Nuclear Security: NRC and DHS Need to Take Additional Steps to	 
Better Track and Detect Radioactive Materials (19-JUN-08,	 
GAO-08-598).							 
                                                                 
Concerns have grown that terrorists could use radioactive	 
materials and sealed sources (materials sealed in a capsule) to  
build a "dirty bomb"-- a device using conventional explosives to 
disperse radioactive material. In 2003, GAO found weaknesses in  
the Nuclear Regulatory Commission's (NRC) radioactive materials  
licensing process and made recommendations for improvement. For  
this report, GAO assesses (1) the progress NRC has made in	 
implementing the 2003 recommendations, (2) other steps NRC has	 
taken to improve its ability to track radioactive materials, (3) 
Customs and Border Protection's (CBP) ability to detect 	 
radioactive materials at land ports of entry, and (4) CBP's	 
ability to verify that such materials are appropriately licensed 
prior to entering the United States. To perform this work, GAO	 
assessed documents and interviewed NRC and CBP officials in	 
headquarters and in several field locations.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-08-598 					        
    ACCNO:   A82440						        
  TITLE:     Nuclear Security: NRC and DHS Need to Take Additional    
Steps to Better Track and Detect Radioactive Materials		 
     DATE:   06/19/2008 
  SUBJECT:   Border security					 
	     Data collection					 
	     Dirty bombs					 
	     Equipment management				 
	     Equipment upgrades 				 
	     Federal regulations				 
	     Foreign license agreements 			 
	     Homeland security					 
	     Independent regulatory commissions 		 
	     Information management				 
	     Information systems				 
	     Inspection 					 
	     Internal controls					 
	     License agreements 				 
	     Licenses						 
	     Mission critical information			 
	     Nuclear materials					 
	     Nuclear radiation monitoring			 
	     Port security					 
	     Radiation monitoring				 
	     Radioactive materials				 
	     Radiological warfare				 
	     Risk management					 
	     Schedule slippages 				 
	     Security assessments				 
	     Security regulations				 
	     Terrorism						 
	     Terrorists 					 

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GAO-08-598

   

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Report to the Permanent Subcommittee on Investigations, Committee on 
Homeland Security and Governmental Affairs, U.S. Senate: 

United States Government Accountability Office: 
GAO: 

June 2008: 

Nuclear Security: 

NRC and DHS Need to Take Additional Steps to Better Track and Detect 
Radioactive Materials: 

GAO-08-598: 

GAO Highlights: 

Highlights of GAO-08-598, a report to the Permanent Subcommittee on 
Investigations, Committee on Homeland Security and Governmental 
Affairs, U.S. Senate. 

Why GAO Did This Study: 

Concerns have grown that terrorists could use radioactive materials and 
sealed sources (materials sealed in a capsule) to build a ï¿½dirty bombï¿½ï¿½ 
a device using conventional explosives to disperse radioactive 
material. In 2003, GAO found weaknesses in the Nuclear Regulatory 
Commissionï¿½s (NRC) radioactive materials licensing process and made 
recommendations for improvement. For this report, GAO assesses (1) the 
progress NRC has made in implementing the 2003 recommendations, (2) 
other steps NRC has taken to improve its ability to track radioactive 
materials, (3) Customs and Border Protectionï¿½s (CBP) ability to detect 
radioactive materials at land ports of entry, and (4) CBPï¿½s ability to 
verify that such materials are appropriately licensed prior to entering 
the United States. To perform this work, GAO assessed documents and 
interviewed NRC and CBP officials in headquarters and in several field 
locations. 

What GAO Found: 

NRC has implemented three of the six recommendations in GAOï¿½s 2003 
report on the security of radioactive sources. It has worked with the 
35 states to which it ceded primary authority to regulate radioactive 
materials and sources and others to (1) identify sealed sources of 
greatest concern, (2) enhance requirements to secure radioactive 
sources, and (3) ensure security requirements are implemented. In 
contrast, NRC has made limited progress toward implementing 
recommendations to (1) modify its process for issuing licenses to 
ensure that radioactive materials cannot be purchased by those with no 
legitimate need for them, (2) determine how to effectively mitigate the 
potential psychological effects of malicious use of such materials, and 
(3) examine whether certain radioactive sources should be subject to 
more stringent regulations. Beyond acting on GAOï¿½s recommendations, NRC 
has also taken four steps to improve its ability to monitor and track 
radioactive materials. First, NRC created an interim national database 
to monitor the licensed sealed sources containing materials that pose 
the greatest risk of being used in a dirty bomb. Second, NRC is 
developing a National Source Tracking System to replace the interim 
database and provide more comprehensive, frequently updated information 
on potentially dangerous sources. However, this system has been delayed 
by 18 months and is not expected to be fully operational until January 
2009. Third, NRC is also developing a Web-based licensing system that 
will include more comprehensive information on all sources and 
materials that require NRC or state approval to possess. Finally, NRC 
is developing a license verification system that will draw information 
from the other new systems to enable officials and vendors to verify 
that those seeking to bring these radioactive materials into the 
country or purchase them are licensed to do so. However, these systems 
are more than 3 years behind schedule and may not include the licensing 
information, initially at least, on radioactive materials regulated by 
agreement statesï¿½which represent over 80 percent of all U.S. licenses 
for such materials. The delays in the deployment and full development 
of these systems are especially consequential because NRC has 
identified their deployment as key to improving the control and 
accountability of radioactive materials. 

While CBP has a comprehensive system in place to detect radioactive 
materials entering the United States at land borders, some equipment 
that is used to protect CBP officers is in short supply. Specifically, 
vehicles, cargo, and people entering the United States at most ports of 
entry along the Canadian and Mexican borders are scanned for 
radioactive materials with radiation detection equipment capable of 
detecting very small amounts of radiation. However we found that 
personal radiation detectors are not available to all officers who need 
them. Moreover, while CBP has systems in place to verify the legitimacy 
of radioactive materials licenses, it has not effectively communicated 
to officers at the borders when they must contact officials to verify 
the license for a given sealed source. Consequently, some CPB officers 
are not following current guidance, and some potentially dangerous 
radioactive materials have entered the country without license 
verification. 

What GAO Recommends: 

GAO recommends NRC take steps to ensure that the current target dates 
for launching new systems are not further postponed. GAO recommends CBP 
more effectively communicate guidance on when officers must verify the 
legitimacy of radioactive materials and take steps to ensure that this 
guidance is being followed. NRC neither agreed nor disagreed with GAOï¿½s 
findings and recommendations but described its efforts to implement 
GAOï¿½s 2003 recommendations and its plans to implement GAOï¿½s 2008 
recommendations. CBP agreed with GAOï¿½s recommendations. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-598]. For more 
information, contact Gene Aloise at (202) 512-3841 or [email protected]. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

NRC Has Implemented Three of the Six Recommendations from GAO's 2003 
Report: 

NRC Has Improved Its Ability to Monitor and Track Radioactive Sealed 
Sources, but New Systems Have Been Delayed: 

CBP Has a Comprehensive System for Detecting Radiation at Ports of 
Entry on the Northern and Southern Borders: 

CBP Guidance on When to Verify Licenses for Radioactive Materials 
Entering the United States Was Not Communicated to the Field: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Potential Effects of a Radiological Dispersal Device with 
Category 1, 2, and 3 Quantities of Radioactive Material: 

Appendix II: Comments from the Nuclear Regulatory Commission: 

Appendix III: Comments from the Department of Homeland Security: 

Appendix IV: Comments from the Organization of Agreement States: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: 16 Radionuclides of Concern: 

Table 2: Increased Controls on Category 2 or Greater Quantities of the 
16 Radionuclides of Concern: 

Table 3: Potential Contamination from an RDD: 

Figures: 

Figure 1: Cesium-137 Sources at a Hospital Used for Cancer Treatment 
Are Kept in a Secure Room with Limited Access: 

Figure 2: Passenger Vehicles at a Port of Entry on the Southern Border: 

Figure 3: Trucks Passing through Portal Monitors on the Northern 
Border: 

Figure 4: Truck-Sized Portal Monitor in the Inspection Area at a Port 
of Entry on the Southern Border: 

Abbreviations: 

CBP: Customs and Border Patrol: 

DHS: Department of Homeland Security: 

EPA: Environmental Protection Agency: 

IAEA: International Atomic Energy Agency: 

IND: improvised nuclear devices: 

NRC: Nuclear Regulatory Commission: 

NSTS: National Source Tracking System: 

PAG: Protective Action Guides: 

RIID: radiation isotope identification device: 

RDD: radiological dispersal device: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

June 19, 2008: 

The Honorable Carl Levin: 
Chairman: 
The Honorable Norm Coleman: 
Ranking Member: 
Permanent Subcommittee on Investigations: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

Radioactive sealed sources, which are commonly used throughout the 
world for a variety of purposes, are radioactive materials sealed in a 
capsule or permanently bonded in a solid form. These sealed sources are 
used in medicine and in the oil and gas, electric power, construction, 
and food industries. For example, devices containing radioactive sealed 
sources are used to diagnose and treat millions of patients each year, 
sterilize items such as medical instruments and food, and detect flaws 
in the metal welds in pipelines. Currently, about 2 million sealed 
sources are licensed for use in the United States. Since terrorists 
attacked the United States in 2001, concerns have grown that they could 
obtain and use sealed sources to build a "dirty bomb"--a type of 
radiological dispersal device (RDD) that uses conventional explosives 
to disperse radioactive material. 

The consequences of detonating an RDD depend on the amount and type of 
radioactive material used and the size and characteristics of the area 
in which the material is dispersed. In many scenarios, an RDD would 
cause few deaths or injuries, but significant economic effects could 
result. In particular, the affected area would need to be 
decontaminated and people who work or live in the affected area might 
not return to their homes or businesses for an extended period of time 
because they fear the consequences. Generally, the smaller or more 
confined the area in which a given amount of radioactive material is 
dispersed, the more severe the consequences. Accordingly, depending 
upon the circumstances, even small amounts of material can be 
potentially dangerous. For example, a relatively small quantity of a 
particular material dispersed over many city blocks could be disruptive 
and result in an evacuation while first responders assessed the extent 
of the contamination and determined the need for a cleanup. In this 
case, the small quantity of this material might not cause immediate 
health effects or require significant cleanup, but it could result in 
economic and psychological consequences if people were temporarily 
evacuated from their businesses and homes. However, the same small 
quantity of the same material dispersed in a more confined setting, 
such as a restaurant or enclosed subway station, would also result in 
an evacuation and would prevent people from returning to the affected 
area until a more extensive cleanup could be completed. Moreover, those 
exposed to radiation under this scenario could experience radiation 
sickness, with symptoms that include nausea, vomiting, and diarrhea. If 
exposure is extended, the result can be permanent injury or death. 
Finally, larger amounts of this same radioactive material spread over a 
larger area could produce more significant consequences. (For further 
discussion of the potential effects of an RDD, see app. I.) 

Until 2001, oversight of radioactive sealed sources in the United 
States largely focused on ensuring that such sources were licensed as 
required and used and stored safely. In the years after 2001, security 
concerns surrounding radioactive sealed sources received greater 
attention nationally and internationally. For example, in May 2003, the 
Nuclear Regulatory Commission (NRC) and the Department of Energy (DOE), 
relying in part on a 2002 study by Sandia National Laboratories 
[Footnote 1] that, among other things, identified several 
radionuclides--the particular types of radioactive material used in 
sealed sources--that are most commonly used in the United States and 
that pose the greatest risk of being used by terrorists to make an RDD. 
[Footnote 2] Also that year, the International Atomic Energy Agency 
(IAEA) published a system for ranking quantities of individual 
radionuclides into one of five categories on the basis of their 
potential to harm human health.[Footnote 3] Under IAEA's system, a 
given radionuclide is considered "dangerous" when gathered in close 
proximity to people in sufficient quantity to cause direct human health 
effects.[Footnote 4] A category 1 quantity of a given radionuclide, the 
most dangerous, is defined as an amount 1,000 times or more than the 
amount necessary to cause permanent human injury; a category 2 quantity 
is defined as an amount at least 10 times but less than 1,000 times the 
amount necessary to cause permanent human injury. A category 3 quantity 
of a given radionuclide is defined as at least the minimum amount, but 
less than 10 times the amount, sufficient to cause permanent injury. 
Category 4 and 5 quantities of radioactive materials are unlikely to 
cause permanent injury. In September 2003, the United States and other 
nations endorsed IAEA's Code of Conduct, which sets forth basic 
principles and guidance to promote the safe and secure use of sealed 
sources containing sufficient quantities of radioactive material to be 
categorized as dangerous. The Code of Conduct applies to categories 1, 
2, and 3--all of which are potentially dangerous to human health and 
could, if not properly controlled, cause permanent injuries or death to 
a person who handled it or who was otherwise in contact with it. 

How dangerous any given type of radioactive material is depends on its 
activity level, or intensity; how long exposure lasts; and the way in 
which the body is exposed to it--via inhalation, ingestion, or external 
exposure. The different types of radiation--including alpha, beta, 
gamma, and neutron--also vary in how easy or difficult they are to 
block, or shield, and this variation, in turn, affects the threat to 
health that a particular type of radiation poses. Depending on the 
intensity and length and manner of exposure, health effects range from 
death, to severe injury, to the development of cancer, to no 
discernable damage. For example, alpha radiation poses little threat to 
human health from external exposure but poses considerable health risks 
if inhaled or ingested. Gamma radiation is more penetrating and, if not 
properly shielded, can cause injury or death through external exposure. 
Although sources of neutron radiation are less common, neutron 
radiation is emitted from some materials that are used to make nuclear 
weapons. Thus, tools that can detect neutron radiation are particularly 
important for national security purposes, such as securing our borders. 

An underlying goal of federal and state regulation of radioactive 
materials is to protect people from health effects caused by exposure 
to harmful levels of radiation. The Atomic Energy Act gives NRC primary 
responsibility for regulating most domestic industrial, medical, and 
research uses of radioactive materials to protect public health and 
safety. The act authorizes NRC to relinquish primary regulatory 
authority over radioactive materials to states (called "agreement" 
states) that agree to meet certain conditions. To date, NRC has 
relinquished authority to 35 states to grant licenses to possess and 
use radioactive materials and sealed sources and conduct regular 
inspections of licensees to enforce compliance. NRC and numerous state 
governments license, monitor, track, and require security for 
radioactive materials in order to protect both workers and members of 
the general public from exposure to hazardous levels of radiation 
generated by the activities of their licensees. Given this mandate to 
regulate the radioactive material covered by their licenses, NRC and 
state regulators focus on the dangers posed by day-to-day occupational 
exposure to radiation and the direct health effects from industrial 
accidents. NRC periodically evaluates its own regulatory program and 
evaluates each agreement state's program for compatibility with NRC 
regulations. 

NRC and agreement states issue two types of licenses to authorize the 
possession of radioactive materials: specific licenses and general 
licenses. Specific licenses are issued for devices that contain 
relatively larger radioactive sealed sources. These devices, such as 
medical equipment used to treat cancer, cameras used for industrial 
radiography, and moisture and density gauges used in construction, 
generally require training to be used safely and may also need to be 
properly secured to avoid misuse. Organizations or individuals wanting 
to obtain a specific license must submit an application and gain the 
approval of either NRC or an agreement state. In contrast, devices 
approved for use under general license, such as luminous exit signs, 
normally contain relatively small radioactive sources. Such devices are 
designed with inherent radiation safety features, are widely 
commercially available, and do not require NRC or agreement state 
approval to possess. Of the approximately 22,000 specific materials 
licenses in the United States, NRC administers about 3,750, and the 
agreement states administer the rest. 

Other federal agencies' responsibilities related to regulation of 
radioactive materials are focused on protecting the general public from 
exposure to harmful levels of radiation (the Environmental Protection 
Agency), establishing emergency response procedures (the Department of 
Homeland Security), or preventing the illicit import of such materials 
(Customs and Border Protection, a component of the Department of 
Homeland Security). For example, the Environmental Protection Agency 
(EPA) is responsible for developing and implementing standards for 
protecting the general public from, among other things, radiation from 
contaminated air, water, and soil--whether this contamination is the by-
product of industrial activities or occurred as a result of an 
accidental or deliberate release of radioactive materials. EPA sets 
cleanup standards for areas contaminated by radiation that consider the 
direct health effects and the risks posed by very long-term exposure to 
even very low levels of radiation, which has the potential to increase 
the risk of developing cancer in the future. EPA is also responsible 
for establishing a comprehensive set of guidelines for use by local, 
state, and federal emergency services personnel and other first 
responders in the event of a release of radioactive material--such as 
that caused by an industrial accident or an RDD. The Department of 
Homeland Security (DHS) incorporates the radiation exposure thresholds, 
established primarily by EPA, into their guidance document, Application 
of Protective Action Guides for Radiological Dispersal Device and 
Improvised Nuclear Device Incidents. EPA's more general guidelines 
identify steps that should be taken to respond to and mitigate the 
effects of various types of radiological incidents--whether they are 
industrial accidents or terrorist attacks. Finally, DHS's Customs and 
Border Protection[Footnote 5] (CBP) is responsible for preventing the 
smuggling of radioactive materials into the United States. 

In August 2003, we reported that (1) the number of radioactive sealed 
sources in the United States was unknown because NRC and agreement 
states tracked licenses, which can be issued for more than one source, 
rather than individual sealed sources; (2) despite concerns about the 
need for heightened security of radioactive sources, NRC had only 
recently issued requirements to improve the security of a relatively 
small number of the very largest sealed sources, used for irradiating 
food or medical supplies, leaving many others without increased 
security; and (3) there were potential security weaknesses in NRC and 
agreement state licensing processes. We made several recommendations to 
correct these problems, including that NRC (1) collaborate with 
agreement states to identify the types, amount, and availability of the 
highest-risk radioactive sources and the associated health and economic 
consequences of their malicious use; (2) re-examine its licensing 
procedures and requirements; and (3) work with states to devise and 
implement additional security measures, including performance measures 
to make sure any new measures are effective.[Footnote 6] In addition, 
we reported in March 2006 that, among other things, CBP did not have 
access to NRC or agreement state licensing data, making it difficult 
for officers at U.S. ports of entry to verify the legitimacy of 
shipments of radioactive sealed sources or materials.[Footnote 7] 
Accordingly, we recommended that CBP and NRC develop a capacity to 
provide CBP border personnel with information needed to help determine 
if radioactive sealed source shipments are legitimate, including NRC 
licensing data. We also conducted two undercover operations to test 
CBP's and NRC's ability to prevent those with malicious intent from 
obtaining radioactive sources or from smuggling them into the United 
States. In March 2006, we reported on an undercover operation in which 
we used forged NRC documents to transport category 5 radioactive 
sources across the northern and southern borders of the United States, 
underscoring CBP's inability to verify the legitimacy of radioactive 
sources entering the United States.[Footnote 8] In March 2007, using 
the name of a fictitious business, we obtained a radioactive materials 
license from NRC, which we altered and then used to obtain commitments 
from private companies to purchase dangerous quantities of radioactive 
sources.[Footnote 9] We did this only a few months after NRC had issued 
guidance designed to prevent those with no legitimate need to possess 
radioactive sources from acquiring a license. 

In this context, this report assesses (1) the progress NRC has made in 
implementing the recommendations in our August 2003 report, (2) other 
steps NRC has taken to improve its ability to monitor and track 
radioactive materials, (3) CBP's ability to detect radioactive 
materials at ports of entry on the northern and southern borders, and 
(4) CBP's ability to verify that such materials are appropriately 
licensed before they are allowed to enter the United States. 

To assess the progress NRC has made in implementing the recommendations 
in our August 2003 report, we reviewed NRC's periodic reports to the 
Congress on the status of these recommendations, reviewed the relevant 
policy and procedural changes undertaken since the report was issued, 
and interviewed NRC officials about the status of our recommendations 
and actions taken and steps planned to implement them. We also spoke to 
various state regulators of radioactive sources and materials. We 
attended two annual meetings of the Organization of Agreement States 
and interviewed each of the board members to obtain their perspectives 
on NRC's implementation of the recommendations on issues affecting 
states. We also obtained documents and interviewed several experts at 
Sandia and Los Alamos National Laboratories in Albuquerque and Los 
Alamos, New Mexico, respectively, and Lawrence Livermore National 
Laboratory in Livermore, California, about the risks posed by RDDs. In 
addition, we met with officials from the National Nuclear Security 
Administration's Office of Global Threat Reduction, who are working on 
a classified, comprehensive analysis of the potential social and 
economic costs of various RDD scenarios. Finally, we obtained documents 
and interviewed officials from EPA about their responsibilities for 
developing and implementing standards for protecting the general public 
from radiation in contaminated air, water, and soil. 

To assess other steps NRC has taken to improve its ability to monitor 
and track radioactive materials, we obtained documentation about the 
capabilities, operations, and reliability of the NRC databases 
currently in operation and those in various stages of development. We 
also interviewed senior NRC database managers responsible for running 
or developing these systems. 

To assess CBP's ability to detect and verify the legitimacy of 
radioactive sealed sources and materials before they are allowed to 
enter the United States, we gathered documentation on the capabilities 
and operations of DHS's National Targeting Center, toured the facility, 
and interviewed the center's director. We gathered documents and 
interviewed CBP officials, including port directors and CBP line 
officers, during visits to a nonprobability sample[Footnote 10] of 
several ports of entry on both the Canadian and Mexican borders. In 
addition, we gathered documentation about the operations of four other 
ports of entry and interviewed the principal CBP officials responsible 
for running these land border crossings. We selected these ports of 
entry because of their geographic locations and sizes, as well as the 
estimated volume of entries into the United States of both passengers 
and cargo (general and radioactive materials) at these locations. We 
also gathered information about the technical capabilities of the 
radiation detection equipment used by CBP officers. Finally, we 
interviewed officers of the Organization of Agreement States and other 
state officials to obtain the states' perspectives on their 
collaboration with NRC and DHS. We conducted this performance audit 
from August 2006 to May 2008 in accordance with generally accepted 
government auditing standards. Those standards require that we plan and 
perform the audit to obtain sufficient, appropriate evidence to provide 
a reasonable basis for our findings and conclusions based on our audit 
objectives. We believe that the evidence obtained provides a reasonable 
basis for our findings and conclusions based on our audit objectives. 

Results in Brief: 

NRC has implemented three of the six recommendations in our 2003 report 
on the security of radioactive sources by working with agreement states 
to (1) identify radioactive sealed sources of greatest concern, (2) 
determine how agreement state and nonagreement state officials could 
participate in the development and implementation of additional 
security measures for radionuclides of concern, and (3) include 
performance criteria for assessing NRC's and agreement states' 
implementation of these additional security requirements in periodic 
evaluations of both NRC and agreement state effectiveness. 
Specifically, NRC, working with DOE, developed a list of 16 
radionuclides of concern that, if gathered in sufficient quantities, 
pose the greatest risk of being used by terrorists to make an RDD. 
Second, NRC, working with agreement states, has required several 
additional security measures called "increased controls" be taken to 
protect such radionuclides from theft, diversion, or other unauthorized 
access when they are gathered in quantities at or above a particular 
threshold. Increased controls include such measures as implementing 24- 
hour surveillance, multiple layers of physical security, and measures 
to ensure the immediate notification of local law enforcement agencies 
in the event of any actual or suspected breach in security. Finally, 
NRC and agreement states also established criteria for assessing the 
implementation of these increased controls and integrated these 
criteria into NRC's existing oversight program. To date, inspection 
teams comprised of inspectors from NRC (headquarters and regional 
office staff) and agreement states have assessed the implementation of 
increased controls by several agreement states and one of four NRC 
regional offices. 

In contrast, NRC has made limited progress toward implementing our 
recommendations to (1) modify its process for issuing licenses to 
ensure that radioactive materials cannot be purchased by individuals 
who have no legitimate need for them, (2) determine how to effectively 
mitigate the potential psychological effects of malicious use of 
radioactive materials, and (3) re-examine whether certain radioactive 
sources should be regulated through specific licenses rather than 
general licenses. More specifically, although NRC did take steps in 
December 2006 that it thought would ensure that radioactive materials 
could not be purchased by those without a legitimate need for them, 
these changes were not sufficient to prevent us from obtaining an NRC 
license for a fictitious business and using this license to obtain 
commitments from manufacturers of industrial devices containing 
radioactive materials to sell them to us. Taken together, the devices 
we could have acquired would have contained a potentially dangerous 
quantity of one of the 16 radionuclides of concern. Moreover, NRC has 
not yet taken steps to determine how to mitigate the potential 
psychological effects of a terrorist attack using radioactive 
materials, although it has participated in an interagency working group 
that recently produced a draft version of a public education action 
plan that seeks, among other things, to reduce public fears of 
radioactivity and diminish the impact of a terrorist attack using such 
materials. Finally, although NRC has gathered the data it needs to re- 
examine whether certain radioactive sources should be regulated through 
specific licenses rather than general licenses, it has only recently 
begun the process of deciding, in consultation with agreement states, 
whether and what sort of changes should be made. 

Beyond responding to our previous recommendations, NRC has taken four 
steps to improve its ability to monitor and track radioactive materials 
since we issued our 2003 report. However, three of these efforts have 
limitations and are not yet implemented. More specifically, NRC created 
an interim national database to monitor all the licensed radioactive 
sealed sources that contain the more dangerous quantities (categories 1 
and 2) of the types of radioactive sources that pose the greatest risk 
of being used in an RDD. This database, which relies on data that are 
updated annually, is intended to provide limited monitoring and 
tracking information on sealed sources until NRC can launch the 
National Source Tracking System. This system is intended to replace the 
interim database and provide more detailed, comprehensive, and 
frequently updated information on radioactive sealed sources. The 
National Source Tracking System will initially include information only 
about the potentially more dangerous category 1 and 2 radioactive 
sealed sources containing RDD-suitable radioactive materials, but will 
eventually include information on category 3 and the largest category 4 
sources which NRC also considers to be potentially dangerous. Also, 
this system has already been delayed by 18 months and is not currently 
expected to be launched until January 2009. In April 2008, NRC 
announced plans to expand the National Source Tracking System to 
include category 3 and the largest category 4 sources by July 31, 2009-
-a date which NRC told us the following month would slip to at least 
March 2010. NRC is also developing a Web-based system that will include 
information on all NRC specific licenses. This system is already more 
than 3 years behind schedule, however, and may not include information, 
initially at least, on radioactive materials licenses that are issued 
by agreement states--which represent over 80 percent of all U.S. 
licenses for these materials. NRC officials told us that they are 
currently working with agreement states to determine the most efficient 
means of including agreement state data in the Web-based licensing 
system. Furthermore, NRC is in the early stages of developing a new, 
third system--a license verification system--which NRC officials hope 
to have operational by the time the Web-based licensing system is 
deployed in the summer of 2010, and will draw on information in both 
the National Source Tracking System and the Web-based licensing system 
to provide regulators and vendors with the ability to verify that those 
seeking to purchase additional radioactive sealed sources are licensed 
to do so. Taken together, these systems will include detailed 
information about what licensees are allowed to possess and, 
importantly, whether a prospective licensee seeking to purchase 
additional sealed sources is licensed to possess the additional types 
and quantities. The delays in the deployment and full development of 
both the National Source Tracking System and Web-based licensing 
system, and the new license verification system, are especially 
consequential because NRC has identified the deployment of these 
systems as key to improving the security of radioactive materials in 
the United States. 

While CBP has a comprehensive system in place to detect radioactive 
materials entering the United States at land borders, some equipment 
that is used to protect CBP officers is in short supply. More 
specifically, vehicles, cargo, and people entering the United States at 
most ports of entry along the Canadian and Mexican borders are scanned 
for radioactive materials with radiation detection equipment capable of 
detecting even very small amounts of radiation--whether these materials 
are in the form of industrial sources, raw materials, trace amounts of 
radiation found in such common products as ceramics or bananas, or 
radionuclides left in the human body in the aftermath of medical 
procedures. If radiation is detected, CBP officers must investigate 
until they are convinced that any vehicles, cargo, and people pose no 
threat. When CBP officers cannot resolve the radiation alarm with the 
information available to them at the border, they are required to 
contact technical experts at CBP's National Targeting Center for 
assistance. If radioactive materials are found, CBP officers must take 
steps to ensure that those seeking entry to the United States appear to 
have a legitimate reason to possess and transport such materials, and 
are licensed as appropriate, before being allowed to enter the country. 
However, while CBP has comprehensive systems in place for detecting 
radiation, we found that personal radiation detectors--an important 
component of the suite of radiation detection equipment in place at the 
borders--are in short supply. Unlike other radiation detection 
equipment that is designed to be used as screening tools for 
radioactive materials, personal radiation detectors are designed to 
alert the individual wearer when he or she is being exposed to 
unusually high levels of radiation. While most CBP officers dealing 
with the public in front-line positions are equipped with personal 
radiation detectors, some are not. According to CBP officials, the 
agency lacks sufficient resources to purchase the approximately 1,500 
personal radiation detectors it needs to provide one for each officer 
at the border who currently needs one. 

While CBP has systems in place to verify that all licenses for 
radioactive materials are legitimate, it has not effectively 
communicated its guidance to CBP officers on when they must contact the 
National Targeting Center to verify that radioactive materials are 
legitimately licensed. Consequently, some CPB officers are not 
following the most recent guidance, and some dangerous radioactive 
materials have entered the country without license verification. 
Specifically, according to a directive issued in 2003, there are 
circumstances when even large shipments of radioactive materials could 
be admitted without a CBP officer contacting the center to verify 
legitimacy. In 2006, to tighten security, CBP issued a supplemental 
memorandum revising the circumstances under which CBP officers are 
required to contact the National Targeting Center. That is, as of 2006, 
CBP officers must now contact the center to verify that radioactive 
materials are legitimately licensed whenever they detect more than 
incidental, trace amounts of radiation--for example, amounts higher 
than the low levels found in such common products as ceramics and 
bananas. However, headquarters has not effectively communicated this 
updated guidance to CBP officers at the border. When we asked CBP 
officers at several ports of entry about the current guidance for 
regulating the flow of radioactive materials across the border, almost 
all officers either provided us with the 2003 directive or confirmed 
that the 2003 directive was current and operative; only one gave us 
guidance reflecting the 2006 memorandum. Finally, at one port of entry, 
CBP officers were confused about when to verify licenses and were 
routinely permitting large shipments of neutron-emitting material to 
enter the country. This situation was particularly troubling because 
(1) some neutron-emitting materials can be used to make nuclear weapons 
and (2) it has been CBP policy since 2003 to verify the legitimacy of 
all neutron-emitting materials. 

We are recommending that the Chairman of the NRC take steps, consistent 
with sound systems development practices, to (1) ensure that priority 
attention is given to meeting the current January 2009 and summer 2010 
target dates for launching the National Source Tracking System, Web- 
based licensing system, and the new license verification system, 
respectively; and (2) complete the needed steps to include all 
potentially dangerous radioactive sources in the National Source 
Tracking System as quickly as is reasonably possible. In addition, to 
improve the likelihood of preventing radioactive sources and materials 
from being smuggled into the United States, we recommend that the 
Secretary of Homeland Security direct the Commissioner of CBP to (1) 
effectively communicate current CBP guidance to officers at ports of 
entry regarding when they are required to contact the National 
Targeting Center to verify the legitimacy of radioactive materials, and 
(2) take measures to ensure that this guidance is being followed. 

We provided a draft of this report to the Chairman of the NRC, the 
Secretary of Homeland Security, the Secretary of Energy, the 
Administrator of the EPA, and the Chair of the Organization of 
Agreement States for comment. NRC neither agreed nor disagreed with the 
report's findings and recommendations. Instead, NRC described its 
current efforts to implement the recommendations from our 2003 report 
and stated its intention to place the highest priority on the 
completion and deployment of the National Source Tracking System and 
the Web-based licensing system and a new, third system. Although we are 
encouraged by NRC's efforts to finish implementing the recommendations 
from our 2003 report, we remain concerned that nearly 5 years after we 
issued our report these recommendations have yet to be fully 
implemented. The other federal agencies that were offered the 
opportunity to comment on our report either agreed with our 
recommendations and outlined the steps to be taken to implement them, 
or chose not to comment on the final draft. Specifically, according to 
DHS's written comments, CBP concurred with our recommendations and 
specified the steps it will take to implement them. DOE and EPA 
reviewed and provided comments on earlier versions of our draft report 
and, after reviewing our final draft, had no further comments. The 
Organization of Agreement States neither agreed nor disagreed with our 
findings and recommendations, but offered comments on the quality of 
agreement state regulatory programs and NRC collaboration with 
agreement states, which we incorporated into the report. 

NRC Has Implemented Three of the Six Recommendations from GAO's 2003 
Report: 

Since 2003, NRC has worked with agreement states and others to identify 
the radioactive materials that pose the greatest risk of being used to 
make an RDD, established additional security measures for these 
materials, and taken steps to ensure the increased security measures 
are effectively implemented. However, NRC has not successfully 
corrected the weaknesses in its radioactive materials licensing 
processes. Further, NRC has taken limited steps to determine how to 
effectively mitigate the potential psychological effects of an RDD. 
Finally, NRC has not yet decided whether certain radioactive sources 
need stronger licensing requirements. 

NRC Has Worked with the States and Others to Identify Radioactive 
Sources That Pose the Greatest Risk of Being Used to Make an RDD: 

An NRC and DOE working group had established a tentative list of 
radioactive materials under NRC license and DOE control and the 
quantities at which they pose the greatest risk. However, according to 
agreement states representatives, the agreement states were not 
directly involved in creating this list prior to the release of our 
August 2003 report. Our report recommended that the Chairman of NRC 
collaborate with the agreement states on this list, which NRC did 
before the list was finalized in August 2005. Specifically, in July 
2002, the chairman of the NRC and the Secretary of Energy established a 
working group to identify radioactive materials according to the 
relative risk they posed of being used by terrorists to make an RDD. 
The working group assessed the relative hazards of various radioactive 
isotopes, taking into consideration both the nature of the materials 
(their potential threat to human health) and their attractiveness for 
use in an RDD (their half-lives, the quantities in which such materials 
are typically found, the level of protection typically surrounding 
them, and the ease with which they might be dispersed). The working 
group completed its initial study in November 2002 and issued a final 
report in May 2003. During this period, NRC, DOE, and other U.S. 
government entities were also negotiating with other countries under 
the auspices of the International Atomic Energy Agency (IAEA) to create 
a single international threshold quantity at which nations adopting 
IAEA's Code of Conduct would agree to take measures to more closely 
track and consider increased security measures to protect radionuclides 
of concern. NRC also consulted with agreement states on this issue. In 
the end, it was agreed in September 2003 that the threshold for 
increased concern--that is, the quantities at which various 
radionuclides become subject to more stringent security--should be 
category 2 quantities. 

After our August 2003 recommendation that NRC consult with the 
agreement states on this list, NRC officials formally provided it to 
agreement state officials for their review. The agreement states agreed 
with the list and the thresholds developed by the IAEA and 
participating countries (see table 1). 

Table 1: 16 Radionuclides of Concern: 

Radionuclide: Americium-241; 
Common abbreviation: Am-241; 
Principal emission(s): alpha; 
Threshold for concern in curies (IAEA category 2): 16. 

Radionuclide: Americium-241/Beryllium; 
Common abbreviation: Am-241/Be; 
Principal emission(s): alpha/neutron; 
Threshold for concern in curies (IAEA category 2): 16. 

Radionuclide: Californium-252; 
Common abbreviation: Cf-252; 
Principal emission(s): alpha; 
Threshold for concern in curies (IAEA category 2): 5.4. 

Radionuclide: Cesium-137; 
Common abbreviation: Cs-137; 
Principal emission(s): beta/gamma; 
Threshold for concern in curies (IAEA category 2): 27. 

Radionuclide: Cobalt-60; 
Common abbreviation: Co-60; 
Principal emission(s): beta/gamma; 
Threshold for concern in curies (IAEA category 2): 8.1. 

Radionuclide: Curium-244; 
Common abbreviation: Cm-244; 
Principal emission(s): alpha; 
Threshold for concern in curies (IAEA category 2): 14. 

Radionuclide: Gadolinium-153; 
Common abbreviation: Gd-153; 
Principal emission(s): gamma; 
Threshold for concern in curies (IAEA category 2): 270. 

Radionuclide: Iridium-192; 
Common abbreviation: Ir-192; 
Principal emission(s): beta/gamma; 
Threshold for concern in curies (IAEA category 2): 22. 

Radionuclide: Plutonium-238; 
Common abbreviation: Pu-238; 
Principal emission(s): alpha; 
Threshold for concern in curies (IAEA category 2): 16. 

Radionuclide: Plutonium-239/Beryllium; 
Common abbreviation: Pu-239/Be; 
Principal emission(s): alpha/neutron; 
Threshold for concern in curies (IAEA category 2): 16. 

Radionuclide: Promethium-147; 
Common abbreviation: Pm-147; 
Principal emission(s): beta; 
Threshold for concern in curies (IAEA category 2): 11,000. 

Radionuclide: Radium-226; 
Common abbreviation: Ra-226; 
Principal emission(s): alpha; 
Threshold for concern in curies (IAEA category 2): 11. 

Radionuclide: Selenium-75; 
Common abbreviation: Se-75; 
Principal emission(s): gamma; 
Threshold for concern in curies (IAEA category 2): 54. 

Radionuclide: Strontium-90 (Yttrium-90); 
Common abbreviation: Sr-90 (Y-90); 
Principal emission(s): beta; 
Threshold for concern in curies (IAEA category 2): 270. 

Radionuclide: Thulium-170; 
Common abbreviation: Tm-170; 
Principal emission(s): gamma; 
Threshold for concern in curies (IAEA category 2): 5,400. 

Radionuclide: Ytterbium-169; 
Common abbreviation: Yb-169; 
Principal emission(s): gamma; 
Threshold for concern in curies (IAEA category 2): 81. 

Source: NRC. 

Note: NRC published the list of 16 radionuclides of concern in the 
Federal Register in 2007 as part of Orders Imposing Additional Security 
Measures. 

[End of table] 

NRC and Agreement States Have Established Additional Security 
Requirements and Taken Steps to Ensure Their Implementation: 

NRC also implemented our recommendations to (1) determine how agreement 
state and nonagreement state officials could participate in the 
development and implementation of additional security measures for 
radionuclides of concern and (2) include performance criteria for 
assessing NRC's and agreement states' implementation of these 
additional security requirements in periodic evaluations of both NRC 
and agreement state effectiveness. First, NRC worked with agreement 
states to devise and implement several additional security measures-- 
called "increased controls" --to protect category 2 or greater 
quantities of radionuclides of concern from theft, diversion, and other 
unauthorized access. In late 2003, NRC and state officials, some of 
whom were also officers of the Organization of Agreement States or 
Conference of Radiation Control Program Directors (an organization that 
includes both agreement and nonagreement states), established several 
working groups to facilitate the participation of state officials and 
their organizations in developing and implementing additional security 
measures for certain radioactive sources and materials. Several state 
officials, including a former chair of the Organization of Agreement 
States (OAS), told us that these working groups functioned in a highly 
collaborative and deliberative manner. Another OAS official told us 
that the fact that so many agreement state officials have been willing 
to volunteer to serve in working groups, and that NRC has been willing 
to provide some financial support for state officials' involvement, is 
a testament to the importance that both NRC and agreement states placed 
on federal-state collaboration. NRC and agreement states officially 
issued requirements for the increased controls in December 2005. The 
purposes of the increased controls, according to NRC, are to reduce the 
risk of unauthorized use of radioactive materials and to aid the prompt 
detection and assessment of and response to any such attempt. Increased 
controls include such measures as 24-hour surveillance, multiple layers 
of physical security, and measures to ensure the immediate notification 
of local law enforcement agencies in the event of any actual or 
suspected breach in security. For example, increased controls on 
medical sources require some sources to be kept in heavily secured 
rooms with limited access (see fig. 1). 

Figure 1: Cesium-137 Sources at a Hospital Used for Cancer Treatment 
Are Kept in a Secure Room with Limited Access: 

[See PDF for image] 

This figure is a photograph of the door to a secure room with limited 
access. 

Source: GAO. 

[End of figure] 

According to NRC, all increased controls were to be fully implemented 
by June 2006. Some licensees with the highest-risk sources were 
inspected by June 2007, while all increased controls must be fully 
inspected by June 2009. NRC regional offices and agreement state 
regulators are also currently in the process of reaching out to 
licensees to help ensure they will be able to meet the June 2009 
deadline and have already performed preliminary increased controls 
inspections on approximately 1,100 of the 1,700 licensees subject to 
the new controls (see table 2). 

Table 2: Increased Controls on Category 2 or Greater Quantities of the 
16 Radionuclides of Concern: 

Control: Access controls; 
General purpose: Control access to high-risk materials at all times. 

Control: Background checks for unescorted access; 
General purpose: Limit unescorted access only to those determined to be 
trustworthy and reliable after background checks. 

Control: Monitor, detect, and respond to unauthorized access; 
General purpose: Ensure the establishment of the means to monitor and 
immediately detect and respond to any unauthorized access. 

Control: Advance coordination with local law enforcement; 
General purpose: Response plans must include advanced cooperation with 
local law enforcement agencies, and any actual response must include 
this local law enforcement agency. 

Control: Transportation controls; 
General purpose: Additional security measures are required for 
shipments of category 1 and 2 sources. 

Control: Protection of sensitive physical plant information; 
General purpose: Protecting security related information against 
unauthorized disclosure by limiting access to trustworthy and reliable 
individuals with a need to know. 

Source: NRC. 

[End of table] 

Agreement state officials told us that they have already prevented at 
least one attempted theft of an industrial radiography source typically 
used to inspect metal parts and welds for defects. The would-be thieves 
broke in to an area protected by an alarm system that had been recently 
installed by the licensee to comply with the new requirement mandating 
the capacity to monitor, detect, and respond quickly with local law 
enforcement in the event of any unauthorized access. This new alarm 
system immediately notified local law enforcement authorities, who 
responded in time to prevent the criminals from obtaining an iridium- 
192 radiography source--a potent gamma emitter that could cause 
extensive radiation burns if handled improperly. 

NRC and agreement states have also collaborated in establishing 
criteria for assessing the implementation of increased controls and 
integrated these criteria into NRC's existing oversight program, the 
Integrated Materials Performance Evaluation Program (IMPEP).[Footnote 
11] In March 2006, NRC established performance criteria devised in 
working groups with agreement state officials for evaluating the 
implementation of increased controls. Under each of the existing 
performance categories--staffing and training, the technical quality of 
inspections, licensing actions, incident and allegation activities, and 
the overall status of the materials inspection program--NRC added 
additional performance criteria. For example, NRC regional and 
agreement state programs are now evaluated on whether they have 
established a system to readily identify new licensees that should be 
subject to increased controls and to determine whether sensitive 
licensee information is being securely maintained. Although not all NRC 
regional and agreement states' radioactive materials programs have been 
evaluated on their implementation of the increased controls, 22 of the 
35 agreement states and one of the three NRC regional offices with 
responsibilities for regulating such materials have to date had aspects 
of their implementation of increased controls at least partially 
assessed in this manner. Moreover, agreement state officials familiar 
with this revised performance evaluation process told us that the new 
criteria were effective and valid measures of the implementation of the 
increased controls. 

Weaknesses Persist in NRC's Materials Licensing Process: 

To increase the security of radioactive materials and sealed sources 
and better ensure that they are used as intended, we recommended in 
2003 that NRC modify its process for issuing specific licenses to 
ensure that such sources cannot be purchased before NRC has verified, 
through inspection or other means, that the materials and sources will 
be used as intended. In December 2006, NRC issued new prelicensing 
guidance to help NRC and agreement state licensing officials to make a 
risk-based determination of whether an applicant for a license to 
possess an amount of radioactive material or source sufficient to 
require a specific (rather than a general) license should have to 
undergo some sort of verification before being granted a license. This 
guidance asked two screening questions: (1) whether "the applicant is 
an entity or a licensee transferring control to an entity that has 
never had a license or is unknown" and (2) whether the applicant is 
seeking category 2 or greater quantities of one or more of the 16 
radionuclides of concern and has not already been licensed to possess 
materials subject to a security order or additional requirements for 
increased controls. If the applicant answers yes to either question, 
according to the guidance, the license examiner should consider whether 
it is necessary to take any of the steps on a 12-item checklist. For 
example, one checklist item suggests doing an Internet search on the 
name of the applicant; another suggests conducting a site visit to the 
stated place of business. In spring 2007, however, our investigators, 
posed as first-time radioactive materials license applicants for 
devices containing sources large enough to require specific licenses, 
and therefore subject to the extra scrutiny from the 12-item checklist, 
they were able to obtain a materials license from NRC, even though an 
Internet search or a prelicensing site visit would have revealed the 
application to be based on false claims.[Footnote 12] After being 
notified of the results of our undercover investigation in June, NRC 
stopped issuing specific licenses for radioactive materials and sources 
until it could develop and issue "supplemental interim prelicensing 
guidance." This supplemental guidance, issued 12 days after NRC stopped 
issuing specific licenses, requires a first-time licensee to pass a 
site visit inspection at the applicant's place of business or appear at 
an NRC regional office for a face-to-face meeting with a license 
application reviewer and satisfy this official that the radioactive 
materials will be used as intended. Applicants would not be subject to 
these requirements if they already have an established regulatory 
relationship with NRC or an agreement state and meet other specific 
criteria. 

In September 2007, NRC announced in a public briefing that it had 
developed a comprehensive plan for resolving all the vulnerabilities in 
its radioactive materials licensing processes. NRC announced plans to 
do several things to help make its program more secure, including the 
following. 

* Establish a panel of independent external reviewers to study NRC's 
materials licensing program vulnerabilities, with particular scrutiny 
of its "good faith assumptions" about applicants. This panel presented 
a number of observations and recommendations to NRC in March 2008. 

* Reconstitute the NRC and agreement state prelicensing working group 
to develop solutions to vulnerabilities associated with verification, 
counterfeiting, and general licenses. 

* Establish a new materials program working group that would review the 
results of an independent external review and comprehensively assess 
the entire materials licensing program, including NRC's evaluation of 
state programs. 

* Leverage the capabilities of new databases currently under 
development--the National Source Tracking System and Web-based 
licensing. 

To assure themselves that other radioactive materials licenses had not 
been issued to fraudulent individuals, NRC also undertook a 
retrospective review of a sampling of licenses to verify their 
legitimacy. NRC officials stated that these reviews uncovered no other 
incidences of fraud. We think all of these actions are useful steps 
toward closing the long-standing vulnerabilities in NRC materials 
licensing processes, but it is too early to evaluate whether these 
steps will be successful. 

NRC Has Taken No Significant Actions to Mitigate the Potential 
Psychological Effects of an RDD: 

In addition to recommending that NRC work with agreement states and 
others to identify and better secure the radioactive sources that pose 
the greatest risk of being used to make an RDD, we also recommended 
that NRC determine how to effectively mitigate the potential 
psychological effects of malicious use of radioactive materials. Since 
we issued our 2003 report, DHS issued the National Response Plan in 
December of 2004 to establish a comprehensive all-hazards approach to 
domestic incident management. The National Response Plan, revised and 
reissued as the National Response Framework in January 2008, details 
how federal agencies and others should coordinate to ensure an 
efficient and effective nationwide response to a broad spectrum of 
domestic incidents, including those involving the malicious use of 
radioactive materials. Under the National Response Framework, where a 
radiological incident involves facilities or materials licensed by the 
NRC or agreement states, NRC either coordinates federal response 
activities or assists DHS in doing so, depending on the scope of the 
incident.[Footnote 13] In our view, such coordination should include 
taking actions to determine how to effectively mitigate all the effects 
of such an RDD--including psychological effects. 

However, NRC has not implemented this recommendation because, according 
to NRC officials, NRC has only a very limited role to play in 
mitigating the psychological effects that may occur in the aftermath of 
an RDD event unless the amount of radioactive materials released is 
sufficient to cause "prompt fatalities"--that is, fatalities directly 
caused by exposure to radioactive materials. Accordingly, NRC has 
identified and taken limited steps that it sees as consistent with its 
prescribed role. Specifically, NRC points to its participation in the 
interagency Radiation Source Protection and Security Task Force Public 
Education Working Group with DHS, DOE, agreement and nonagreement 
states, and others to design a coordinated public education campaign 
to, among other things, reduce public fears of radioactivity and 
diminish the impact of a terrorist attack using radioactive materials. 
This working group issued a draft public education action plan in 
December 2007 and provided an update on its efforts on May 15, 2008. 
NRC is also a member of and has provided input to a Health Physics 
Society[Footnote 14] working group that is putting together a program 
to educate the public about radiation and help counteract unfounded or 
irrational fears. 

Despite these activities, in our view, NRC's response to our 
recommendation is inadequate. Over 4 years after we made our 
recommendation, NRC has not yet determined how to effectively mitigate 
the potential psychological effects of the malicious use of radioactive 
materials. Moreover, according to existing EPA protective action 
guidelines, the amount of radioactive material needed to cause "prompt 
fatalities"--the threshold at which NRC accepts having a significant 
role--is significantly greater than would be necessary to cause 
contaminated areas to be evacuated, a threshold at which psychological 
effects could reasonably be expected to occur. According to NRC 
officials, unless the prompt fatalities threshold is met, NRC believes 
its job is to provide the public with prompt, complete information 
about the effects of any release of radiation involving material the 
agency regulates and, to the extent it is relevant, to inform the 
public about the NRC regulations or guidance that may be relevant as a 
result. Beyond participating in an interagency task force working 
group, providing any additional information that may be needed is, 
according to NRC, the responsibility of others (federal, state, or 
local officials, etc.). This approach is consistent with NRC's view 
that its primary responsibility is to regulate "inside the fence, 
inside licensee-controlled areas." "Outside the fence," NRC views its 
role as assisting those federal agencies that have primary 
responsibility, namely DHS, DOE, and others and making sure that its 
licensees comply with these agencies' legitimate concerns. 

NRC Has Not Yet Decided Whether Certain Radioactive Sources Need 
Stronger Licensing Requirements: 

In light of growing concerns about the potential malicious use of 
radioactive sealed sources, and to better secure generally licensed 
devices containing such sources, we recommended that NRC, in 
consultation with agreement states, re-examine whether certain 
radioactive sources should be regulated through specific licenses 
rather than general licenses. According to NRC, by November 2007 it had 
gathered the necessary information about generally licensed devices 
containing relatively larger radioactive sources (the largest category 
4 sources or higher) to decide whether changes should be made.[Footnote 
15] NRC and agreement state officials are currently analyzing the data 
and conferring in working groups and, according to NRC officials, 
initiated a rulemaking process in September 2007. Given the complexity 
and range of the issue and the solutions to be considered, NRC 
officials estimate the formal rulemaking process will take 
approximately 2 years, depending on what form a new rule takes. Rules 
that require states to make statutory changes typically take longer to 
implement. NRC officials stressed that it is impossible to predict what 
form a final rule would take. The various options--for example, a lower 
activity cap for general licenses; specific licensing requirements for 
particular radionuclides regardless of activity; or the development of 
a new, more streamlined specific license--will continue to be a subject 
of discussion among federal and state radioactive materials regulators 
until a decision has been reached. If a revised rule is finalized by 
September 2009, agreement states could have up to an additional 3 years 
to fully implement any changes--meaning that any rule change may not be 
fully implemented until the fall of 2012. 

NRC Has Improved Its Ability to Monitor and Track Radioactive Sealed 
Sources, but New Systems Have Been Delayed: 

NRC has developed an interim database that can monitor and track the 
more dangerous, category 1 and 2 radioactive sealed sources. However, 
two additional systems--one to track radioactive sealed sources and one 
to track licenses--have been repeatedly delayed. A third system under 
development will draw on information in both of these systems to 
provide regulators and vendors with the ability to verify that those 
seeking to purchase radioactive sources are licensed to do so. 

NRC Created an Interim National Database to Better Monitor the More 
Dangerous Radioactive Sealed Sources: 

NRC established the interim database in October 2003 to provide NRC and 
agreement states a stop-gap means of more closely monitoring the 
potentially more dangerous sources until the new National Source 
Tracking System (NSTS) could be completed. This database is called 
"interim" because it is intended to be a temporary measure for 
implementing a quick, practical response to the recommendation in the 
May 2003 DOE-NRC report on RDDs that the U.S. government develop a 
database of sources at greatest risk of being used to make an RDD. The 
interim database currently records information about category 1 and 2 
radioactive sealed sources licensed by both NRC and agreement states. 
[Footnote 16] For a given source, the interim database records the 
radionuclide; the quantity (activity); the licensee address; and the 
make, model, and serial number (where available) of the registered 
source. Although participation is voluntary, NRC successfully persuaded 
agreement states to provide data on their licensees for inclusion in 
the interim database, and as a result, the database includes 
information from 99 percent of all licensees. Originally, the database 
was intended to be a one-time snapshot of what radioactive materials 
existed in the United States during fiscal year 2004. However, NRC 
began to update the database annually as it became apparent that the 
development and launch of the NSTS would take longer than expected. The 
result is an annual snapshot of information about radioactive sources 
as they were at one point during a given year, not a system that tracks 
the current location of sources. The information for any given source 
in the database is, at any given time, 0 to 12 months old. 

It is important to note that the licensee address listed in the interim 
database may simply be the address for the licensee's administrative 
offices--that is, the place where the company officials responsible for 
dealing with NRC or state regulators have offices--and not necessarily 
the address of the physical location of the material. A licensee may be 
allowed to store radioactive materials in several locations throughout 
one or more states but still provide only a single administrative 
address for reporting purposes in the interim database. NRC and 
agreement states check the completeness and accuracy of this inventory 
of source locations during routine inspections of licensees. 

New Systems to Track Radioactive Sealed Sources and Licenses Have 
Limitations and Have Been Repeatedly Delayed: 

The completion and implementation of the major new systems NRC is 
developing to help it better track, and ultimately help secure, 
radioactive sealed sources have been delayed repeatedly. The impetus 
for the creation of the NSTS was a recommendation in the May 2003 DOE- 
NRC report on RDDs that radionuclides identified as being at greatest 
risk of use by terrorists to make an RDD be nationally tracked. The 
Energy Policy Act of 2005 required the establishment of a mandatory 
tracking system.[Footnote 17] The NSTS is also consistent with the 
United States' endorsement of the IAEA Code of Conduct, which 
recommends that nations establish a national source registry to 
include, at a minimum, category 1 and 2 sources of radionuclides of 
concern. 

The NSTS will initially track category 1 and 2 sources of the 20 
radionuclides that NRC has determined are sufficiently attractive for 
use in an RDD or for other malicious purposes that warrant national 
tracking. The 20 radionuclides include the 16 radionuclides of concern 
plus four additional radionuclides: actinium-227, polonium-210, and 
thorium-228 and -229.[Footnote 18] In April 2008, NRC proposed a rule 
to expand the NSTS to include all category 3 sources and the largest 
category 4 sources (at or about one-tenth of the activity threshold for 
category 3). Although the NSTS was originally supposed to be 
operational in mid-2007, difficulties in developing the system have led 
NRC to postpone the launch of the NSTS multiple times. NRC's current 
estimate for the launch of the NSTS (tracking category 1 and 2 sources) 
is January 31, 2009. NRC estimates the expansion of the NSTS will be 
implemented by March 2010. 

According to NRC, the NSTS will initially be populated by the data from 
the interim database. However, unlike the interim database, the NSTS 
will not be an annual snapshot of source inventories. The NSTS will be 
a transaction-based system that will track each major step that each 
tracked radioactive source takes within the United States, from "cradle 
to grave." That is, licensees will be responsible for recording the 
manufacture, shipment, arrival, and disposal of all licensed and 
tracked category 1 and 2 radioactive sources. More specifically, the 
NSTS will include the radionuclide, quantity (activity),[Footnote 19] 
manufacturer, manufacture date, model number, serial number, and site 
address. The licensee will have until the close of the next business 
day after a transaction takes place to enter it into the system. As a 
result, the location of all such sources will be accounted for and more 
closely tracked than in the interim database. While some sources may be 
moved temporarily to different sites, any time that the source changes 
its "home base," the transaction must be registered through the NSTS. 
In this way, the data in the system should be kept up-to-date. 

For security reasons, access to the information in the NSTS will be on 
a need-to-know basis. Licensees will have access to information about 
their sources, agreement state officials will have access to 
information about licensees and sources in their state, and only 
selected NRC officials will have access to the entire system. 

While the NSTS is designed to track larger and potentially more 
dangerous radioactive sealed sources, NRC's Web-based licensing system 
is being developed to provide quick access to up-to-date information on 
all NRC specific licenses for radioactive materials and sources in all 
five IAEA categories. In its technical comments on a draft of this 
report, NRC told us that it is developing a third system--a license 
verification system--which, once operational, will draw on the 
information in NSTS and the Web-based licensing system which will 
provide regulators and vendors of radioactive sources with an easily 
accessible ability to verify that those seeking to purchase nationally 
tracked sources are licensed to do so. Taken together, these systems 
will include detailed information about what licensees are allowed to 
possess and, importantly, whether a prospective licensee seeking to 
purchase additional sealed sources is authorized to possess the 
additional types and quantities. For example, an individual from a 
construction company wanting to purchase a piece of equipment 
containing a radioactive sealed source must demonstrate to the vendor 
that the company is licensed to possess such a source. Once all three 
systems are operational, the vendor could easily verify that the 
company is legitimately licensed to purchase a given piece of equipment 
containing the particular sealed source. Although the Web-based 
licensing system was originally supposed to be deployed in 2005, it is 
now estimated be completed no earlier than the late summer of 2010. 
Moreover, the Web-based licensing system may not initially include any 
information on radioactive materials licenses issued by agreement 
states--which represent over 80 percent of all U.S. licenses for these 
materials. NRC officials told us that they are currently working with 
agreement states to determine the most efficient means of including 
agreement state data in the Web-based licensing system. Finally, NRC 
has only recently begun developing its new license verification system 
and has not yet established firm completion dates. However, NRC 
officials told us that they expect it to be complete by the time that 
the Web-based licensing is launched. 

The delays in the development of both the NSTS and the Web-based 
licensing system are especially consequential because NRC officials, 
both commissioners and staff, have identified the deployment of these 
systems as key to improving the control and accountability of 
radioactive materials in the United States. More specifically, in NRC's 
September 2007 public hearing addressing the weaknesses that we 
uncovered in NRC's materials licensing program, the commissioners said 
that an expanded NSTS including category 3 and perhaps the largest 
category 4 sources, a Web-based licensing system including agreement 
state data, and some means for making relevant information in both of 
these systems available to vendors and officials at ports of entry, 
would be a secure and effective means of verifying that those seeking 
to obtain radioactive materials, or enter the United States with 
licensable quantities of radioactive materials or sources, were doing 
so for legitimate purposes. 

CBP Has a Comprehensive System for Detecting Radiation at Ports of 
Entry on the Northern and Southern Borders: 

CBP has a comprehensive, layered system for detecting and identifying 
radioactive materials as they enter the United States at land ports of 
entry--whether they are in the form of industrial sources, raw 
materials, trace amounts of radiation found in such common products as 
ceramics or bananas, or radionuclides left in the human body in the 
aftermath of medical procedures. However, some equipment that is used 
to protect CBP officers is in short supply. 

CBP's Radiation Portal Monitors Scan Most Vehicle, Cargo, and Passenger 
Traffic Entering the United States: 

According to CBP, over 90 percent of the personally owned vehicles 
entering the United States at land ports of entry pass through 
radiation portal monitors.[Footnote 20] Portal monitors are very 
sensitive and can detect even the very small amounts of radiation. All 
vehicles must pass through the monitors at every port of entry that 
deploys them. Any vehicle triggering a portal monitor alarm is referred 
to a secondary screening area, where it is sent through a second portal 
monitor to confirm (or disconfirm) the original alarm. Whether the 
second portal monitor confirms the alarm or not, the vehicle, the 
driver, any passengers, and any cargo are scanned by a CBP officer with 
a hand-held radiation isotope identification device (RIID). The RIID 
can detect very small amounts of radiation and also identify many of 
the most commonly used radionuclides by name and activity level. CBP 
keeps detailed records on the cause of each alarm and its resolution 
and sends them to a central location for archiving. All portal monitor 
alarms must be resolved--that is, CBP officers must investigate each 
alarm until they are convinced that the vehicle, occupants, and any 
cargo pose no threat and, if radioactive materials are found, that the 
vehicle occupants appear to have a legitimate reason to possess and 
transport them--before the vehicle, driver, and any passengers can be 
allowed to enter the United States. 

The vast majority of portal monitor alarms are resolved by CBP officers 
at the border using the information available to them directly from 
portal monitor and RIID scans, documents provided by shippers and 
passengers, and the explanations of the travelers (commercial and 
passenger vehicle drivers and passengers) for why they are carrying 
radioactive materials, whatever the amount or form. When CBP officers 
cannot resolve the radiation alarm with information available to them 
at the border, they are required to contact technical experts at CBP's 
National Targeting Center for assistance. These experts offer 
scientific expertise to help CBP officers interpret and use the portal 
monitor and RIID data and will also verify whether any radioactive 
sources have been properly licensed by checking NRC and agreement state 
licensing data.[Footnote 21] Figures 2 and 3 show vehicles lining up 
and passing through portal monitors at ports of entry. Figure 4 shows 
an inspection area and a truck-sized portal monitor on the southern 
border. 

Figure 2: Passenger Vehicles at a Port of Entry on the Southern Border: 

[See PDF for image] 

Photograph of passenger vehicles at a port of entry on the southern 
border. 

Source: GAO. 

[End of figure] 

Figure 3: Trucks Passing through Portal Monitors on the Northern 
Border: 

[See PDF for image] 

Photograph of trucks passing through portal monitors on the northern 
border. 

Source: GAO. 

[End of figure] 

Figure 4: Truck-Sized Portal Monitor in the Inspection Area at a Port 
of Entry on the Southern Border: 

[See PDF for image] 

Photograph of truck-sized portal monitor in the inspection area at a 
port of entry on the southern border. 

Source: GAO. 

[End of figure] 

Most of the CBP officers we spoke with at the ports of entry we visited 
told us they had never or rarely felt it necessary to contact the 
National Targeting Center for assistance, but they all stated that they 
would not hesitate to do so if they encountered anything out of the 
ordinary or if they thought something might pose any threat to national 
security. Those CBP officers who told us they had contacted the center 
for assistance were very pleased with the timely and practical help 
they received. 

Some Radiation Detection Equipment Is in Short Supply: 

Finally, we found that personal radiation detectors--an important 
component of the suite of radiation detection equipment at the borders-
-are in short supply. Unlike portal monitors and RIIDs, personal 
radiation detectors are not designed to be used as screening tools for 
radioactive materials. Instead, they are designed to alert the 
individual wearer when he or she is being exposed to unusually high 
levels of radiation, permitting CBP officers to take protective 
measures if needed. While most CBP officers dealing with the public in 
frontline positions are equipped with personal radiation detectors, 
some are not. According to CBP officials, the agency lacks sufficient 
resources to purchase the approximately 1,500 personal radiation 
detectors it needs to provide one for each officer at the border who 
currently needs one. In fact, during our visit to one port of entry, we 
found that some officers in frontline positions at the border did not 
have a personal radiation detector. Moreover, CBP has no money 
currently in the budget to acquire the approximately 2,000 additional 
personal radiation detectors it would require to equip the new officers 
it plans to hire--leaving a shortfall of about 3,500 personal radiation 
detectors. CBP headquarters officials are aware of the shortage of 
personal radiation detectors and they hope to procure enough of them 
for each officer who needs one. However, they acknowledged that, in 
doing so, they have to consider competing priorities at the border, and 
also whether emerging technologies may provide a more effective 
solution. 

CBP Guidance on When to Verify Licenses for Radioactive Materials 
Entering the United States Was Not Communicated to the Field: 

In December 2003, CBP issued a radiation detection program directive 
that contained, among other things, the requirement that CBP officers 
at the border contact the National Targeting Center for assistance 
under certain circumstances when radiation is detected. Under the 
directive, even large shipments of radioactive materials can be 
admitted without a CBP officer contacting the National Targeting Center 
to verify whether the materials are legitimately licensed. The 
radiation detection program directive was scheduled for review in 
December 2006, but CBP officials told us that this review was delayed 
pending the resolution of unrelated matters regarding the CBP's right 
to search property for radioactive materials between ports of entry. 

In response to our March 2006 reports[Footnote 22] assessing the 
progress DHS has made deploying radiation detection equipment at U.S. 
ports of entry and detailing how our investigators used fake documents 
to bring licensable quantities of industrial radioactive sources into 
the United States respectively, CBP revised its policy. Specifically, 
in May 2006, CBP issued a memorandum that officials told us tightened 
security by requiring CBP officers to contact the center to verify the 
legitimacy of a license or obtain technical assistance whenever they 
detect more than incidental, trace amounts of radiation, such as that 
found in ceramics and bananas or in people who have recently undergone 
a medical treatment using radionuclides. This memorandum, according to 
headquarters officials, was intended to communicate to officers at the 
border that they should verify the legitimacy of radioactive materials 
because CBP officers at a port of entry cannot determine whether a 
licensee or shipper is authentic without the assistance of the National 
Targeting Center. 

This updated guidance, however, was not effectively communicated to 
officers at the border. Specifically, we asked border officials at the 
several ports of entry we visited and the four others we interviewed on 
the telephone about the current guidance they use for regulating the 
flow of radioactive materials across borders. All either provided us 
copies of the 2003 radiation detection program directive or confirmed 
it was current and operative, and some gave us versions of the 
directive that were port-specific, and therefore, more detailed. Only 
one port of entry provided us with guidance reflecting the May 2006 
memorandum and its requirement that CBP officers contact the National 
Targeting Center to verify the legitimacy of all licensable quantities 
of radioactive materials crossing the border. Moreover, officials at 
all these ports of entry told us that they contact the National 
Targeting Center for technical assistance when they need it; officials 
at only one port of entry told us they would call solely to verify 
whether radioactive materials are appropriately licensed. Officials 
representing a few other ports of entry told us they had never called 
the National Targeting Center to verify the legitimacy of a license and 
that all of their inquiries had been made solely to seek technical 
assistance. 

In addition, the officers we spoke to had minimal knowledge of the 
general regulatory structure established by NRC and agreement states. 
While we found officers generally were aware that radioactive materials 
and sources must be licensed, they typically did not take steps to 
verify licenses, as required by the May 2006 guidance. At the ports of 
entry we visited, we observed CBP officers working to ensure that when 
radioactive materials triggered an alarm, the people carrying (or 
contaminated with) these materials had a good explanation and that the 
readings from the portal monitors and RIIDs were in accord with what 
travelers said and what their documents attested to. In short, the 
officers were focused on resolving the alarm according to the rules 
established in the 2003 radiation detection program directive and on 
attending to the many other tasks they have in monitoring what flows 
through U.S. land ports of entry. 

In fact, the approach to resolving radiation alarms according to the 
procedures prescribed in the 2003 radiation detection directive has 
been so ingrained in day-to-day practice at one port of entry that CBP 
field office managers had discovered only in the week before our visit 
that officers had been allowing large neutron radiation-emitting 
shipments to enter the United States without contacting the National 
Targeting Center for technical support and to verify their legitimacy. 
While this situation has since been corrected, this is of particular 
concern because (1) some neutron radiation-emitting materials can be 
used to produce nuclear weapons and (2) it is in direct conflict with 
CBP's 2003 directive and 2006 supplemental guidance. 

A senior CBP headquarters official told us that the 2003 radiation 
detection program directive, as supplemented by the additional criteria 
established by the May 2006 memorandum on when CBP officers must call 
to verify the legitimacy of radioactive materials, reflected current 
policy. He told us that the May 2006 memorandum was always envisioned 
as only an interim solution, pending a revision of the directive. 
According to this official, CBP was still working on a revision to the 
directive that would fully incorporate the heightened security of the 
memorandum--but he could not give a firm date when an updated directive 
would be issued. In our view, until CBP effectively communicates the 
guidance in the 2006 memorandum to its border locations, CBP officers 
at the border will not know when they should contact the National 
Targeting Center to verify that radioactive materials being brought 
into the United States are legitimately licensed. 

Conclusions: 

NRC has taken a number of important actions to implement several of our 
recommendations from our 2003 report that will enhance the 
accountability and control of radioactive sources and materials and its 
ability to help protect the nation from nuclear smuggling. Still, its 
actions in three key areas remain incomplete. In our view, the reasons 
behind our recommendations 4 years ago are still valid today. 
Accordingly, to further enhance public protection from the threats 
posed by potentially dangerous quantities of radioactive sealed sources 
and materials, we continue to believe that NRC should implement the 
recommendations from our 2003 report. Specifically, NRC should: 

* correct the vulnerabilities uncovered in NRC's materials licensing 
process and implement the steps needed to ensure that radioactive 
materials can only be purchased by those with a legitimate reason to 
possess them, and: 

* determine whether certain radioactive sources should be regulated 
through specific licenses rather than general licenses and move quickly 
to implement whatever changes are deemed necessary. 

In addition, we continue to believe that a plan of how to effectively 
mitigate the potential psychological effects of an RDD event needs to 
be developed. For potential incidents involving radiological facilities 
or materials licensed by NRC or agreement states, for which NRC has 
coordinating responsibilities, NRC should work with DHS, other federal 
agencies, and agreement states, respecting the roles described in the 
National Response Framework, to take action to determine how to 
effectively mitigate the potential psychological effects of such an 
event. 

Also, the causes of the delays in the development and implementation of 
NRC's more comprehensive systems for securing, monitoring, and tracking 
radioactive materials need to be confronted and addressed. 
Specifically, NRC's National Source Tracking System and Web-based 
licensing system have missed numerous milestones and are not expected 
to be complete as currently envisioned until at least 2010. Past delays 
in implementing these systems give reason to wonder whether these dates 
will again be extended and whether NRC is firmly committed to 
delivering these systems. The recent decision to develop a third new 
system has added to these concerns. In our view, given the potential 
consequences of the use of these materials in an RDD and the potential 
for these systems to greatly improve the security of both NRC's and 
agreement states' materials licensing processes, it is time for NRC to 
make meaningful progress in successfully completing these important 
initiatives. 

While CBP has a comprehensive system in place to detect radiation at 
ports of entry on the northern and southern borders, CBP's task of 
preventing the smuggling of radioactive materials is made more 
difficult by the fact that guidance on when officers should verify 
whether radioactive materials being brought into the United States are 
legitimately licensed has not been effectively communicated. The result 
of this communication gap is that resources that are available to CBP 
officers at the border to ensure that those possessing radioactive 
materials are doing so legitimately are underutilized. 

Recommendations for Executive Action: 

Given the repeated delays in implementing improvements to the Nuclear 
Regulatory Commission's ability to monitor and track radioactive sealed 
sources, we recommend that the Chairman of the Nuclear Regulatory 
Commission take steps, consistent with sound systems development 
practices, to ensure that priority attention is given to meeting the 
current January 2009 and summer 2010 target dates for launching the 
National Source Tracking System, Web-based licensing system, and the 
new license verification system, respectively. 

In addition, because some quantities of radioactive materials are 
potentially dangerous to human health if not properly handled, we 
recommend that the Nuclear Regulatory Commission complete the steps 
needed to include all potentially dangerous radioactive sources 
(category 3 and the larger category 4 sources, as well as categories 1 
and 2) in the National Source Tracking System as quickly as is 
reasonably possible. 

Finally, to improve the likelihood of preventing radioactive sources 
and materials from being smuggled into the United States, we recommend 
that the Secretary of Homeland Security direct the Commissioner of 
Customs and Border Protection to: 

* effectively communicate current Customs and Border Protection 
guidance to officers at ports of entry regarding when they are required 
to contact the National Targeting Center to verify that radioactive 
materials are legitimately licensed, and: 

* take measures to ensure that this guidance is being followed. 

Agency Comments and Our Evaluation: 

We provided the Chairman of the Nuclear Regulatory Commission, the 
Secretary of Homeland Security, the Secretary of Energy, the 
Administrator of the Environmental Protection Agency, and the Chair of 
the Organization of Agreement States with draft copies of our report 
for their review and comment. 

In commenting on the draft of this report, NRC neither agreed nor 
disagreed with our findings and recommendations. Instead, NRC described 
its current efforts to implement the recommendations from our 2003 
report. On this point, NRC outlined the steps it is taking to modify 
and strengthen its processes and procedures for licensing radioactive 
materials. NRC also provided an update on the status of the efforts of 
the Radiation Source Protection and Security Task Force's subgroup on 
public education--a subgroup led by DHS of which NRC is a member--to 
proactively educate the general public about radiation with the goal of 
reducing public anxiety and mitigating the adverse psychological 
effects in the event of an RDD attack. Finally, NRC described its 
proposed rule, expected to be issued in the fall of 2009, to limit the 
quantity of radioactive material allowed in a generally licensed 
device. Although we are encouraged by NRC's efforts to finish 
implementing the recommendations from our 2003 report, we remain 
concerned that nearly 5 years after we issued our report these 
recommendations have yet to be fully implemented. Furthermore, NRC 
stated that it is taking the steps necessary to launch the National 
Source Tracking System (NSTS) and Web-based licensing and to complete 
the needed steps to include all potentially dangerous radioactive 
sources in the NSTS as quickly as is reasonably possible. In addition, 
NRC assures that it intends to place the highest priority on the 
completion and deployment of the NSTS and Web-based licensing system. 
However, we are concerned that NRC has once again postponed its 
estimated completion dates for these systems--by at least 9 months in 
the case of expanding NSTS to include the smaller but still potentially 
dangerous radioactive sources and estimates a similar delay in the 
deployment of the Web-based licensing system. Finally, in its technical 
comments, NRC informed us that it is developing a new, third system 
which will draw information from both the NSTS and the Web-based 
licensing system to provide an improved capability for vendors and 
regulators to verify licensing information. While we hope this new, 
third system provides the intended additional capabilities, we are 
concerned that after so many delays with NSTS and the Web-based 
licensing system, adding a third system may further delay the ultimate 
security benefits that these systems are expected to provide. NRC also 
provided additional technical comments, which we incorporated into the 
report as appropriate. 

The other federal agencies that were offered the opportunity to comment 
on our report either agreed with our recommendations and outlined the 
steps to be taken to implement them, or chose not comment on the final 
draft. Specifically, according to DHS's written comments, CBP concurred 
with our recommendations and specified the steps it will take to 
effectively communicate current Customs and Border Protection guidance 
to officers at ports of entry regarding when they are required to 
contact the National Targeting Center to verify that radioactive 
materials are legitimately licensed, and the measures it will take to 
ensure this guidance is being followed. In fact, CBP has already 
updated its current guidance to CBP officers at the border by issuing a 
memorandum to the field directors restating and clarifying when 
officers must contact the National Targeting Center to verify that 
radioactive materials are legitimately licensed and requiring them to 
incorporate this guidance into ports of entry standard operating 
procedures. Finally, DOE and EPA reviewed and provided comments on 
earlier versions of our draft report and, after reviewing our final 
draft, had no further comments. 

The Organization of Agreement States neither agreed nor disagreed with 
our findings and recommendations, but offered two comments which we 
incorporated into the report. Specifically, state officials thought it 
was important to recognize the quality of agreement state regulatory 
programs by highlighting the fact that while GAO investigators 
succeeded in obtaining an NRC radioactive materials license using 
fictitious documents, GAO withdrew its application to obtain a 
materials license from the agreement state when that state informed GAO 
investigators that it would take steps that would have revealed the 
application not to be authentic. State officials also wanted to stress 
what they view as the high level of collaboration they enjoy with NRC, 
as evidenced by the number of state officials involved in security- 
related working groups with NRC officials and the financial support 
that NRC provides to states to enable this level of state 
participation. 

As agreed with your offices, unless you publicly announce the contents 
of this report, we plan no further distribution until 24 days from the 
report date. At that time, we will send copies of this report to the 
Chairman of the Nuclear Regulatory Commission, the Secretary of 
Homeland Security, the Secretary of Energy, the Administrator of the 
Environmental Protection Agency, the Chair of the Organization of 
Agreement States, and interested congressional committees. We will also 
make copies available to others upon request. In addition, this report 
will be available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staffs have any questions about this report, please 
contact me at (202) 512-3841 or [email protected]. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. GAO staff that made major contributions 
to this report are listed in appendix V. 

Signed by: 

Gene Aloise: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Potential Effects of a Radiological Dispersal Device with 
Category 1, 2, and 3 Quantities of Radioactive Material: 

A radiological dispersal device (RDD) is any type of device that is 
intended to disperse radioactive materials, through conventional 
explosives or other means. Among the federal agencies, the 
Environmental Protection Agency (EPA) has lead responsibility for 
providing radiological emergency planning guidance, known as Protective 
Action Guides (PAG), to protect the public from exposure to radiation. 
In addition, the Department of Homeland Security (DHS) issued PAGs for 
responses to RDD and improvised nuclear devices (IND) for interim use 
and comment. Both EPA's and DHS's PAGs can be used by other federal 
agencies or state governments to develop their own guidance or 
regulations to protect public health. According to EPA officials, the 
general public's fear of radiation, coupled with most law enforcement 
officers' relative inexperience dealing with radioactive material, 
would likely cause any emergency incident that triggers first 
responders' radiation detectors to be treated as an RDD. Until the type 
and specific quantity of radioactive material could be determined, the 
situation would initiate a federal response, whether or not specific, 
federal thresholds for safety have been reached. Even very small 
amounts of radioactive material are sufficient to set off the radiation 
detectors of first responders. 

For purposes of illustration (see table 3), we calculated how large an 
area might be sufficiently contaminated using International Atomic 
Energy Agency (IAEA) category 1, 2, and 3 quantities of cesium-137-- 
assuming the material could be evenly distributed--to (1) trigger the 
EPA PAG recommending relocation of the public until the site is cleaned 
up and (2) reach the threshold at which potential direct health 
effects, such as radiation sickness, might occur. We used category 2 
and 3 amounts of cesium-137 (one of the 16 radionuclides of concern) 
because, according to the International Atomic Energy Agency 
categorization scheme, the threshold category 3 quantity is the amount 
at which a radionuclide becomes potentially dangerous to human health 
if not handled appropriately. A category 2 quantity of a radioactive 
material is at least 10 times more dangerous than the category 3 
threshold quantity and is also the level at which NRC requires 
licensees to take additional security measures to protect the material 
from unauthorized access or use. We calculated how large an area might 
be contaminated with a category 1 quantity of cesium-137 because such 
quantities can be found in medical devices and irradiators throughout 
the United States. 

Table 3: Potential Contamination from an RDD: 

Thresholds for concern (based on 1 year of exposure): 
Amount of radioactive material (cesium-137): 
* Category 3 threshold (2.7 curies); 
* Category 2 threshold (27 curies); 
* Category 1 threshold (2,700 curies). 

EPA recommends relocation (2 rem)[A]: 
Amount of radioactive material (cesium-137): 
* Category 1: 15.1 acres; 
* Category 2: 150.7 acres; 
* Category 3: 15,012 acres. 

Potential observable health effects (100 rem); 
Amount of radioactive material (cesium-137): 
* Category 1: 0.3 acre; 
* Category 2: 3 acres; 
* Category 3: 300 acres. 

Source: GAO. 

Notes: Calculations based on the Department of Energy's Federal 
Regulatory Monitoring and Assessment Center dose assessment 
methodology. The potential area contamination figures assume uniform 
ground deposition of radioactive material, which is difficult to 
accomplish and may not be realistic. 

[A] A rem is a term scientists use to describe how much radiation the 
body absorbs, multiplied by a quality factor for the various types of 
radiation (e.g., alpha, beta, gamma, or neutron). For example, 
scientists estimate that the average person receives 360 millirem (0.36 
rem) every year from natural (such as radon gas) and manufactured 
radiation sources (such as exposure to radioactive isotopes used in 
some medical procedures). 

[End of table] 

Specifically, when the potential additional exposure to radiation for a 
person remaining in a given area for 1 year reaches 2 rem, EPA 
considers the area sufficiently dangerous to recommend that people be 
relocated until the site can be decontaminated. When the potential 
exposure to radiation over the course of 1 year reaches 100 rem, the 
International Commission on Radiological Protection--an organization of 
radiation scientists from around the world who provide recommendations 
regarding radiation exposure--concludes that readily observable health 
effects, such as radiation sickness, are possible with extended 
exposure. Only a category 1 quantity would be likely to produce health 
effects due to acute radiation doses. This level, however, is still 
substantially below the level at which prompt fatalities could occur. 
(Prompt fatalities from untreated radiation exposure may only result 
from acute radiation doses--that is, doses delivered in their entirety 
in a matter of hours or days--of at least hundreds of rem from a 
predominately beta-gamma emitting radionuclide like cesium-137.) 

EPA guidance is based on protecting human health and calculating the 
odds that radiation exposure will lead to cancer, the most common of 
radiation's long term side effects. In the event of an RDD, federal RDD 
PAGs, such as those issued by DHS in 2006, would be used to manage the 
response to the incident. PAGs are operative during the emergency, and 
their chief goal is to protect the public by providing standards to 
guide the response in the early and intermediate phases of an incident. 
However, any PAG guidance is only a series of recommendations and is 
not legally enforceable or binding. 

Furthermore, a PAG does not establish cleanup levels. In fact, guidance 
for specific cleanup levels after an RDD has been deliberately left ad 
hoc, and is to be established after an evaluation occurs using an 
"optimization" process for long-term site cleanup and restoration. The 
level to which a contaminated site would be cleaned up for the long 
term would be agreed upon after the emergency has passed and would 
depend on the uses of the site. A cleanup standard would factor in the 
lifetime exposure that the contamination creates for the people using 
the site--generally, the long-term increased risk of developing cancer. 
For example, a site that is used for business purposes, where the 
typical person would spend only working hours, would not have to be 
cleaned up to the same level as a site where people live, where some 
people could reasonably be exposed to the post-cleanup radiation levels 
24 hours a day. Public involvement in the decision would play a 
significant role in determining what risk levels are acceptable. While 
EPA provides guidelines, state and local authorities make the ultimate 
decisions under most scenarios. 

[End of section] 

Appendix II: Comments from the Nuclear Regulatory Commission: 

United States Nuclear Regulatory Commission: 
Washington, DC 20565-0001: 

May 28, 2008: 

Mr. Gene Aloise, Director: 
Natural Resources and Environment: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, D.C. 20548: 

Dear Mr. Aloise: 

On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am 
responding to your e-mail dated April 21, 2008, requesting NRC review 
and comment on your draft report, "Nuclear Security: NRC and DHS Need 
to Take Additional Steps to Better Track and Detect Radioactive 
Materials" (GAO-08-598). I appreciate you providing the NRC the 
opportunity to review this draft report and the time and effort that 
you and your staff have invested in reviewing this important topic. 

NRC's leadership role in applying a risk-based approach has enhanced 
security of radioactive materials and has reduced the potential threat 
from a radiological dispersal device (RDD) or radiological exposure 
device. As a result, these materials are significantly more secure than 
before the events of September 11, 2001. NRC is working closely with 
its domestic and international partners to continuously assess, 
integrate, and improve its security programs to make risk-significant 
radiation sources more secure and less vulnerable to terrorists. 

Specifically, the U.S. Government Accountability Office (GAO) noted 
that the NRC has made limited progress toward implementing 3 of the 6 
recommendations in the 2003 report on security of radioactive sources. 
The GAO recommended that the NRC: (1) modify its process for issuing 
licenses to ensure that radioactive materials cannot be purchased by 
individuals with no legitimate need for them; (2) determine how to 
effectively mitigate the potential psychological effects of malicious 
use of such materials; and (3) examine whether certain radioactive 
sources should be subject to more stringent regulations. With regard to 
these recommendations, the NRC and its Federal and Agreement State 
partners have made and are making significant progress towards 
achieving these goals. 

Beginning in January 2008, the NRC has modified its licensing process 
and now conducts pre-licensing site visits for all unknown applicants 
before issuing new licenses. The new procedure was tested in a pilot 
project with the Agreement States. The procedure will be revised based 
on comments received from licensing reviewers in the NRC Regions and 
the Agreement States as a result of the pilot project. These actions 
are aiding in the prevention of illegitimate purchases of radioactive 
materials. 

The NRC is working with its Federal and Agreement State partners to 
address the issue of mitigation of potential psychological effects of 
an RDD through the Radiation Source Protection and Security Task 
Force's (Task Force) subgroup on public education, which is chaired by 
the Department of Homeland Security. As noted in their December 2007 
Draft Public Education Action Plan, proactively educating the public 
about radiation in general and the specific radiation risks associated 
with RDDs may reduce the public's anxiety and ameliorate adverse 
psychological impacts in the event of an RDD attack. This plan was 
presented to the Task Force on May 15, 2008. 

Additionally, the Task Force has reactivated the radiation sources 
subgroup to reevaluate the list of radioactive sources that warrant 
enhanced security and protection. The subgroup's proposed evaluation 
will take economic, physical, psychological, and social disruption 
consequences into consideration. The results will be presented to the 
Task Force by November 2008. The combined work planned by these two 
subgroups will address mitigation of psychological impacts of a RDD and 
address whether enhanced security measures may be warranted for certain 
radioactive materials. 

With regard to whether generally licensed radioactive sources should be 
subject to more stringent regulations, the NRC formed a rulemaking 
working group which included State representatives in September 2007, 
to consider which sources should be specifically licensed. The working 
group has drafted a proposed rule to limit the quantity of radioactive 
material allowed in a generally licensed device. The draft proposed 
rule is currently being reviewed by the NRC and the Agreement States 
and is expected to be issued for public comment this fall. The final 
rule is projected to be issued in fall 2009. 

In addition to providing a status update on the NRC's progress in 
implementing the recommendations from the 2003 report, the GAO also 
recommended that the Chairman of the NRC take steps, consistent with 
sound systems development practices, to: (1) ensure that priority 
attention is given to meeting the current January and October 2009 
target dates for launching the National Source Tracking System (NSTS) 
and Web-based Licensing (WBL) System, respectively, and (2) complete 
the needed steps to include all potentially dangerous radioactive 
sources in the NSTS as quickly as is reasonably possible. 

With regard to the GAO's recommendation that the NRC take steps to 
ensure that priority attention is given to meeting the current January 
and October 2009 target dates for launching the NSTS and WBL systems, I 
want to assure you that the Commission has placed a high priority in 
the deployment of these systems. In accordance with Office of 
Management and Budget guidance, the NRC has employed sound system 
development practices. The NRC has: (1) assigned professionally 
certified project managers to both NSTS and WBL; (2) set reasonable 
performance baselines and integrated project schedules for both NSTS 
and WBL; and (3) employed earned value management on the NSTS project 
and wilt employ it on the WBL project once a contract is in place. The 
NSTS is on schedule for deployment in January 2009. Additionally, a 
proposed rule has been issued for public comment, which would expand 
NSTS beyond Category 2 sources to include Category 3 and 1/10th of the 
Category 3 threshold values. The final rule is projected to be issued 
in early 2009. The October 2009 target date for WBL deployment was 
based upon having a contract awarded and a preliminary estimate of 
remaining work. The NRC has encountered delays in awarding the 
contract, which are based on changing scope and requirements to meet 
current programmatic needs. NRC's goal is to have the contract awarded 
by late summer 2008 and to have the system deployed 24 months later. 

Enclosed are additional comments related to enhancing the clarity and 
accuracy of statements in the body of the report. Should you have any 
questions about these comments, please contact Mr. Jesse Arildsen of my 
staff at (301) 415-1785. 

Sincerely, 

Signed by: 

R.W. Borchardt: 
Executive Director for Operations 

Enclosure: 

NRC Comments on the GAO's Draft Report, "Nuclear Security: NRC and DHS 
Need to Take Additional Steps to Better Track and Detect Radioactive 
Materials" (GAO-08-598). 

[End of section] 

Appendix III: Comments from the Department of Homeland Security: 

U.S. Department of Homeland Security: 
[hyperlink, http://www.dhs.gov]: 
Washington, DC 20528: 

June 2, 2008: 

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

Dear Mr. Aloise: 

Thank you for providing us with a copy of the draft report entitled 
"Nuclear Security: NRC and DHS Need to Take Additional Steps to Better 
Track and Detect Radioactive Materials" (GAO-08-598) where GAO was 
requested to assess: 1) the progress NRC has made in implementing 2003 
recommendations; 2) other steps NRC has taken to improve its ability to 
track radioactive materials; 3) Customs and Border Protection's (CBP's) 
ability to detect radioactive materials at land ports of entry; and 4) 
CBP's ability to verify that such materials are appropriately licensed 
before they are allowed to enter the United States. 

CBP concurs with GAO's recommendation that CBP effectively communicate 
current CBP guidance to officers at ports of entry regarding when they 
are required to call the National Targeting Center to verify the 
legitimacy of radioactive materials; and take measures to ensure that 
this guidance is being followed. 

CBP will: 

1) Issue guidance to officers at ports of entry regarding when they are 
required to call the National Targeting Center to verify the legitimacy 
of radioactive materials. 

2) Have all field offices ensure that the port's Standard Operating 
Procedures include the guidance. 

Due Date: March 31, 2009. 

We thank you again for the opportunity to review the draft report and 
provide comments. 

Sincerely, 

Signed by: 
Penelope G. McCormack: 
Acting Director: 
Departmental GAO/OIG Liaison Office: 

[End of section] 

Appendix IV: Comments from the Organization of Agreement States: 

Organization of Agreement States: 
Cindy Cardwell, Chair, Texas: 
Julia Schmitt, Chair-Elect, Nebraska: 
Paul Schmidt, Past Chair, Wisconsin: 
Tom Conley, Treasurer, Kansas: 
Isabelle Busenitz, Secretary, Kansas: 
Lee Cox, Director, North Carolina: 
Ann Troxler, Director, Louisiana: 

May 27, 2008: 

Gene Aloise: 
Director, Natural Resources and Environment: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Aloise: 

Please accept the comments below on behalf of the Board of the 
Organization of Agreement States on the draft report on Nuclear 
Security, which you provided to us during the week of April 21, 2008 
and for the statement of facts provided to us in March. We've noted the 
changes from the earlier document to this one. 

In the section of the report beginning on page 18, which discusses 
GAO's ability to obtain a license from NRC for a false company, no 
mention is made of GAO's attempt to obtain a license from an Agreement 
State. GAO subsequently abandoned that attempt when the licensing 
process of the Agreement State was made known. The Agreement States 
believe this is very significant, not only because an Agreement State's 
actions caused such an attempt to be abandoned, but because this points 
out the very real fact that the licensing process may indeed differ. 
Agreement State programs may go to different lengths in verifications 
made during the licensing process. So, the fact that GAO obtained a 
license from one regulatory agency is not indicative that the same 
would happen with any other regulatory agency. 

Although collaboration between NRC and the Agreement States is 
mentioned several times throughout the report, we do not believe this 
point is emphasized enough. Currently, there are an unprecedented 
number of security-related working groups involving NRC and Agreement 
State staff members. The fact that the states are able to obtain 
volunteers to work on all of these working groups and that NRC is 
funding the travel involved with such efforts, is a testament to our 
belief in the importance of ensuring security of radioactive material 
in this country. 

We appreciate the opportunity to review the report and provide 
comments. Thank you for your patience. 

Sincerely, 

Signed by: 

Cindy Cardwell, Chair: 
Organization of Agreement States: 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Gene Aloise, (202) 512-3841 or [email protected]: 

Staff Acknowledgments: 

In addition to the contact named above, Ned Woodward, Nabajyoti 
Barkakati, Kevin Bray, Ryan Coles, Nancy Crothers, Walker Fullerton, 
Cindy Gilbert, Richard Hung, Carol Kolarik, Keith Rhodes, and Kevin 
Tarmann made significant contributions to this report. 

[End of section] 

Footnotes: 

[1] Sandia National Laboratories, located in Albuquerque, New Mexico, 
and Livermore, California, are 2 of the more than 20 national 
laboratories and technology centers overseen by DOE. 

[2] A radionuclide is an unstable, radiation-emitting nuclide. A 
nuclide is a particular atomic form of an element distinguished from 
other nuclides by its number of neutrons and protons, as well as by the 
amount of energy it contains. Every known element has multiple 
(radio)nuclides. For example, cesium has many radionuclides, and each 
is suited to different purposes--cesium-133 is used in atomic clocks, 
and cesium-137 is used as an irradiator to sterilize blood and in other 
medical radiation devices for treating cancer. 

[3] The IAEA Safety Guide #RS-G-1.9, "Categorization of Radioactive 
Sources," details the underlying methodology for the five-category 
scheme. 

[4] Direct, or nonprobabilistic, human health effects are readily 
observable, may be acute, and are, accordingly, more severe than the 
elevated risk of a future health effect, such as cancer. 

[5] CBP is the unified border agency within DHS. CBP combines the 
inspectional workforces and broad border authorities of the former U.S. 
Customs Service, U.S. Immigration and Naturalization Service, Animal 
and Plant Health Inspection Service, and the entire U.S. Border Patrol. 

[6] GAO, Nuclear Security: Federal and State Action Needed to Improve 
Security of Sealed Radioactive Sources, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-03-804] (Washington, D.C.: Aug. 
6, 2003). 

[7] GAO, Combating Nuclear Smuggling: DHS Has Made Progress Deploying 
Radiation Detection Equipment at U.S. Ports-of-Entry, but Concerns 
Remain, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-389] 
(Washington, D.C.: Mar. 22, 2006). 

[8] GAO, Border Security: Investigators Successfully Transported 
Radioactive Sources across Our Nation's Borders at Selected Locations, 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-545R] (Washington, 
D.C.: Mar. 28, 2006). 

[9] GAO, Nuclear Security: Actions Taken by NRC to Strengthen Its 
Licensing Process for Sealed Radioactive Sources Are Not Effective, 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-1038T] 
(Washington, D.C.: July 12, 2007). 

[10] Results from a nonprobability sample cannot be used to make 
inferences about a population because, in a nonprobability sample, some 
elements of the population being studied have no chance or an unknown 
chance of being selected as part of the sample. 

[11] NRC implemented IMPEP in 1995 to evaluate NRC's regional materials 
program and the agreement state radiation control programs using 
evaluation criteria, known as performance indicators, to ensure 
consistency in the nation's materials safety program. Reviews are 
conducted jointly by the Office of Federal and State Materials and 
Environmental Management Program staff, with agreement state and 
regional representatives usually on the team. Approximately 10 to 12 
reviews are scheduled each year. NRC regions are normally reviewed 
every 2 years, and agreement states every 2 to 4 years--the timeline 
may be adjusted depending on past performance. 

[12] GAO investigators made a similar application for a radioactive 
materials license to an agreement state but withdrew the application 
when the agreement state official informed GAO investigators that it 
would require a site visit to the applicant's place of business--a step 
that would have revealed the application not to be authentic. 

[13] See National Response Framework, "Emergency Support Function #10- 
Oil and Hazardous Material Response," p. 14, and Nuclear/Radiological 
Incident Annex, p. NUC-3 and table 1. 

[14] The Health Physics Society is a scientific and professional 
organization whose members specialize in occupational and environmental 
radiation safety. The society supports its members in the practice of 
their profession and also, among other things, promotes public 
information preparation and dissemination, education and training 
opportunities, and scientific information exchange through conferences 
and meetings, [hyperlink, http://hps.org/aboutthesociety/] (accessed 
April 17, 2008). 

[15] NRC has gathered information from licensees of category 1 through 
3 and the most dangerous category 4 sources. Under the IAEA 
categorization scheme, any source containing category 3 or greater 
quantities of radioactive materials could be dangerous to human health 
if not handled properly. 

[16] During the first year of the interim database, information on some 
category 3 sources that were aggregated in quantities large enough to 
be considered a category 2 quantity were also recorded. However, the 
difficulty in defining what constituted collocated/aggregated or 
separate sources made recording aggregated category 2 quantities 
extremely difficult and such information was no longer collected after 
the first year of implementation. For example, keeping a larger number 
of category 3 sources divided among locked barriers of a certain 
security level may allow some such material at the same facility not to 
be reported as collocated and not subject to the aggregation rules that 
would require it to be reported as a category 2 quantity. 

[17] An NRC rule creating the NSTS and certain provisions for the 
system are required by the Energy Policy Act of 2005. The final rule 
(issued under NRC's authority to regulate radioactive materials for 
public health and safety, an authority shared with the agreement 
states) requiring that licensees report to the NSTS and requiring the 
issuance of unique source serial numbers was published in the Federal 
Register on November 8, 2006. NRC has since modified the rule and now 
requires reporting to the NSTS by January 31, 2009. 

[18] NRC opted to include these four additional radionuclides that NRC 
deems of concern for RDD purposes in the NSTS at DOE request. Although 
NRC and agreement state licensees do not possess large numbers of 
sources containing these radionuclides, and none with category 2 or 
higher quantities, DOE might. 

[19] The activity data for a given source may be reported as of the 
manufacture date or assay date. Because all radioactive materials decay 
over time, an up-to-date estimation of the activity level will be 
calculated, if needed, by the system. 

[20] According to CBP officials, 91 percent of all personal vehicles 
arriving in the United States are scanned by radiation portal monitors. 
In addition, 100 percent of truck cargo arriving from Mexico and 91 
percent arriving from Canada are scanned by portal monitors. 

[21] NRC provides the National Targeting Center with up-to-date 
information concerning the licensing, import, and export of all 
regulated radioactive materials and sources in the United States. This 
cooperation gives CBP indirect access to NRC and agreement state 
licensing databases; NRC's list of licensees authorized to import or 
export radioactive materials and sources; and advanced notification of 
large, category 1 radioactive materials shipments. 

[22] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-389] and 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-545R]. 

[End of section] 

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