect illicit nuclear material.10 Prior to the creation of
DNDO, DHS's Science and Technology (S&T) directorate had this
responsibility. DNDO has assumed these responsibilities and works with
S&T's Counter Measures Test Beds (CMTB) to test radiation detection
equipment in New York and New Jersey. As of January 2006, DNDO has
provided $605,000 to DOE national laboratories that support this effort.
Additional funding for fiscal year 2006 from S&T and DNDO to support test
and evaluation activities at the CMTB is yet to be determined. The
Homeland Security Act also provided DHS the authority to use DOE national
laboratories for research, development, and testing of new technologies to
detect nuclear material.11
DHS Has Made Progress in Deploying Radiation Detection Equipment, but the
Agency's Program Goals Are Unrealistic and the Cost Estimate Is Uncertain
As of December 2005, DHS had completed deployment of portal monitors at
two categories of entry-a total of 61 ports-of-entry-and has begun work on
two other categories; overall, however, progress has been slower than
planned. According to DHS officials, the slow progress has resulted from a
late disbursal of funds, and delays in negotiating deployment agreements
with seaport operators. Further, we believe the expected cost of the
program is uncertain because DHS's plans to purchase newer, more advanced
equipment are not yet finalized; also we project that the program's final
cost will be much higher than CBP currently anticipates.
The Program to Install Portal Monitors Has Fallen Behind Schedule
Between October 2000 and October 2005, DHS, mainly through its prime
contractor PNNL, has spent about $286 million to deploy radiation
detection equipment at U.S. ports-of-entry. As of December 2005, DHS had
deployed 670 of 3,034 radiation portal monitors-about 22 percent of the
portal monitors DHS plans to deploy.12 The agency has completed portal
monitor deployments at international mail and express courier facilities
and the first phase of northern border sites-57 and 217 portal monitors,
respectively. In addition, by December 2005, DHS had deployed 143 of 495
portal monitors at seaports and 244 of 360 at southern borders. In
addition, three portal monitors had been installed at the Nevada Test Site
to analyze their detection capabilities and four had been retrofitted at
express mail facilities. As of February 2006, CBP estimated that with
these deployments CBP has the ability to screen about 62 percent of all
containerized shipments entering the United States, and roughly 77 percent
of all private vehicles (POVs). Within these total percentages, CBP can
screen 32 percent of all containerized seaborne shipments; 90 percent of
commercial trucks and 80 percent of private vehicles entering from Canada;
and approximately 88 percent of all commercial trucks and 74 percent of
all private vehicles entering from Mexico.
CBP does not maintain a firm schedule for deploying handheld radiation
detectors, such as pagers and radiation isotope identification devices.
This is equipment used mainly to help pinpoint and identify sources of
radiation found during inspections. Instead, according to CBP officials,
the agency acquires and deploys such equipment each fiscal year as needed.
The handheld radiation detectors are procured to coincide with portal
monitor deployments to ensure mission support. Since fiscal year 2001, CBP
has spent about $24.5 million on pagers, and about $6.6 million on
radiation isotope identification devices. At present, CBP can field
roughly 12,450 pagers-enough to ensure that all officers conducting
primary or secondary inspections at a given time have one. The agency
intends to deploy about 6,500 additional pagers. Similarly, CBP's 549
radiation isotope identification devices are deployed at domestic
ports-of-entry. CBP intends to acquire another 900 to ensure that all
needs are met.
Overall, CBP and PNNL have experienced difficulty meeting the portal
monitor deployment schedule. None of the planned portal monitor
deployments has progressed according to schedule, and monthly deployments
would have to increase by almost 230 percent to meet a September 2009
program completion date. For example, in November 2005, deployments at
land crossings were about 20 months and $1.9 million behind schedule,
while deployments at the first 22 seaports were about 2 years and $24
million behind schedule.13 Despite these delays, PNNL reported in November
2005 that the overall project schedule should not extend beyond its
current completion date of September 2009. However, our analysis indicates
that CBP's deployment schedule is too optimistic.
In fact, for CBP and PNNL to meet the current deployment schedule, they
would have to install about 52 portal monitors per month from November
2005 to September 2009. In our view, this is unlikely because it requires
a rate of deployment that far exceeds recent experience. For example,
during calendar year 2005, PNNL deployed portal monitors at the rate of
about 22 per month, and deployments have fallen further and further behind
schedule. Between February and December 2005, for example, PNNL did not
meet any of its scheduled monthly deployments, never deploying more than
38 portal monitors during any single month. If CBP continues to deploy
portal monitors at its 2005 pace, the last monitor would not be deployed
until about December 2014. Table 1 details the status of portal monitor
deployments, as of December 2005.
Table 1: Status of Portal Monitor Deployments as of December 2005
Portal monitor deployment phase Total portals Status
planned
International mail and express 57 Completed April 2004 4
consignment facilitiesa (23 months late
facilities)
Land border and rail ports-of-entry 967 20 months late
(205 crossings)
Seaports (106 terminals) and 1,205 24 months late
international airports
Retrofitsb 82c Projected September
2009 completion
Other sitesd 3
Excess equipmente 721
Total 3,035f
Sources: PNNL and CBP.
aExcludes FedEx and UPS, both of whom screen packages overseas as agreed
in a memorandum of understanding with CBP.
b"Retrofitting" refers to replacing currently-fielded portal monitors with
advanced-technology portal monitors.
cPNNL plans a "net" increase of 82 portal monitors as a result of
retrofits.
d"Other sites" refers to portal monitors installed at the Nevada Test Site
for testing purposes.
e"Excess equipment" refers to the older portal monitors being replaced
through the retrofit process.
fThe total number of portal monitors planned for deployment is based on
December 2005 estimates from CBP and PNNL. It represents a recent estimate
of CBP's requirements, and according to CBP, it will be used to update the
agency's current deployment plan, which calls for deploying 2,397 portal
monitors by September 2009.
Further, we analyzed CBP's earned value management data as of November
2005 and determined that, although CBP planned for the deployment program
to be 20.5 percent complete by that date, the program is only about 16
percent complete. In addition, our analysis indicates that since the
program's inception, work valued at $48.6 million has fallen behind
schedule. Moreover, the trend over the past 14 months shows CBP and PNNL
falling further behind schedule, as seen in figure 1.
Figure 1: Monthly Cumulative Values of Work Planned but Not Finished As
Planned
Note: The "zeropoint" on this figure denotes work that was completed at
its planned cost. A positive number means that all the work completed to
that point costs less than planned, while a negative number means that all
the work completed to that point costs more than planned.
There have been at least three major sources of delay that have affected
the portal monitor deployment program: funding issues, negotiations with
seaport terminal operators, and problems in screening rail
cars-particularly in a seaport environment.
Funding Issues
According to CBP and PNNL officials, recurrent difficulties with the
project's funding are the most important explanations of the schedule
delays. Specifically, according to DHS and PNNL officials, CBP has been
chronically late in providing appropriated funds to PNNL, thereby
hindering its ability to meet program deployment goals. For example, PNNL
did not receive its fiscal year 2005 funding until September 2005.
According to PNNL officials, because of this delay, some contracting
activities in all deployment phases had to be delayed or halted, but the
adverse effects on seaports were especially severe. For example, PNNL
reported in August 2005 that site preparation work at 13 seaports had to
cease because the Laboratory had not yet received its fiscal year 2005
funding allocation. According to senior CBP officials, their agency's
inability to provide a timely spending plan to the Congress for the portal
monitor deployment program is the main reason for these funding delays.
According to the House Appropriations Committee report on the CBP portion
of DHS's fiscal year 2005 budget, CBP should provide the Congress an
acquisition and deployment plan for the portal monitor program prior to
funding PNNL.14 However, these plans typically take many months for CBP to
finalize-in part because CBP requires that the plans undergo several
levels of review-but also because these plans are reviewed by DHS and OMB
before being submitted to the Congress. In fiscal year 2005, this process
was further delayed by the creation of DNDO, uncertainty regarding DNDO's
responsibilities, and negotiations regarding the expenditure of the fiscal
year 2005 appropriations.
CBP has tried to address this problem by reprogramming funds when money
from other programs is available. In some cases, the amount of
reprogrammed funds has been fairly large. For example, about 15 percent of
fiscal year 2005's funding included money reprogrammed from other CBP
sources, or almost $14 million. In fiscal year 2004, about $16 million was
reprogrammed-or about a third of the fiscal year's total. And in fiscal
year 2003, the total of reprogrammed money was about $18 million-about 20
percent.
Delays in Gaining Agreements Have Slowed Seaport Deployments
Negotiations with seaport operators have been slow and have also delayed
the portal monitor deployment program. According to CBP and PNNL
officials, one of the primary reasons behind the seaport phase's
substantial delay in deployments is the difficulty in obtaining
contractual agreements with port and terminal operators at seaports. DHS
has not attempted to impose agreements on seaport operators because,
according to officials, cooperative arrangements with the port operators
are more efficient and, in the long term, probably more timely. According
to CBP and PNNL officials, many operators believe screening for radiation
will adversely affect the flow of commerce through their ports. In
addition, deploying portal monitors in major seaports presents several
unique challenges. For example, seaports are much larger than land border
crossings, consist of multiple terminals, and may have multiple exits.
Because of these multiple exits, seaports require a greater number of
portal monitors, which may entail more negotiations with port and terminal
operators. In addition, port operators at times have insisted on
late-stage design changes, requested various studies prior to proceeding
with final designs, insisted on inefficient construction schedules, and
delayed their final review and approval of project designs. According to
CBP and PNNL, these efforts often reflect the port and terminal operators'
uneasiness with portal monitor deployments, and their resolve to ensure
that the outcome of the deployment process maintains their businesses'
competitiveness. For example, port officials at one seaport requested
several changes late in the process, including performing an unscheduled
survey for laying cable, revising portal monitor locations at two gates,
and adding a CBP control booth at a third terminal. According to CBP and
PNNL officials, the agency prefers to accommodate these types of changes,
even late in the process and even if they slow deployment, because in the
long term they believe it is more efficient and effective.
Screening Rail Cars in Seaports Presents Unique Problems
The difficulty of devising an effective and efficient way to conduct
secondary inspections of rail traffic departing seaports without
disrupting commerce has created operational issues that could further
delay deployments. Four of the five seaports we visited employ rail cars
to ship significant amounts of cargo. In one seaport, the port director
estimated that about 80-85 percent of the cargo shipped through his port
departs via rail. For the other three seaports, the percentages for rail
traffic were 5 percent, 13 percent, and 40 percent respectively. According
to port officials, these seaports would like to accommodate CBP's efforts
to install radiation detection equipment designed to screen rail traffic,
but they are concerned that the logistics of conducting secondary
inspections on trains as they prepare to depart the seaport could back up
rail traffic within the port and disrupt rail schedules throughout the
region-potentially costing the port tens of thousands of dollars in lost
revenue. For example, one senior port authority official told us that his
port lacked ample space to park trains for secondary inspections, or to
maneuver trains to decouple the rail car(s) that may have caused a primary
inspection alarm. As a result, trains that cause a primary alarm would
have to wait, in place, for CBP to conduct a secondary inspection,
blocking any other trains from leaving the port. According to this port
official, any delay whatsoever with a train leaving the port could cause
rail problems down the line because track switches are geared to train
schedules. To avoid these kinds of problems, CBP has delayed deploying
portal monitors in this seaport until technical and operational issues can
be overcome. As of December 2005, no portal monitors had been deployed at
this seaport, although according to PNNL's schedule, 5 of its 11
terminals-a total of 19 portal monitors-should have been deployed by
October 2005. According to the port director at another seaport we
visited, a port that actually has a rail portal monitor installed, similar
operational issues exist. However, in addition to backing up rail traffic
within the port, trains awaiting secondary inspections at this port could
block the entrance/exit to a nearby military base. The director of the
state's port authority told us that his solution has been to simply turn
off the portal monitor. According to CBP officials, this was entirely a
state decision, since this portal monitor is the state's responsibility
and not part of CBP's deployment. However, these officials also noted that
they agreed with the states and noted that they would not attempt to
impose a solution or deadline on either port. CBP officials noted that
most seaport operators seem willing to accommodate portal monitors, but
until a better portal monitor technology evolves that can help ensure a
smooth flow of rail traffic out of the port, negotiations with seaport
operators will continue to be slow.
According to CBP and port officials, they have considered several
potential solutions. For example, there is widespread agreement that
screening sea cargo containers before they are placed on rail cars offers
the best solution, but this option is operationally difficult in many
seaports. Mobile portal monitors, when commercially available, may also
offer a partial solution. In addition, CBP is optimistic that advanced
portal monitors, when they become commercially available, may help solve
some of the problems in the rail environment by limiting the number of
nuisance alarms. However, according to the CBP and port officials we
contacted, screening rail traffic continues to pose a vexing operational
problem for seaports.
The concerns that seaport operators and CBP expressed regarding screening
rail commerce in seaports may increase and intensify in the future because
rail traffic, in general, is expected to increase substantially by 2020.
DOT has forecast that by 2020, rail will transport roughly 699 million
tons of international freight-up from 358 million tons carried in 1998.
Officials at 3 of the 5 seaports we visited expect rail traffic through
their facilities to increase dramatically during the next 10 to 15 years.
As the volume of trade increases, so too will the economic stakes for the
port and terminal operators, while the regulatory burden for CBP is likely
to increase as well. Delays-for any reason, including radiation
detection-are likely to become more costly, and CBP will likely have
ever-increasing numbers of rail cars to screen.
In addition, although CBP is not scheduled to begin deploying portal
monitors to screen rail shipments at land border crossings until 2007, the
agency will likely experience operational challenges at land border
crossing similar to those it is now experiencing at seaports. For example,
at both land border crossings and seaports, if a rail car alarms as it
passes through a portal monitor, that car will possibly have to be
separated from the remaining train-sometimes a mile in length-to undergo a
secondary inspection. Furthermore, because trains transport numerous types
of cargo containing large quantities of naturally occurring radioactive
material, CBP faces the challenge of maintaining a nuisance alarm rate
that does not adversely affect commerce. CBP and PNNL are currently
conducting testing of a prototype rail portal monitor to determine the
potential impact of naturally occurring radioactive material on rail
operations at land border crossings.
Other Factors Have Delayed Portal Monitor Deployments
Unforeseen design and construction problems have also played a role in
delaying portal monitor deployments. For example, deployments at six
southern border sites have been delayed to coincide with the sites'
expansion activities. According to CBP officials, there are two approaches
to accommodating a port-of-entry's alterations, both of which may delay
portal monitor deployments. First, CBP and PNNL may decide to delay the
start of portal monitor projects until the port-of-entry completes its
alterations, to make certain that portal monitor placements are properly
located. Second, port-of-entry expansion activities may alter existing
traffic flows and require that PNNL redesign its portal monitor
deployments. The portal monitor deployments at three southern border
ports-of-entry has taken much longer than planned because of the port's
expansion activities. According to PNNL, there is now considerable
schedule uncertainty associated with these deployments, which may
ultimately impact the completion of the southern land border deployments.
Portal monitor deployments have also been hampered by poor weather. For
example, cold weather at several northern sites caused some unexpected
work stoppages and equipment failures that resulted in construction delays
of 2 to 3 months. Finally, one southern border site has been delayed
because of major flooding problems. The flooding issue must be resolved
before the deployment can be completed.
DHS's Portal Monitor Deployment Program Cost Estimate Is Uncertain and
Overly Optimistic
DHS's current estimate to complete the program is $1.3 billion, but this
estimate is highly uncertain and overly optimistic. First, DHS's cost
estimate is based on a plan to deploy advanced-technology portal monitors
that have so far shown mixed results for detecting radiation compared to
currently-fielded portal monitors. Since the efficacy of the advanced
portal monitors has not yet been proven conclusively, there is at least
some uncertainty over whether-and, if so, how many-of the new portal
monitors may be deployed. In addition, the final cost of the new portal
monitors has not been established. Second, our analysis of CBP's earned
value data also suggests that the program will likely cost much more than
planned.
The current deployment plan calls for installing advanced portal monitors
at all cargo primary and secondary inspection locations, at all secondary
inspection locations for private vehicles, and also retrofitting many
sites with the advanced equipment, when it becomes available. However,
according to senior officials at DNDO, the advanced technology must meet
all of DNDO's performance criteria, and must be proven superior to the
portal monitors already in use, before DNDO will procure it for use in the
United States. Recent tests of the new portal monitors indicate that
DNDO's criteria have not yet been met. For example, S&T sponsored research
in 2004 that compared the detection capabilities of currently-fielded
portal monitors with the advanced portal monitors. The results of that
research suggested that, in some scenarios, the detection abilities of the
two portal monitor types were nearly equivalent. In other scenarios, the
new equipment's detection capability was significantly better. S&T
concluded that more work remains to be done in optimizing and comparing
portal monitors so as to understand how they can be used to the greatest
effect at U.S. ports-of-entry. In 2005, DNDO sponsored additional research
designed to compare the two types of portal monitor, and determined that
the advanced portal monitors' detection capabilities were somewhat better
than those of the currently-fielded equipment. In addition, in October
2005, DNDO completed the first comprehensive tests for these advanced
portal monitors at the Nevada Test Site. This advanced technology combines
the ability to detect radiation and identify its source. According to an
official who helped supervise these tests, the new portal monitors'
performance did not meet all of DNDO's expectations with regard to
providing significant detection improvements over currently-fielded
equipment in all scenarios. CBP and DNDO officials also expressed concerns
regarding the advanced portal monitors' detection capabilities in light of
the Nevada test results. In particular, senior CBP officials questioned
whether the advanced portal monitors would be worth their considerable
extra costs, and emphasized finding the right mix of current and
advanced-technology equipment based on the needs at individual
ports-of-entry. According to DNDO officials, the potential improvement
over currently fielded portal monitors in capability to identify
radioactive sources, and hence to detect actual threats as opposed to
simply detecting radiation, has not yet been quantified. However, these
officials believe that the results to date have been promising, and DNDO
intends to continue supporting the advanced portal monitor's development
and believe the new technology may be ready for deployment early in
calendar year 2007.
There is also considerable uncertainty regarding the eventual cost of the
advanced portal monitors-if they become commercially available, and if
DNDO opts to use them. Experts we contacted estimated that the new portal
monitors could cost between $330,000 and $460,000 each. These estimates
are highly uncertain because advanced portal monitors are not yet
commercially available. As a point of reference, the portal monitors
currently in use typically cost between $49,000 and $60,000. These costs
include only the purchase price of the equipment, not its installation.
According to CBP and PNNL officials, installation costs vary, but average
about $200,000 per portal monitor. Even if future test results indicate
that the new technology exhibits much better detection and identification
capabilities, it would not be clear that the dramatically higher cost for
this new equipment would be worth the considerable investment, without the
agency having first rigorously compared the portal monitors' capabilities
taking their costs into account. Currently, DNDO and CBP are working
together to determine the most appropriate technologies and concepts of
operation for each port-of-entry site. The two agencies are also trying to
determine the highest priority sites for advanced-technology portal
monitors based on the extent to which the new portal monitors show
improved performance.
In November 2005, PNNL reported that the portal monitor deployment program
could experience an overall cost overrun of $36 million. In contrast, our
analysis of CBP's earned value data indicates that the agency should
expect a cost overrun of between $88 million and $596 million. We based
our cost overrun projections on the rates at which CBP and PNNL deployed
portal monitors, through November 2005. The more efficient the agency and
its contractor are in deploying portal monitors, the smaller the cost
overruns; conversely, when efficiency declines, cost overruns increase.15
In fact, as shown in figure 2, recent cumulative program cost trends have
been negative, indicating that CBP's cost overruns are deepening over
time.
Figure 2: Monthly Cumulative Cost Overruns
Note: The "zero point" on this figure denotes work that was completed at
its planned cost. A positive number means that all the work completed to
that point costs less than planned, while a negative number means that all
the work completed to that point costs more than planned.
PNNL noted that its management reserve of $62 million should cover the
anticipated overrun. However, we do not agree.16 First, we believe the
cumulative cost overrun will far exceed PNNL's estimate of $36 million. We
believe an overrun of about $342 million, the midpoint of our projected
overrun range, is more likely. Since 1977, we have analyzed over 700
acquisition projects on which EVM techniques have been applied. These
analyses consistently show that once a program is 15 percent complete (as
is the case with this program), cost performance almost never improves
and, in most cases, declines. PNNL's recent cost trend follows this
pattern. Second, based on these 700-plus studies, our estimate takes a
more realistic view that the portal monitor deployment program's cost
performance most likely will continue to decline; hence the management
reserve will be consumed over time as the program incurs unexpected
expenses. Finally, to meet the deployment program's planned costs, PNNL
would have to greatly improve its work efficiency. However, our analysis
of prior EVM-based projects indicates that productivity rates nearly
always decline over the course of a project. We determined that PNNL's
efficiency rate for the most recent 8 months has averaged about 86
percent-PNNL has been delivering about $.86 worth of work for every dollar
spent. In order to complete the remaining work with available funding,
PNNL's efficiency rate would have to climb to around 98 percent, a rate of
improvement unprecedented in the 700-plus studies we have analyzed.
CBP Does Not Know If PNNL's Cost and Schedule Data Are Reliable
Federal agencies are required by OMB to track the progress of major
systems acquisitions using a validated EVM system and to conduct an
integrated baseline review.17 We found that PNNL has an EVM system but has
not certified it to show that it complies with guidance developed by the
American National Standards Institute/Electronic Industries Alliance.18
This guidance identifies 32 criteria that reliable EVM systems should
meet. In addition, we found that PNNL has not conducted an integrated
baseline review-a necessary step to ensure that the EVM baseline for the
portal monitor program represents all work to be completed, and adequate
resources are available.
However, although the EVM data have not been independently validated, we
examined the EVM data and found that they did not show any anomalies and
were very detailed. Therefore, we used them to analyze the portal monitor
program status and to make independent projections of the program's final
costs at completion.
CBP Officers Have Made Progress in Using Radiation Detection Equipment
Correctly and Adhering to Inspection Guidelines, but There Are Potential
Issues with Agency Procedures
CBP officers we observed conducting primary and secondary inspections
appeared to use radiation detection equipment correctly and to follow the
agency's inspection procedures. In fact, in some cases, CBP officers
exceeded standard inspection procedure requirements by opening and
entering containers to better identify radiation sources. In contrast, in
2003, when we issued our last report on domestic radiation detection, CBP
officers sometimes deviated from standard inspection procedures and, at
times, used detection equipment incorrectly. However, the agency's
inspection procedures could be strengthened.
CBP Officers Appeared to Use Equipment Correctly and Follow Procedures
During this review, at the 10 ports-of-entry that we visited, the CBP
officers we observed conducting primary and secondary inspections
appeared to follow inspection procedures and to use radiation detection
equipment correctly. The officers' current proficiency in these areas
follows increases in training and in CBP's experience using the detection
equipment. In contrast, in 2003 we reported that CBP officers sometimes
used radiation detection equipment in ways that reduced its effectiveness.
CBP has increased the number of its officers trained to use radiation
detection equipment; in fact, the agency now requires that officers
receive training before they operate radiation detection equipment. As of
February 2006, CBP had trained 6,410 officers to use radiation isotope
identification devices, 8,461 to use portal monitors, and 22,180 to use
pagers. Many CBP officers received training on more than one piece of
equipment and about 900 have since left the agency. Generally, today CBP
officers receive radiation detection training from 4 sources: the CBP
Academy in Glynco, Georgia; the Border Patrol Academy in Artesia, New
Mexico; a DOE-sponsored 3-day training course for interdicting weapons of
mass destruction, in Washington state; and on-the-job training at
ports-of-entry. Training at the Academies in Georgia and New Mexico
includes formal classroom instruction, as well as hands-on exercises on
how to use portal monitors, isotope identifiers, and pagers. This training
includes simulated scenarios in which officers use radiation detection
equipment to conduct searches for nuclear and radiological materials.
On-the-job instruction continues at field locations as senior CBP
officers, as well as PNNL and other DHS contractor staff, work closely
with inexperienced officers to provide them with practical training on how
the radiation detection equipment works and how to respond to alarms.
According to senior CBP officials, all of the instructors that offer
training on using radiation detection equipment are certified in its use.
Trainees must demonstrate proficiency in the use of each system prior to
assuming full responsibility for radiation detection inspections. About
1,600 CBP officers have participated in DOE's 3-day training course
designed to acquaint CBP officers with detection equipment. CBP is
currently developing refresher training courses on the use of radiation
detection equipment. To further enhance officers' ability to effectively
respond to real or potential threats, several of the field locations that
we visited conduct "table-top exercises" that simulate scenarios in which
the equipment detects an illicit radiological source.
According to several of the CBP field supervisors we contacted, many
officers have gained proficiency in following procedures and using
radiation detection equipment through substantial field experience
responding to alarms. The number of alarms officers typically handle
varies according to the size of the site, its location, and type. For
example, an isolated land border site would probably experience fewer
alarms than a major seaport because of the differences in the volume of
traffic. However, it was common for several of the locations we visited to
experience 15 to 60 alarms per day. One seaport we visited had 9
terminals, usually with 2 primary and 1 secondary portal monitors.
According to CBP officials, each terminal recorded about 8 to 12 alarms
per day. The director of port security for a major eastern seaport we
visited estimated that her facility records roughly 150 portal monitor
alarms each day. Virtually all have been nuisance alarms, but CBP
officials still believe they gained valuable experience in using the
equipment and following procedures.
All of the primary and secondary inspections we witnessed were nuisance
alarms. In all of these cases except one, officers followed CBP's
guidance-as well as local variations meant to address issues unique to the
area-and correctly used detection equipment. The lone exception occurred
at a site whose primary inspection station was staffed by a state port
police officer. After the station's portal monitor registered an alarm for
a truck departing the site, the police officer did not follow CBP's
procedures.19 For example, he did not collect any documentation from the
driver. At all other sites we visited, when a primary portal monitor
sounded, CBP officers gathered the cargo's manifest, the vehicle
registration, and the driver's license prior to sending the vehicle
through secondary inspection. Officers use these documents to check the
driver and vehicle cargo. The port police officer told us that he
recognized the driver in this case, and so the officer did not believe it
was necessary to collect such information. A CBP officer performed the
secondary inspection in line with agency guidance. In fact, after using a
radiation isotope identification device to conduct an external inspection
and determine the source of the alarm-potassium hydroxide-the officer
required that the driver open the back of the truck so she could make a
visual check of the cargo. From the time of the initial alarm, until the
truck departed the site boundary, about 35 minutes elapsed. According to
port and CBP officials, this particular alarm, its resolution, and the
amount of time it took to resolve are typical of the site. We also
discussed the site's radiation detection efforts with the truck driver, in
particular the delay associated with this alarm. He noted that he
considers the delays experienced at this site to be relatively minor, and
that the delays have not had any adverse effects on his business.
We also visited a seaport that experienced a legitimate alarm in which CBP
officers used the detection equipment correctly and responded according to
procedures. Uranium hexafluoride, a potentially hazardous chemical
containing low levels of radioactivity, caused this alarm. A primary
portal monitor at the seaport sounded as a truck carrying one container
attempted to exit a terminal. Following standard operating procedures, the
truck was diverted to a secondary inspection station, where a secondary
portal monitor also alarmed. A CBP officer then scanned the container and
cab of the truck with an isotope identifier, which indicated that the
radiation source was located in the cab within several metal pails. The
isotope identifier identified two radiation sources, one of which was
uranium-235-potentially a weapons-usable material. The other source was
uranium-238. Again following procedures, CBP officers isolated the sources
of radiation and provided LSS scientists with information collected by the
isotope identifier. Officers also reviewed the driver's delivery papers;
used various CBP databases to check the driver, importer, and consignee's
history of transporting goods; and contacted the driver's dispatcher and
the U.S. consignee to gather information on and assess the legitimacy of
the shipment. The consignee explained that the pails contained trace
amounts of uranium hexafluoride that had been sent to the company's
laboratory for testing. Following additional investigation, which included
an X-ray of the pails and a review of DOT requirements regarding
radiation-warning placard requirements, CBP determined that the event was
not a security threat and released the driver and conveyance. Senior
officials at this seaport told us that CBP's radiation detection guidance
served as an effective and successful guide to resolving this alarm.
Potential Issues in CBP's Inspection Procedures Could Be Mitigated to
Improve Detection Capabilities
We identified two potential issues in CBP's national inspection procedures
that could increase the nation's vulnerability to nuclear smuggling. The
first potential issue involves NRC documentation. Generally, NRC requires
that importers obtain an NRC license for their legitimate shipments of
radiological materials into the United States.20 However, NRC regulations
do not require that the license accompany the shipment, although in some
cases importers choose to voluntarily include the license. According to
CBP officials, CBP lacks access to NRC license data that could be used to
verify that importers actually acquired the necessary licenses or to
authenticate a license at the border. At present, CBP officers employ a
variety of investigative techniques to try to determine if individuals or
organizations are authorized to transport a radiological shipment. For
example, CBP officers review their entry paperwork, such as shipping
papers. Officers also often interview drivers about the details of the
delivery and observe their behavior for any suspicious or unusual signs.
At one land border crossing we visited, officers told us that frequent and
legitimate shippers of radiological material provide advance notice that a
radiological shipment will be transported. This can lead to law
enforcement personnel being called in to escort the shipment through the
port-of-entry.
The second potential issue pertains to CBP's secondary inspection
guidelines. Generally, CBP's guidelines require that CBP officers locate,
isolate, and identify the radiation source(s) identified during primary
inspections. Customarily, officers use a radiation isotope identification
device to perform an external examination of cargo containers in these
situations. (See fig. 3.) However, the effectiveness of a radiation
isotope identification device is diminished as its distance from the
radioactive source increases, and by the thickness of the metal container
housing the radioactive source. As a result, secondary inspections that
rely solely on external examinations may not always be able to locate,
isolate, and identify an illicit shipment of nuclear material.
Figure 3: CBP Officers Conducting an External Secondary Inspection at a
Seaport
The local procedures at some ports-of-entry we visited go beyond the
requirements established by CBP's guidelines by having CBP officers open
and, if necessary, enter containers when conducting secondary inspections.
(See fig. 4.) For example, at one high-volume seaport we visited, the
local inspection procedures require officers to open and, if necessary,
enter a container to locate and identify a radiological source if an
external examination with an isotope identifier is unable to do so. Under
such circumstances, the port's procedures require the officer to open the
container doors, locate the source, and obtain another reading as close to
the source as possible. By entering the container, an officer may be able
to reduce the isotope identifier's distance from the radioactive source,
and thus obtain a more accurate reading. If the isotope identifier is
unable to detect and identify the source after two readings within the
container, officers must contact LSS for further guidance. Officers at
this seaport have opened containers in the past when the isotope
identifier had been unable to detect naturally occurring radioactive
material, such as granite or ceramic tile, which is low in radioactive
emissions. CBP supervisors at this seaport said that this occurs
infrequently and that it adds a very minimal amount of time to the
inspection process. In addition, at a land border crossing we visited, the
local standard operating procedures instruct CBP officers to conduct a
physical examination on vehicles that alarm for the presence of radiation.
Officials at this particular port-of-entry said that they have entered
vehicles with an isotope identifier when the device has been unable to
detect or identify the radioactive source from vehicles' exterior. During
a physical examination, officers are supposed to open the vehicle and look
for high-density materials, such as lead or steel, which can be used to
shield gamma radiation and solid objects with large quantities of liquid
that could be used to shield neutron radiation. Because the majority of
alarms at this land border crossing are caused by medical isotopes in
people, CBP officers physically inspect vehicles on an infrequent basis.
Figure 4: A CBP Officer Entering a Cargo Container During a Secondary
Inspection at a Seaport
Finally, we also visited a land border crossing where CBP officers
routinely open and enter commercial trucks to conduct secondary
inspections, even though the site's local procedures do not require this
additional examination. Officials at this crossing said that they open up
containers to verify that the container's manifest and reading from the
isotope identifier are consistent with the container's load. If they are
not consistent, CBP officers are supposed to contact LSS for further
guidance. During our visit, we observed a truck that alarmed at primary
and secondary portal monitors. CBP officers then required the driver to
park at a loading dock, where officers first used an isotope identifier to
screen the truck from the outside; the reading from the isotope identifier
was inconclusive, however. Officers then opened and entered the container
with an isotope identifier, conducted a second reading of the radioactive
source, and determined that the material inside the container was a
non-threatening radioactive source that matched the manifest. A CBP
supervisor released the truck. This inspection, from the time of the
original alarm to the truck's release took about 25 minutes-slightly
greater than the 20-minute average for this site. According to CBP
supervisors, officers at this port-of-entry follow this practice
routinely, even during the site's peak hours. This approach enables the
officers to get closer to the source and obtain a more accurate reading.
Furthermore, since this practice enables officers to conduct a more
thorough examination of the containers' contents, it may increase the
likelihood that CBP officers will find any illicit radioactive material.
According to senior CBP officials at this port-of-entry, despite being
implemented at one of the busiest commercial ports-of-entry in the nation,
this additional procedure has had little negative impact on the flow of
commerce and has not increased the cost of CBP inspections.
DHS Is Working to Improve the Capabilities of Currently-fielded and New
Radiation Detection Equipment, but Much Work Remains to Achieve Better
Equipment Performance
DHS has managed research, development, and testing activities that attempt
to address the inherent limitations of currently-fielded radiation
detection equipment and to produce new, advanced technologies with even
greater detection capabilities. DHS is enhancing its ability to test
detection equipment by building a new test facility at DOE's Nevada Test
Site. In addition, DHS tests radiation detection equipment under real-life
conditions at S&T's CMTB in New York and New Jersey. However, much work
remains for the agency to achieve consistently better detection
capabilities, as the efforts undertaken so far have achieved only mixed
results.
Currently-fielded Radiation Detection Equipment Has Inherent Limitations
Currently-fielded radiation portal monitors have two main limitations.
First, they are limited by the physical properties of the radiation they
are designed to detect, specifically with regard to the range of detection
(some radioactive material emits more radiation than others). Further,
this limitation can be exacerbated because sufficient amounts of
high-density materials, such as lead or steel, can shield radiation
emissions to prevent their detection. Second, currently-fielded portal
monitors cannot distinguish between different types of radioactive
materials, i.e., they cannot differentiate naturally occurring radioactive
material from radiological threat materials. CBP officers are required to
conduct secondary inspections on all portal monitor alarms, including
nuisance alarms. According to the CBP field supervisors with whom we
spoke, nuisance alarms comprise almost all of the radiation alerts at
their ports-of-entry. Port operators noted a concern that nuisance alarms
might become so numerous that commerce could be impeded, but thus far
these alarms have not greatly slowed the flow of commerce through their
ports-of-entry.
CBP's currently-fielded radiation isotope identification devices also have
inherent limitations. For example, during some secondary inspections,
radiation isotope identification devices are unable to identify
radiological material. In these cases, CBP standard procedures require
that officers consult LSS to conclusively identify the source. According
to CBP officers at two of the ports we visited, this usually lengthens
secondary inspections by 20 to 30 minutes, although in some cases an hour
or more was needed to resolve the alarm. Furthermore, a 2003 Los Alamos
National Laboratory evaluation of seven isotope identifiers, including the
one deployed by CBP, concluded that all devices had difficulty recognizing
radioactive material and correctly identifying the material they did
recognize. The Los Alamos finding is consistent with our field
observations, as CBP officers at several of the ports-of-entry we visited
reported similar trouble with their radiation isotope identification
devices.
Laboratory testing of currently-fielded radiation detection equipment has
further demonstrated their limitations in effectively detecting and
identifying nuclear material. For example, in February 2005, DHS sponsored
testing of commercially available portal monitors, isotope identifiers,
and pagers against criteria set out in American National Standards
Institute (ANSI) standards. The ANSI standards provide performance
specifications and test methods for testing radiation detection equipment,
including portal monitors and handheld devices. The actual testing was
performed by four DOE laboratories, with coordination, technical
management, and data evaluation provided by the Department of Commerce's
National Institute for Standards and Technology (NIST). The laboratories
tested a total of 14 portal monitors from 8 manufacturers against 29
performance requirements in the ANSI standards. Overall, none of the
radiation detection equipment, including the portal monitors and handheld
devices deployed by CBP, met all of the performance requirements in this
first round of testing. However, according to S&T officials, many of the
limitations noted in CBP's equipment were related to withstanding
environmental conditions-not radiation detection or isotope
identification. However, in some tests, the portal monitors that CBP
employs, along with many others, exhibited poor results. For example, in
tests conducted to evaluate the portal monitors' response to neutron
radiation, of which plutonium is a primary source, almost all monitors,
including a portal monitor fielded by CBP, failed to meet the ANSI
requirement. However, according to S&T officials, the test was conducted
using the manufacturer's standard configuration, rather than the
configuration CBP uses in its field operations. In another test, one that
used CBP's typical field parameters rather than the manufacturer's, the
portal monitor passed all the radiation detection performance
requirements. S&T believes that the portals used by CBP would meet all the
radiation performance requirements if set up with the parameters and
configuration as used in the field. In addition, isotope identifiers
displayed weaknesses. For example, the isotope identifier currently in use
by CBP was not able to simultaneously identify two different isotopes, as
required by the ANSI standards. When tested with barium-133 and
plutonium-239, the isotope identifier was able to recognize the barium but
failed to recognize the plutonium-a weapons-grade nuclear material. As
this was a first round of testing and modifications were made to both the
standards and testing protocols after the procedures were completed, NIST
plans to manage testing of the equipment again in early 2006. The results
from both rounds of testing are intended to provide guidance for federal,
state, and local officials in evaluating and purchasing radiation
detection equipment, and to enable manufacturers to improve their
equipment's performance.
DHS Has Sponsored Research and Development to Improve the Capabilities of
Current Technology and to Develop New Technology but Much Work Remains
DHS has sponsored research efforts designed to improve the detection
capabilities of the currently-fielded portal monitors and to provide them
with the ability to distinguish radiological sources. For example, PNNL
researched, developed, and tested a new software-known as "energy
windowing"-to address the currently-fielded portal monitors' inability to
distinguish between radiological materials. Energy-windowing is supposed
to identify and screen out material, such as fertilizer or kitty litter,
that cause nuisance alarms and thereby reduce the number of such alarms at
cargo screening facilities, while also improving the portal monitor's
sensitivity to identify nuclear material of concern. PNNL has activated
energy-windowing on the 556 portal monitors it has deployed at land border
crossings and seaports. At a few ports-of-entry that we visited, CBP
officials said that the software has been effective in significantly
reducing the number of nuisance alarms. However, tests of the software
have shown that its effectiveness in reducing nuisance alarms largely
depends on the types of radiation sources it has been programmed to detect
and differentiate. In tests involving some common, unshielded radiation
sources, such as cobalt-57 and barium-153, the new software has shown
improved detection and discrimination capabilities. However, during
scenarios that target other common, shielded threat sources-such as those
that might be used in a shielded radiological dispersal device or nuclear
weapon-the software has been less able to detect and discriminate. Experts
have recommended further testing to fully explore the software's
capabilities.
DHS is also sponsoring the development of three new technologies that are
designed to address the main inherent limitations of currently-fielded
portal monitors. CBP's deployment plan currently calls for the widespread
installation of the first of these technologies, "advanced spectroscopic
portal monitors." According to DNDO, the advanced spectroscopic technology
uses different detection materials that are capable of both detecting the
presence of radiation and identifying the isotope causing the alarm. It is
hoped that the spectroscopic portal monitor can more quickly identify the
sources of alarms, thereby reducing the number of nuisance alarms. This
increased operational effectiveness may allow the portal monitors to be
set at a lower detection threshold, thus allowing for greater sensitivity
to materials of concern. DHS commissioned PNNL to determine whether
spectroscopic portal monitors provide improved performance capabilities
over the currently-fielded monitors. In July 2004 and July 2005, PNNL
conducted two small-scale preliminary studies to compare the two types of
portal monitors in side-by-side tests using shielded and unshielded
radioactive materials. In the first test, PNNL concluded that the relative
performance of spectroscopic and currently-fielded portal monitors is
highly dependent on variables such as the radioactive sources being
targeted and the analytic methods being used. The results of these tests
were mixed. In some situations, spectroscopic portal monitors outperformed
the current technology; in other cases, they performed equally well. In
the second test, PNNL concluded that the spectroscopic monitor's ability
to detect the shielded threat sources was equal to, but no better than,
those of the currently-fielded portal monitors. However, because
spectroscopic portal monitors have the ability to identify isotopes, they
produced fewer nuisance alarms than the current portal monitors. PNNL
noted that because the studies were limited in scope, more testing is
needed.
In October 2005, DNDO completed the first round of comprehensive testing
of spectroscopic portal monitors at its testbed at the Nevada Test Site.
DNDO tested 10 spectroscopic portal monitors against 3 currently-fielded
monitors in 7,000 test runs involving the portal monitors' ability to
detect a variety of radiological materials under many different cargo
configurations. According to senior DNDO officials who supervised these
tests, preliminary analysis of test data indicates that the spectroscopic
portal monitors' performance demonstrated somewhat mixed results.
Spectroscopic portal monitors outperformed currently-fielded equipment in
detecting numerous small, medium-sized, and threat-like radioactive
objects, and were able to identify and dismiss most naturally occurring
radioactive material. However, as the amount of source material declined
in size, the detection capabilities of both types of portal monitors
converged. Because the data produced by the test runs is voluminous and
complex, NIST and another contractor are still in the process of analyzing
the test data and plan to produce a report summarizing the results of the
testing in 2006. DNDO received responses to the Advanced Spectroscopic
Portal Request for Proposal in February 2006, and intends to use the data
from the Nevada Test Site to help evaluate these responses. In fiscal year
2006, DNDO also intends to award contracts to two or three manufacturers
for further engineering development and production.
The second new technology is "high-Z detection," which is designed to
better detect high atomic number (high-Z) materials-such as Special
Nuclear Material (SNM)-and shielding materials-such as lead-that could be
used to shield gamma radiation from portal monitors. The Cargo Advanced
Automated Radiography System (CAARS) program within DNDO is intended to
develop the technologies necessary for automated detection of high-Z
material. DNDO envisions using the advanced portal monitor technology for
the detection of lightly shielded nuclear threats and radiological
dispersal devices, and using CAARS technology for the detection of high-Z
materials.
The third new technology is "active interrogation," which is designed to
better detect nuclear material, especially shielded sources, and DNDO
expects it to play a role further in the future than advanced portal
monitors and CAARS. DHS and DOE are supporting research at DOE national
laboratories, such as Los Alamos and Lawrence Livermore, to develop these
systems. Active interrogation systems probe or "interrogate" containers
with neutron or gamma rays to induce additional radiation emissions from
radioactive material within the container. According to DNDO, these
systems are too large and costly to consider for current use. In addition,
because these systems emit radiation, care will have to be taken to ensure
personnel safety before any deployments are made.
In addition to these relatively near-term research and development
efforts, DNDO intends to solicit proposals from private, public, academic,
and federally funded research centers to pursue radiation detection
projects with a more long-term orientation. The solicitation identifies
five areas of research:
o mobile detection systems that can be used to detect potential
radiological threats that are in transit, at fixed locations, and at
special events;
o detection systems that can be integrated into ships, trucks, planes, or
into containers;
o active detection technologies, including portal monitors and handheld
devices that can detect and verify the presence of shielded nuclear
materials;
o innovative detector materials that provide improved detection and
isotope identification capabilities over existing materials, in addition
to technologies that lead to reductions in the costs to manufacture
detector materials, increasing the size and choice of the shapes of
detector materials without a loss in performance; and
o alternate means to detect and identify nuclear material other than
through radiation detection such as mass, density, or temperature.
DHS Sponsors Test Facilities in Nevada, New York, and New Jersey to
Support Efforts to Improve Detection Capabilities
DHS is testing commercially available portal monitors, advanced portal
monitors, and handheld devices at its new Radiological and Nuclear
Countermeasures Test and Evaluation Complex at the Nevada Test Site (NTS).
DNDO, with assistance from DOE's National Nuclear Security Administration,
began construction of the complex in 2005.21 While construction work is
under way, an Interim Test Track was built nearby. The complex is to
support the DNDO's development, testing, acquisition, and support of the
deployment of radiation detection technologies. When completed, the
complex will be comprised of several operating areas where testing and
evaluation of detection systems will be conducted, such as a testing
facility to evaluate active interrogation technologies; and a large,
instrumented outdoor testing area to test mobile detection systems. The
complex will also have a vehicle choke point where detection systems for
land border crossings, toll plazas, and entrances to tunnels and bridges
can be evaluated. According to DNDO officials, an important advantage of
using NTS is that it provides the necessary facilities to test detection
system capabilities with special nuclear materials in
threat-representative configurations. The complex will be open to other
organizations within DHS, including CBP, S&T, the Transportation Security
Administration, and the U.S. Coast Guard. It will also be open to DOE
national laboratories, universities, and private companies conducting
radiation detection development and production for DHS. The facility is
expected to become fully operational in January 2007.
In addition to the Nevada complex, DHS manages CMTB to test radiation
detection equipment in an operational environment. The CMTB originated as
a DOE funded demonstration project in fiscal year 2003, but transferred to
DHS in August 2003. The scientific, engineering, and technical staff of
the CMTB are drawn predominantly from the national laboratories. The test
bed encompasses various operational settings, such as major seaports,
airports, roadways, and railways. The CMTB deploys commercially available
and advanced radiation detection equipment at these venues to test and
evaluate their performance in real-world situations, to develop better
standard operating procedures, and to assess the impact the equipment has
on the flow of commerce. At present, CMTB is testing portal monitors at
toll crossings of two tunnels and one bridge, two seaport terminals, and
two air cargo facilities. In addition, CMTB is developing several advanced
secondary inspection mobile technologies. (See fig. 5.) The advanced
spectroscopic portal monitors that DNDO is developing will likely be
evaluated at the CMTB, once testing is completed at the Nevada Test Site.
Figure 5: The "SMARTCART," a Mobile Portal Monitor Using Advanced
Detection Technology, Being Tested at the CMTB in New York
The Newly Created Domestic Nuclear Detection Office Is Structured to
Improve Coordination of Executive Branch Radiation Detection Programs
DHS works with DOE, DOD, and other federal, state, and local agencies, as
well as the private sector to carry out radiation detection programs. The
newly established DNDO was set up to serve as DHS's main instrument for
coordinating these efforts. Since its creation in April 2005, DNDO has
entered into working relationships with other agencies and is taking the
lead in developing what it calls a "global architecture," an integrated
approach to detecting and stopping nuclear smuggling. However, because
DNDO was created so recently, these efforts are in their early stages of
development and implementation.
DNDO Attempts to Improve Cooperation Among Other DHS Offices, DOE, DOD,
and Other Agencies in Deploying and Operating Equipment
Historically, cooperation among agencies engaged in domestic radiation
detection has been limited. In April 2005, however, the president signed a
joint presidential directive that directed the establishment of DNDO to,
among other things, improve such cooperation by creating a single
accountable organization with the responsibility for establishing strong
linkages across the federal government and with other entities. As
currently envisioned under the directive, DNDO's mission covers a broad
spectrum of radiological and nuclear protective measures, but focuses
mainly on nuclear detection. The directive includes several provisions
directing DNDO to coordinate its activities with other entities. For
example, DNDO is to work with DOE, DOD, the Departments of State and
Justice, state and local agencies, and the private sector to develop
programs to thwart illicit movements of nuclear materials. In addition,
provisions of the directive require consultation between DNDO, law
enforcement and nonproliferation centers, as well as other related federal
and state agencies. Table 2 provides a summary of the cooperation brought
about by the presidential directive.
Table 2: Cooperation with DNDO Brought about by Presidential Directive
Agency Responsibilities
Department of Homeland
Security
S&T All radiological/nuclear detection programs and
staff subsumed by DNDO.
U.S. Coast Guard (USCG) USCG and DNDO coordinate on detection and
reporting resources, and protocols to ensure that
USCG equipment is state-of-the-art and that
detection events are properly reported.
Office of State & Local DNDO works to ensure good communication,
coordination, and takes other actions with state
Government Coordination and local governments. SLGCP personnel help staff
and Preparedness (SLGCP) DNDO.
Interagency Components
Department of Energy Provide staffing to, and coordinates with, DNDO
in equipping National Incident Response Teams.
DOE also provides DNDO with information from
overseas programs. Makes the NTS and special
nuclear materials available for DNDO testing.
Department of Defense Provide staffing to DNDO. Facilitate coordination
between DOD detection programs and domestic
programs. Coordinate on technical "reachback
capabilities." Integrate any domestic detection
systems in communities near military bases with
DNDO assets.
Department of Justice Provide staffing to DNDO. FBI will coordinate on
establishing and executing "reachback
capabilities." FBI remains the lead law
enforcement agency in terrorist events.
Department of State Provide links and overall coordination between
DNDO and non-U.S. organizations responsible for
radiation detection.
Central Intelligence Primary responsibility for gathering, analyzing,
Agency and disseminating intelligence information
relevant to DNDO operations. The agency will
accept collection requirements through channels
from DNDO.
Nuclear Regulatory Coordinate detection requirements with DNDO. DNDO
Commission shares detection event data with NRC, and NRC
shares information with DNDO on legal shipments
of radiological materials.
Source: DNDO.
According to senior DNDO officials, although the close cooperation called
for in DNDO's mandate has been difficult to achieve, there are two factors
that may help DNDO succeed in this effort. First, the presidential
directive is explicit in directing other federal agencies to support
DNDO's efforts. The directive transfers primary responsibility for
radiation and nuclear detection activities in the United States to DNDO,
and requires DNDO to include personnel from other agencies in its
organization. For example, under the directive, DOE will provide DNDO with
information received from overseas programs, including the Megaports
Initiative and others, as well as information from DOE's international
partners involved with radiological and nuclear detection systems. Second,
all of the radiological and nuclear detection programs and staff of S&T
became part of DNDO.
DOE's Second Line of Defense program supports DNDO efforts by working with
the agency to exchange information, data, and lessons learned from
overseas deployments. According to senior officials at DNDO, the data from
overseas deployments are needed to help DNDO efforts to develop profiles
of potential risks to the United States. In addition, the performance of
these systems, as evidenced by these data, can help improve domestic
portal monitors' ability to detect radiation. In addition, DOE provides
equipment training opportunities for DHS personnel. In April 2005, DOE and
DHS formalized certain aspects of this cooperation in a memorandum of
understanding. Specifically, the areas of cooperation include, among other
things: discussing procedures for the rapid analysis of cargo and for
operational/emergency responses, training CBP officers, exchanging
technical and lessons learned information, and providing updates on their
respective programs' implementation.
DHS has also entered into formal agreements with state and local
governments to coordinate their radiation detection efforts. For example,
in April 2005, just prior to DNDO's creation, DHS and the Port Authority
of New York and New Jersey finalized a memorandum of understanding to
provide services, personnel, and equipment to run the CMTB program.
Specifically, the program is designed to evaluate and assess the role of
threat detection technologies, develop and exercise various concepts of
operation and response tools, integrate lessons learned from field
experiences, and provide detection and monitoring capabilities for testing
and evaluation purposes. The agreement spells out each partner's
responsibilities, including coordination with other agencies. According to
a senior DNDO official, DNDO now has responsibility for this and other
similar agreements under its authority to develop and evaluate new
radiation detection equipment.
Finally, DNDO officials also believe that the way the agency has been
staffed and organized will aid its cooperation efforts. For example, staff
from DHS, DOD, DOE, the Departments of State and Justice, and other
agencies, have been detailed to DNDO. All of DNDO's major organizational
units are staffed with personnel from multiple agencies. For example, the
strategic planning staff within the Office of the Director has employees
from DOE, DOD, CBP, Federal Bureau of Investigation (FBI), and DHS's
Office of State and Local Government Coordination and Preparedness.
Significantly, DNDO's Office of Operations Support, which is designed to
provide real-time situational data as well as technical support to field
units, is headed by an FBI executive with senior staff from CBP, DOE, and
DHS's Transportation Security Administration providing direct management
support. According to a senior DNDO official, having this broad range of
agencies represented in DNDO decision making helps ensure that agencies'
views are heard and fully considered, thereby helping to achieve the
greatest possible consensus even for difficult decisions. Further, agency
personnel detailed to DNDO have the authority to "bind" their respective
agencies, i.e., whatever decisions or agreements are reached under the
auspices of DNDO will bind their agency to comply to the extent permitted
by law. Finally, according to senior officials in DOE and CBP, the current
organizational arrangement appears to be working. Officials noted that
early in DNDO's history, communication was difficult, but has recently
improved. For example, CBP and DOE officials told us they had hoped to
have greater input into DNDO's early efforts to develop integrated
radiation detection systems. However, these officials noted that by
October 2005, DNDO seemed to have heard and acted upon their
recommendations. However, although these officials were optimistic about
future collaborations with DNDO, they also noted that DNDO has not yet
completed a large enough body of work to conclude firmly that its
coordination efforts will always be similarly successful.
DNDO Is Cooperating with Other Agencies to Develop a Global Nuclear
Detection System
Among the main purposes in creating the DNDO, according to its Director,
is to develop a global nuclear detection system that he characterized as a
"global architecture." DNDO's intention in developing such an approach is
to coordinate other agencies' efforts, such as the Second Line of Defense
and Container Security Initiative, with the domestic deployment program to
create an integrated, worldwide system. The resulting "global
architecture" would be a multi-layered defense strategy that includes
programs that attempt to secure nuclear materials and detect their
movements overseas; to develop intelligence information on nuclear
materials' trans-shipments and possible movement to the United States; and
to integrate these elements with domestic efforts undertaken by
governments-federal, state, local, and tribal-and the private sector. Much
of DNDO's work in terms of acquiring and supporting the deployment of
radiation detection equipment, as well as in supporting research,
development, and testing of new detection equipment supports the office's
mission to develop the U.S. domestic portion this global architecture.
In addition, DHS, in conjunction with selected state and local
organizations, as well as other federal agencies and the private sector,
began two pilot projects in fiscal year 2003 to demonstrate a layered
defense system designed to protect the United States against radiological
and nuclear threats. DHS's Radiological Pilot Programs Office coordinated
the projects' initial efforts, and DNDO assumed responsibility in October
2005. Field work began in fiscal year 2004 and will be completed in fiscal
year 2007. The project leaders expect the final report and lessons learned
to be issued in fiscal year 2007. Both pilot projects featured a broad
selection of federal, state, and local agencies, including state law
enforcement, counter-terrorism, emergency management, transportation, and
port authorities.
Conclusions
DHS has made progress deploying radiation detection equipment at U.S.
ports-of-entry; notably, the department achieved these gains without
greatly impeding the flow of commerce (i.e., the movement of cargo
containers out of ports-of-entry). However, we believe that DHS will find
it difficult under current plans and assumptions to meet its current
portal monitor deployment schedule at U.S. borders because it would have
to increase its current rate of deployment by 230 percent to meet its
September 2009 deadline. Our analysis of CBP's and PNNL's earned value
data suggests that millions of dollars worth of work is being deferred
each month and that the work that is completed is costing millions more
than planned. Currently, we estimate that CBP is facing a likely cost
overrun of about $340 million, and that the last portal monitor may not be
installed until late 2014. Unless CBP and PNNL make immediate improvements
in the schedule performance, then additional slippage in the deployment
schedule is likely.
A key overriding cause for these delays is the late disbursal of funds to
DHS contractors. This late dispersal disrupts and delays some ongoing
installation projects. In this regard, DHS approval processes for
documentation requested by the House Appropriations Committee are lengthy
and cumbersome. In one case, for example, funds for fiscal year 2005 were
not made available to the DHS contractor until September 2005, the last
month of the fiscal year. This process is taking too long and needs to be
shortened.
Further, the unsure efficacy and uncertain cost associated with the
advanced portal monitor technology means that DHS cannot determine, with
confidence, how much the program will eventually cost. In particular, even
if the advanced portal monitor technology can be shown superior to current
technology-which currently does not seem certain-DHS does not yet know
whether the new technology will be worth its considerable additional cost.
Only after testing of the advanced portal monitors has been completed and
DHS has rigorously compared currently-fielded and advanced portal
monitors, taking into account their differences in cost, will DHS be able
to answer this question.
CBP has experienced difficulty deploying portal monitors at seaports, at
least in part because it has been unable to reach agreements with many
seaport operators, who are concerned that radiation detection efforts may
delay the flow of commerce through their ports. As a result, the agency
has fallen 2 years behind its seaport deployment schedule-and seaports
continue to be vulnerable to nuclear smuggling. Significantly, there is no
clear solution and no reason to be optimistic that progress can be made
soon. CBP's policy of negotiating deployment agreements with seaport
terminal operators has not yet yielded agreements at many seaports and
this has caused significant delays in the deployment of portal monitors at
some seaports. CBP has chosen not to attempt to force terminal operators
to cooperate. A subset of this issue concerns screening rail traffic
leaving seaports, which is a particularly difficult problem. The
operational concerns of performing secondary rail inspections in seaports
are daunting. Some port operators as well as a national study strongly
suggest that rail transport will increase over the next 10 years. However,
unless an effective and efficient means to screen rail traffic is
developed and deployed, seaports will likely continue to either avoid
installing detection equipment altogether, or simply turn it off when its
operation might prove to be inconvenient. Without more progress on this
front, we risk rail cargo becoming a burgeoning gap in our defenses
against nuclear terrorism.
CBP appears to have made progress in using radiation detection equipment
correctly and adhering to inspection procedures. At several ports-of-entry
we visited, CBP officers physically opened and inspected cargo containers
to confirm the nature of the radiological source under certain
circumstances. They did this when they were unable to confirm the type of
radiological material through current approved procedures. Since the
currently deployed handheld equipment is limited in its ability to
accurately identify sources of radiation, opening the container allows CBP
officers to get closer to the source of the alarm and thereby improve
their chances of accurately identifying the source. It also enables
officers to verify that the container's contents are consistent with the
isotope identifier's initial reading and the container's manifest.
Furthermore, since DHS and DOE officials have expressed concerns that
illicit radiological material could be shielded, this practice enables
officers to conduct a more thorough examination of the containers'
contents-thereby increasing the likelihood that CBP officers will find any
illicit radioactive material. Importantly, this process, according to
border security officials, did not impede the progress of commerce through
any port-of-entry.
On the other hand, because CBP officers do not have access to NRC
licensing data, it is difficult for them to verify that shippers have
obtained necessary NRC licenses and to verify the authenticity of any NRC
licenses that may accompany shipments of radioactive materials. As a
result, unless nuclear smugglers in possession of faked license documents
raised suspicions in some other way, CBP officers could follow agency
guidelines yet unwittingly allow them to enter the country with their
illegal nuclear cargo. As we see it, this is a significant gap in CBP's
national procedures that should be closed.
Recommendations for Executive Action
Since DHS provides the Congress with information concerning the
acquisition and deployment of portal monitors, and since DHS's procedures
to obtain internal agreement on this information are lengthy and
cumbersome-often resulting in delays-we recommend that the Secretary of
Homeland Security, working with the Director of DNDO and the Commissioner
of CBP, review these approval procedures and take actions necessary to
ensure that DHS submits information to the Congress early in the fiscal
year.
In order to complete the radiation portal monitor deployment program, as
planned, we recommend that the Secretary of Homeland Security, working
with the Director of DNDO, and in concert with CBP and PNNL, devise a plan
to close the gap between the current deployment rate and the rate needed
to complete deployments by September 2009.
To ensure that DHS's substantial investment in radiation detection
technology yields the greatest possible level of detection capability at
the lowest possible cost, we recommend that once the costs and
capabilities of advanced technology portal monitors are well understood,
and before any of the new equipment is purchased, the Secretary of
Homeland Security work with the Director of DNDO to analyze the benefits
and costs of deploying advanced portal monitors. This analysis should
focus on determining whether any additional detection capability provided
by the advanced equipment is worth its additional cost. After completing
this cost-benefit analysis, the Secretary of Homeland Security, working
with the Director of DNDO, should revise its total program cost estimates
to reflect current decisions.
To help speed seaport deployments and to help ensure that future rail
deployments proceed on time, we recommend that the Secretary of Homeland
Security, in cooperation with the Commissioner of CBP, develop procedures
for effectively screening rail containers and develop new technologies to
facilitate inspections.
To increase the chances that CBP officers find illicit radiological
material, we recommend that the Secretary of Homeland Security, working
with the Commissioner of CBP, consider modifying the agency's standard
operating procedures for secondary inspections to include physically
opening cargo containers during secondary inspections at all
ports-of-entry when the external inspection does not conclusively identify
the radiological material inside.
To further increase the chances that CBP officers identify illicit
radiological material, we recommend that the Secretary of Homeland
Security, working with the Chairman of NRC, develop a way for CBP border
officers to determine whether radiological shipments have the necessary
NRC licenses and to verify the authenticity of NRC licenses that accompany
such shipments.
To ensure that CBP is receiving reliable cost and schedule data, we
recommend that the Secretary of Homeland Security direct PNNL to have its
earned value management system validated so that it complies with guidance
developed by the American National Standards Institute/ Electronic
Industries Alliance. In addition, we recommend the Secretary of Homeland
Security direct CBP and PNNL to conduct an Integrated Baseline Review to
ensure its earned value management data is reliable for assessing risk and
developing alternatives.
Agency Comments and Our Evaluation
We provided a draft of this report to DHS for comment. In response, we
received written comments from DHS officials. DHS noted that the report is
factually correct. Further, the Department agreed with our recommendations
and committed to implementing them. DHS officials also commented that our
review did not completely capture the enormity or complexity of the
Radiation Portal Monitor program. We agree that this program is a massive
undertaking, and our original draft reflected this perspective in several
places. In commenting on our recommendation to develop a better means for
CBP border officers to verify NRC license information, DHS stated that
"NRC licenses are required to accompany certain legitimate shipments of
radiological materials..." However, according to senior NRC officials, no
requirement that the license accompany the shipment exists. Finally, DHS
provided some clarifying comments that we incorporated into this report,
as appropriate.
As agreed with your offices, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from
the report date. At that time, we will send copies to the congressional
committees with jurisdiction over DHS and its activities; the Secretary of
Homeland Security; the Director of OMB; and interested congressional
committees. We will also make copies of the report available to others
upon request. This report will also be available at no charge on GAO's
home page at h ttp://www.gao.gov.
If you or your staff have any questions about this report, please contact
me at (202) 512-3841. Contact points for our Offices of Congressional
Relations
and Public Affairs may be found on the last page of this report. GAO staff
who made major contributions to this report are listed in appendix IV.
Gene Aloise Director, Natural Resources and Environment
List of Requesters
The Honorable Norm Coleman Chairman Permanent Subcommittee on
Investigations Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Susan M. Collins Chairman Committee on Homeland Security and
Governmental Affairs United States Senate
The Honorable Carl Levin Ranking Minority Member Permanent Subcommittee on
Investigations Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable John D. Dingell Ranking Minority Member Committee on Energy
and Commerce House of Representatives
Scope and Methodology Appendix I
To assess the Department of Homeland Security's (DHS) progress in
deploying radiation detection equipment, including radiation portal
monitors, radiation isotope identification devices, and pagers at U.S.
ports-of-entry and any problems associated with that deployment, we
reviewed documents and interviewed officials from the U.S. Customs and
Border Protection (CBP), Domestic Nuclear Detection Office (DNDO), and
Pacific Northwest National Laboratory (PNNL). We focused primarily on the
issues surrounding radiation portal monitors because they are a major tool
in the federal government's efforts to thwart nuclear smuggling, and
because the budget and other resources devoted to these machines far
exceeds the handheld equipment also used at U.S. ports-of-entry. Further,
we focused on the use of radiation detection equipment in primary and
secondary inspections, but we did not examine their use as a part of CBP's
targeted inspections. To assess CBP's current progress in deploying portal
monitors, we compared PNNL's December 2004 project execution plan for
deploying radiation portal monitors-including the project's schedule and
estimated cost. We analyzed budget, cost, and deployment data on portal
monitors to determine differences between PNNL's plan and its current
progress. We also assessed PNNL's cost and schedule performance using
earned value analysis techniques based on data captured in PNNL's contract
performance reports. We also developed a forecast of future cost growth.
We based the lower end of our forecast range on the sum of costs spent to
date and the forecast cost of work remaining. The remaining work was
forecast using an average of the current cost performance index efficiency
factor. For the upper end of our cost range, we relied on the actual costs
spent to date added to the forecast of remaining work with an average
monthly cost and schedule performance index.
We also visited a nonprobability sample of CBP ports-of-entry, including
two international mail and express courier facilities, five seaports, and
three land border crossings.1 We selected these ports-of-entry by using
criteria such as the types of ports-of-entry where CBP plans to deploy
equipment; ports-of-entry with wide geographic coverage; and
ports-of-entry where portal monitors have been-or are planned to
be-installed. During each visit, we spoke with CBP inspectors and local
port authority officials on the progress made, and any problems
experienced in deploying the equipment at their locations.
To assess CBP officers' use of radiation detection equipment, and how
inspection procedures are implemented at U.S. ports-of-entry, and any
problems associated with the use of the equipment, we reviewed CBP's
standard operating procedures for radiation detection; documents on its
training curriculum; and training materials on how to use the equipment.
We participated in a 3-day hands-on training course for CBP officers at
PNNL on how to use radiation detection equipment. We also interviewed
officials from CBP field and headquarters to discuss problems associated
with the use of the equipment. During our site visits, we toured the
facilities, observed the equipment in use, and interviewed CBP officers
about radiation detection policies and procedures and the deployment of
equipment at their locations. We discussed with CBP officers how they
determine the validity of Nuclear Regulatory Commission (NRC) licenses
when legitimate shipments of radioactive material enter the nation.
To assess DHS's progress in improving and testing radiation detection
equipment capabilities, we reviewed documents and interviewed officials
from CBP, DNDO, Science and Technology Directorate (S&T), DOE, PNNL, and
the National Institute for Standards and Technology (NIST). We reviewed
S&T's April 2005 Program Execution Plan; DHS documentation on the
development of advanced radiation detection technologies; and test results
and assessments of the performance of both commercially available
radiation detection equipment and advanced technologies. We visited four
national laboratories-Lawrence Livermore, Los Alamos, Pacific Northwest,
and Sandia-that are involved in the research, development, and testing of
radiation detection technologies. In addition, we visited the Counter
Measures Test Bed (CMTB) in New York and New Jersey, the Nevada Test Site,
and the Department of Defense's (DOD) test site at a U.S. Air Force base
to observe the testing of radiation detection equipment and discuss
progress in improving and testing radiation detection equipment with
onsite experts.
To assess the level of cooperation between DHS and other federal agencies
in conducting radiation detection programs, we interviewed officials from
CBP; S&T; the Transportation Security Administration; DOD's Defense Threat
Reduction Agency; DOE's National Nuclear Security Administration; and
Lawrence Livermore, Los Alamos, Pacific Northwest, and Sandia National
Laboratories. We discussed the current extent of coordination and whether
more coordination could result in improvements to DHS's deployment,
development, and testing of radiation detection equipment and
technologies. We reviewed agency agreements to cooperate, including a
memorandum of understanding between DHS and DOE to exchange information on
radiation detection technologies and deployments, and a memorandum of
understanding between DHS and the Port Authority of New York and New
Jersey to integrate lessons learned into domestic radiation detection
efforts. In addition, we reviewed an organizational chart from DNDO as
well as our past reports on coordination between federal agencies on
deployment and testing.
We received training data from CBP, cost and budget data from CBP, and
deployment data from CBP and PNNL. We obtained responses from key database
officials to a number of questions focused on data reliability covering
issues such as data entry access, internal control procedures, and the
accuracy and completeness of the data. We determined these data were
sufficiently reliable for the purposes of this report.
We conducted our review from March 2005 to February 2006 in accordance
with generally accepted government auditing standards.
GAO Contact and Staff knowledgments Appendix II
Gene Aloise, (202) 512-3841
In addition to the contact named above, Jim Shafer; Nancy Crothers; Emily
Gupta; Brandon Haller; Richard Hung; Winston Le; Greg Marchand; Judy
Pagano; Karen Richey; Keith Rhodes, GAO's Chief Technologist; and Eugene
Wisnoski made key contributions to this report.
Related GAO Products
Combating Nuclear Smuggling: Corruption, Maintenance, and Coordination
Problems Challenge U.S. Efforts to Provide Radiation Detection Equipment
to Other Countries. GAO-06-311 . Washington, D.C.: March 14, 2006.
Combating Nuclear Smuggling: Efforts to Deploy Radiation Detection
Equipment in the United States and in Other Countries. GAO-05-840T .
Washington, D.C.: June 21, 2005.
Homeland Security: Key Cargo Security Programs Can Be Improved.
GAO-05-466T . Washington, D.C.: May 25, 2005.
Container Security: A Flexible Staffing Model and Minimum Equipment
Requirements Would Improve Overseas Targeting and Inspection Efforts.
GAO-05-557 . Washington, D.C.: April 26, 2005.
Preventing Nuclear Smuggling: DOE Has Made Limited Progress in Installing
Radiation Detection Equipment at Highest Priority Foreign Seaports.
GAO-05-375 . Washington, D.C.: March 31, 2005.
Customs Service: Acquisition and Deployment of Radiation Detection
Equipment. GAO-03-235T . Washington, D.C.: October 17, 2002.
Nuclear Nonproliferation: U.S. Efforts to Help Other Countries Combat
Nuclear Smuggling Need Strengthened Coordination and Planning. GAO-02-426
. Washington, D.C.: May 16, 2002.
(360558)
www.gao.gov/cgi-bin/getrpt? GAO-06-389 .
To view the full product, including the scope
and methodology, click on the link above.
For more information, contact Gene Aloise, (202) 512-3841.
Highlights of GAO-06-389 , a report to congressional requesters
March 2006
COMBATING NUCLEAR SMUGGLING
DHS Has Made Progress Deploying Radiation Detection Equipment at U.S.
Ports-of-Entry, but Concerns Remain
Preventing radioactive material from being smuggled into the United States
is a key national security objective. To help address this threat, in
October 2002, DHS began deploying radiation detection equipment at U.S.
ports-of-entry. This report reviews recent progress DHS has made (1)
deploying radiation detection equipment, (2) using radiation detection
equipment, (3) improving the capabilities and testing of this equipment,
and (4) increasing cooperation between DHS and other federal agencies in
conducting radiation detection programs.
What GAO Recommends
The Secretary of Homeland Security should work with other agencies, as
necessary, to (1) streamline internal review procedures so that spending
data can be provided to the Congress in a more timely way; (2) update the
current deployment plan; (3) analyze the benefits and costs of advanced
portals, then revise the program's cost estimates to reflect current
decisions; (4) develop ways to effectively screen rail containers; (5)
revise agency procedures for container inspection; and (6) develop a way
for CBP officers to verify NRC licenses.
In commenting on a draft of this report, DHS stated that it agreed with,
and will implement, our recommendations.
The Department of Homeland Security (DHS) has made progress in deploying
radiation detection equipment at U.S. ports-of-entry, but the agency's
program goals are unrealistic and the program cost estimate is uncertain.
As of December 2005, DHS had deployed 670 portal monitors and over 19,000
pieces of handheld radiation detection equipment. However, the deployment
of portal monitors has fallen behind schedule, making DHS's goal of
deploying 3,034 by September 2009 unlikely. In particular, two factors
have contributed to the schedule delay. First, DHS provides the Congress
with information on portal monitor acquisitions and deployments before
releasing any funds. However, DHS's lengthy review process has caused
delays in providing such information to the Congress. Second, difficult
negotiations with seaport operators about placement of portal monitors and
how to most efficiently screen rail cars have delayed deployments at
seaports. Regarding the uncertainty of the program's cost estimate, DHS
would like to deploy advanced technology portals that will likely cost
significantly more than the currently deployed portals, but tests have not
yet shown that these portals are demonstrably more effective than the
current portals. Consequently, it is not clear that the benefits of the
new portals would be worth any increased cost to the program. Also, our
analysis of the program's costs indicates that DHS may incur a $342
million cost overrun.
DHS has improved in using detection equipment and in following the
agency's inspection procedures since 2003, but we identified two potential
issues in Customs and Border Protection (CBP) inspection procedures.
First, although radiological materials being transported into the United
States are generally required to have a Nuclear Regulatory Commission
(NRC) license, regulations do not require that the license accompany the
shipment. Further, CBP officers do not have access to data that could be
used to verify that shippers have acquired the necessary documentation.
Second, CBP inspection procedures do not require officers to open
containers and inspect them, although under some circumstances, doing so
could improve security. In addition, DHS has sponsored research,
development, and testing activities to address the inherent limitations of
currently fielded equipment. However, much work remains to achieve
consistently better detection capabilities.
DHS seems to have made progress in coordinating with other agencies to
conduct radiation detection programs; however, because the DHS office
created to achieve the coordination is less than 1 year old, its working
relationships with other agencies are in their early stages of development
and implementation. In the future, this office plans to develop a "global
architecture" to integrate several agencies' radiation detection efforts,
including several international programs.
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