Radiological Sources in Iraq
DOD Should Evaluate Its Source Recovery Effort and Apply Lessons Learned to Future Recovery Missions Gao ID: GAO-05-672 September 7, 2005Following the invasion of Iraq in March 2003, concerns were raised about the security of Iraq's radiological sources. Such sources are used in medicine, industry, and research, but unsecured sources could pose risks of radiation exposure, and terrorists could use them to make "dirty bombs." This report provides information on (1) the readiness of the Department of Defense (DOD) to collect and secure sources, (2) the number of sources DOD collected and secured, (3) U.S. assistance to help regulate sources in Iraq, and (4) the lessons DOD and the Department of Energy learned.
DOD was not ready to collect and secure radiological sources when the war began in March 2003 and for about 6 months thereafter. Before DOD could collect radiological sources, it had to specify criteria for which sources should be collected and how to safely collect them, coordinate within DOD, coordinate assistance from the Department of Energy (DOE), and resolve contract issues. DOD did not issue guidance for collecting and securing sources until July 2003 and did not finalize the terms of the contract to collect sources until September 2003. Until radiological sources could be collected, some sources were looted and scattered, and some troops were diverted from their regular combat duties to guard sources in diverse places. In June 2004, DOD removed about 1,000 of the 1,400 radiological sources collected in Iraq and sent them to the United States for disposal. DOD left in place approximately 700 additional sources that it had judged were adequately secured and being used properly by Iraqis. According to DOD and Department of State officials, however, the total number of radiological sources in Iraq remains unknown. The United States assisted in establishing an Iraqi agency to regulate radiological sources. Since June 2004, State and DOE have helped this new agency develop an action plan with assistance from the International Atomic Energy Agency. However, according to State officials, because of uncertainties associated with the continuing formation of the Iraqi government, State will have to monitor Iraqi efforts to ensure the continued growth and success of an independent, competent, and sustainable regulatory authority for the control of radioactive sources and materials. Both DOD and DOE are considering improvements based on their Iraq experiences. A 2004 study of lessons learned, requested by DOD, recommended that DOD develop the capability to quickly eliminate weapons of mass destruction in hostile environments, but it did not focus on the narrower radiological source mission. In contrast, DOE has contracted for a study to examine lessons from its role in removing radiological sources from Iraq.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-05-672, Radiological Sources in Iraq: DOD Should Evaluate Its Source Recovery Effort and Apply Lessons Learned to Future Recovery Missions
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Report to Congressional Committees:
September 2005:
Radiological Sources in Iraq:
DOD Should Evaluate Its Source Recovery Effort and Apply Lessons
Learned to Future Recovery Missions:
GAO-05-672:
GAO Highlights:
Highlights of GAO-05-672, a report to the Senate and House Committees
on Armed Services:
Why GAO Did This Study:
Following the invasion of Iraq in March 2003, concerns were raised
about the security of Iraq‘s radiological sources. Such sources are
used in medicine, industry, and research, but unsecured sources could
pose risks of radiation exposure, and terrorists could use them to make
’dirty bombs.“ This report provides information on (1) the readiness of
the Department of Defense (DOD) to collect and secure sources, (2) the
number of sources DOD collected and secured, (3) U.S. assistance to
help regulate sources in Iraq, and (4) the lessons DOD and the
Department of Energy learned.
What GAO Found:
DOD was not ready to collect and secure radiological sources when the
war began in March 2003 and for about 6 months thereafter. Before DOD
could collect radiological sources, it had to specify criteria for
which sources should be collected and how to safely collect them,
coordinate within DOD, coordinate assistance from the Department of
Energy (DOE), and resolve contract issues. DOD did not issue guidance
for collecting and securing sources until July 2003 and did not
finalize the terms of the contract to collect sources until September
2003. Until radiological sources could be collected, some sources were
looted and scattered, and some troops were diverted from their regular
combat duties to guard sources in diverse places.
In June 2004, DOD removed about 1,000 of the 1,400 radiological sources
collected in Iraq and sent them to the United States for disposal. DOD
left in place approximately 700 additional sources that it had judged
were adequately secured and being used properly by Iraqis. According to
DOD and Department of State officials, however, the total number of
radiological sources in Iraq remains unknown.
The United States assisted in establishing an Iraqi agency to regulate
radiological sources. Since June 2004, State and DOE have helped this
new agency develop an action plan with assistance from the
International Atomic Energy Agency. However, according to State
officials, because of uncertainties associated with the continuing
formation of the Iraqi government, State will have to monitor Iraqi
efforts to ensure the continued growth and success of an independent,
competent, and sustainable regulatory authority for the control of
radioactive sources and materials.
Both DOD and DOE are considering improvements based on their Iraq
experiences. A 2004 study of lessons learned, requested by DOD,
recommended that DOD develop the capability to quickly eliminate
weapons of mass destruction in hostile environments, but it did not
focus on the narrower radiological source mission. In contrast, DOE has
contracted for a study to examine lessons from its role in removing
radiological sources from Iraq.
Bunker Where DOD Secured Radiological Sources, Tuwaitha, Iraq:
[See PDF for image]
[End of figure]
What GAO Recommends:
GAO recommends, among other things, that DOD (1) assess lessons learned
from securing sources in Iraq and (2) ensure that advanced planning
occurs prior to any future missions. DOD concurred or partially
concurred with most of our recommendations and did not concur with two
of them, stating that our report focused on the later phase of source
recovery and that it accepted our recommendations for that phase. Our
recommendations apply to all phases of the effort and we revised some
to clarify this. The Department of State provided clarifications
regarding U.S. assistance to Iraq and reasons for a delay in approval
of export licensing. DOE had no written comments but stated it would
work with DOD to help define sources of greatest risk.
www.gao.gov/cgi-bin/getrpt?GAO-05-672.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Gene Aloise at (202) 512-
3841 or aloisee@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
DOD Was Not Ready to Collect and Secure Radiological Sources in Iraq at
the Start of the Hostilities in March 2003:
DTRA Recovered or Left Secure in Place about 2,100 Radiological
Sources, but the Number of Unsecured Sources Remaining in Iraq Is
Unknown:
The United States Helped Create an Iraqi Agency to Regulate Sources,
but Future Assistance Is Uncertain:
DOD Has Not Assessed Its Source Recovery Effort, but DOE Is Considering
Lessons Learned:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Scope and Methodology:
Appendix II: The National Defense University Study:
Appendix III: Comments from the Department of Defense:
Appendix IV: Comments from the Department of State:
Appendix V: GAO Contact and Staff Acknowledgments:
Figures:
Figure 1: An Intact Pillar and a Looted Metal Pillar That Contained
Cobalt Sources:
Figure 2: Sites from Which Unsecured Sources Were Collected:
Figure 3: Bunker Where DTRA Secured Radiological Sources, Tuwaitha,
Iraq:
Figure 4: Number of DTRA Contractor Missions and Number of Insurgent
Attacks throughout Iraq, June 2003 to May 2004:
Figure 5: Protected Living Area for DOE Experts at the Tuwaitha Nuclear
Research Center:
Abbreviations:
DOD: Department of Defense:
DOE: Department of Energy:
DTRA: Defense Threat Reduction Agency:
IAEA: International Atomic Energy Agency:
IRSRA: Iraqi Radiological Source Regulatory Authority:
MOST: Ministry of Science and Technology (Iraq):
NDU: National Defense University::
WMD: weapons of mass destruction:
Letter September 7, 2005:
The Honorable John Warner:
Chairman:
The Honorable Carl Levin:
Ranking Minority Member:
Committee on Armed Services:
United States Senate:
The Honorable Duncan Hunter:
Chairman:
The Honorable Ike Skelton:
Ranking Minority Member:
Committee on Armed Services:
House of Representatives:
In March 2003, citing the failure of Iraq to live up to agreements to
disarm itself of weapons of mass destruction (WMD), and other concerns,
the United States and its coalition allies invaded Iraq. This conflict
is known as Operation Iraqi Freedom. During late 2002 and early 2003,
the U.S. Department of Defense (DOD) had made plans to find and
eliminate the suspected WMD. DOD's Defense Threat Reduction Agency
(DTRA) was to be responsible for hiring a contractor to dispose of WMD
and their component materials, such as biological agents, chemicals,
and radioactive materials.[Footnote 1] The radioactive materials
included (1) nuclear materials, such as processed uranium, which could
be used in a nuclear weapon, and (2) radiological sources, which are
widely used throughout the world in medicine, agriculture, research,
and industry and could be combined with conventional explosives to
create a radiological dispersion device, a weapon known as a "dirty
bomb." Thus, DOD's plan to eliminate WMD included the removal of
radiological sources, which are not weapons but could be improvised by
terrorists into dirty bombs.
The Department of Energy (DOE) and Department of State also had
responsibilities in the mission to secure radiological sources in Iraq.
By early 2003, DOD was planning for DOE to be involved in both removing
and disposing of sources from Iraq. After the transfer of power from
the Coalition Provisional Authority[Footnote 2] to the interim Iraqi
government in June 2004, State had lead responsibility for helping Iraq
regulate the radiological sources remaining in the country.
Although the United States did not find stockpiles of WMD in Iraq, U.S.
forces found partially processed uranium and radiological sources that
the International Atomic Energy Agency (IAEA) had previously secured at
nuclear facilities. In addition, U.S. forces found radiological sources
throughout Iraq, many of which were unsecured and in danger of being
looted. Citing media reports of looting at nuclear sites, IAEA and
Members of the Congress raised concerns about the security of nuclear
materials and radiological sources. Reflecting these concerns, during a
July 2003 Senate Armed Services hearing, the Ranking Minority Member of
the Readiness and Management Support Subcommittee asked the Secretary
of Defense about the security of radiological sources in Iraq. DOD
replied in a January 2004 letter that numerous sources had been
collected and that efforts were under way to identify and secure
others.
Shortly thereafter, the Ranking Minority Member's office asked us for
an update on the security of radiological sources in Iraq, and we
initiated a review of the effort to collect and secure these sources.
Because of the broad interest in this issue, we conducted this work
under the authority of the Comptroller General and are issuing this
report to the Senate and House Committees on Armed Services. This
report (1) assesses DOD readiness to collect and secure radiological
sources in Iraq from the start of the 2003 war; (2) presents
information on the number of radiological sources DTRA had secured by
the time of the June 2004 transition to the interim Iraqi government;
(3) describes the assistance the United States has provided, and plans
to provide in the future, to the Iraqi government to help regulate
radiological sources in Iraq; and (4) examines DOD and DOE actions to
assess their experiences in Iraq and apply any lessons learned to
possible future radiological source collection missions.
To assess DOD's readiness to collect and secure radiological sources,
we reviewed available policy guidance and reports on individual
missions to collect sources and interviewed DOD and contractor
officials. To present information on the number of radiological sources
secured, we reviewed DOD inventories of sources left in Iraq and
sources collected, interviewed officials about the reliability of these
inventories, and reviewed available mission guidance and other
documents. We assessed the reliability of DTRA's inventories of
radiological sources, including independently corroborating the
information when possible, based on discussions with those responsible
for the inventories. With one exception, we determined that the data
were sufficiently reliable for the purposes of this report. To describe
U.S. efforts to help the interim Iraqi government regulate sources, we
examined the Department of State's planning documents and a Coalition
Provisional Authority order to establish an Iraqi agency to regulate
radiological sources. We also discussed plans for assistance with State
and DOE officials as well as with Iraqi officials visiting the United
States. Finally, to describe what DOD and DOE have done to learn from
their experience in Iraq, and how such lessons might be applied in the
future, we interviewed DOD and DOE officials about their efforts to
identify and document lessons learned and examined draft and published
documents on the mission to dispose of Iraqi WMD. Because of the
continuing hostilities, we did not travel to Iraq. We performed our
work from May 2004 through August 2005 in accordance with generally
accepted government auditing standards. Details of our methodology are
provided in appendix I.
Results in Brief:
DOD was not ready to collect and secure radiological sources when the
war began in March 2003 and for about 6 months thereafter. Although
DOD's prewar plan included removing radiological sources from Iraq, DOD
did not issue guidance for collecting and securing them until July 2003
and did not finalize the terms of the contract that would allow the
radiological sources to be collected and secured until September 2003,
6 months after the beginning of the war. During this 6-month period,
individual military commanders, who possessed limited equipment to
handle the radiological sources they were finding, had to make
decisions regarding which radiological sources should be secured and
how to safely collect them. Illustrating the readiness problems, one
commander, lacking the proper equipment, had to move highly radioactive
sources with an ice cooler that was lined with lead bricks. In other
instances, troops were diverted from their regular combat duties to
guard unsecured radiological sources at various places around the
country until the sources could be properly packaged and removed.
According to one officer, field commanders were concerned that their
troops guarding sources in some places were placed at greater risk for
enemy attack. In addition, the scattering of radiological sources by
looters complicated their collection. DTRA was responsible for
collecting radiological sources in Iraq. However, DTRA officials
explained that collecting these sources only gradually became a mission
focus as it became clear that the broader hunt for WMD was
unsuccessful. Furthermore, before DTRA could collect radiological
sources, it had to specify criteria regarding which sources should be
collected and how to safely collect them, coordinate within DOD for
armed protection for DTRA's contractor as they sought radiological
sources, coordinate assistance from DOE, and resolve legal liability
issues regarding potential damages resulting from its contractor's work
to collect the radioactive sources.
By the end of June 2004, DTRA had removed about 1,000 of 1,400
collected radiological sources from Iraq and sent them to the United
States. DTRA left in place approximately 700 additional sources that it
had judged were adequately secured and being used properly by Iraqis--
for example, for industrial and medical purposes. According to DOD and
State officials, however, the total number of unsecured radiological
sources in Iraq remains unknown. For instance, even after DTRA
completed collecting and securing sources, according to Department of
State officials, a neighboring country twice detected trucks leaving
Iraq with unsecured radiological sources. Despite the difficulties
encountered in collecting and securing radiological sources in Iraq
during ongoing hostilities, according to DOD officials, DTRA and its
contractor successfully carried out about 140 collection missions
without fatalities or severe exposure to radiation. However, for the
removal of sources from Iraq, DOE had difficulty obtaining accurate
information from DOD regarding the type and radioactivity of the
sources. DOE needed this information to determine the type and number
of transportation containers needed to remove the sources. According to
DOE officials, the final disposition of the radiological materials
removed from Iraq may take longer and cost more than estimated because
a legal determination is needed regarding whether the United States
government owns the material or is merely serving as its custodian.
According to these officials, they raised this issue of ownership when
the removal mission was being planned, but it was never resolved.
The United States assisted in establishing an Iraqi agency to regulate
radiological sources. The Department of State worked with the Coalition
Provisional Authority and later with the interim government to create
an Iraqi agency to regulate radiological sources, the Iraqi
Radiological Source Regulatory Agency. In addition, State developed
budget and organizational plans for the regulatory agency and shared
them with Iraqi officials appointed by the Coalition Provisional
Authority. Since the political transition to the interim Iraqi
government in June 2004, State has helped to firmly establish the
agency by facilitating the transfer of DTRA equipment to the new
government and, with funding support from DOE, coordinating meetings
between Iraqi officials and the IAEA to create an action plan. Further,
State, DOE, and IAEA have agreed to offer additional technical and
financial support in such areas as regulation writing, border control,
and security upgrades. However, according to State officials, because
of uncertainties associated with the continuing formation of the Iraqi
government, State will have to monitor Iraqi efforts to ensure the
continued growth and success of an independent, competent, and
sustainable regulatory authority for the control of radioactive sources
and materials.
Both DOD and DOE are considering improvements based on their Iraq
experiences. However, DOD's assessment focuses on its intended WMD
mission rather than on the radiological source mission. DOD requested a
study from its National Defense University to assess lessons learned
from the WMD mission in Iraq and to recommend improvements for possible
future missions. The resulting report did not offer any observations or
recommendations regarding the mission to collect and secure
radiological sources in Iraq. However, it stated that DOD had not
sufficiently planned and prepared for the WMD mission; had shortfalls
in the needed transportation, military security, and logistics
resources; and had operational difficulties because of the extensive
looting, public disorder, and hostile security environment. The report
recommended that DOD develop the capability to quickly eliminate WMD in
hostile environments and develop a permanent organization to eliminate
WMD. Consistent with this recommendation, DOD assigned its Strategic
Command responsibility for planning and ensuring the capacity for
possible future missions to eliminate WMD, which a DOD Joint Staff
officer told us would include the elimination of radiological sealed
sources. In contrast to DOD's focus on the WMD mission, DOE has
contracted for a study to examine lessons from its radiological source
removal mission. DOE considered establishing a reserve of equipment to
handle and package radiological material to ensure rapid action in the
future but decided that it could not proceed because of current budget
constraints.
To ensure that problems experienced with collecting and securing
radiological sources in Iraq are avoided to the extent possible in
future missions, we are recommending that the Secretary of Defense,
among other things, ensure that planning for such missions is completed
prior to their initiation. Such planning should include developing
specific guidance for collecting and securing radiological sources and
coordinating any needed assistance with DOE. Furthermore, we are
recommending that the Secretary of Defense comprehensively review DOD's
experience with collecting and securing radiological sources in Iraq
for lessons learned to apply to possible future missions.
We provided the Departments of Defense, State, and Energy with draft
copies of this report for their review and comment. DOD concurred or
partially concurred with most of our recommendations and did not concur
with two of them, stating that our report focused on the later phase of
source recovery and that it accepted our recommendations for that
phase. Our recommendations apply to all phases of the effort and we
revised some recommendations to clarify this. We also incorporated into
the report State's clarifications of (1) its current outlook for U.S.
assistance to Iraq on radioactive source regulation and (2) the reason
for the delay in State's approval of export licensing. DOE had no
written comments on the report but did state that it will work with DOD
to determine criteria to define which radiological sources are of
greatest risk.
Background:
Widespread looting--including looting of radiological sources--became a
major problem in Iraq after the March 2003 coalition forces invasion,
complicating U.S. efforts to secure and collect radiological sources.
Media reports of the looting at Iraq's Tuwaitha Nuclear Research
Center, for example, brought public attention to the scattering of
radioactive materials throughout populated areas, posing health and
safety risks to Iraqis. In May 2003, the IAEA, which had inventoried
nuclear and radiological materials at Tuwaitha, raised concerns about
Iraqi citizens' exposure to radiation and publicly asked the United
States to secure these materials.
Given the extensive looting, DOD could not assume that facilities and
items within them, including radiological sources, would remain intact
or in place for later collection without being secured. Many facilities
that were no longer under the control of Iraqis, such as abandoned
government research facilities and industrial complexes, were looted.
For example, a 2004 government report on the search for WMD stated that
looters often destroyed sites after a coalition military unit moved
through an area, since the coalition did not have the forces available
to secure the various sites thought to be associated with WMD.
According to one DTRA official, the looting was more extensive than he
had ever seen before. The looting was reported to have included
removing wiring and pipes from walls and from the ground; stealing
desks, windows, sinks, and floors; and even dismantling and removing
whole buildings. While some looting may have been done to thwart the
U.S. mission, according to DTRA officials, most of it seemed to be
related to selling or reusing common materials such as scrap metal
rather than seeking radiological or nuclear materials. At the Tuwaitha
facility, for example, looters dumped partially processed uranium ore
from large containers onto the floor and took the containers.
DOD found that fully securing sources from looters was challenging
because of their persistence. According to a DTRA official's personal
assessment, no amount of forces could have controlled the rampant
looting. At the Tuwaitha Nuclear Research Center, DOD concentrated
security in those areas where radiological and nuclear materials were
stored, but looters continued to penetrate the less secure areas of
Tuwaitha, a large complex of over 90 buildings.
The scattering of radiological sources by looters complicated the later
collection of those sources. In one dramatic instance, looters stole
large cobalt sources from an Iraqi radiological test site in early
September 2003, when U.S. troops were guarding the site. The large,
open site, which was apparently designed for carrying out radiation
exposure experiments in the surrounding areas, contained eight metal
pillars, each with a pulley system to raise a cobalt source from a
concrete storage pit to the pillar's top. Looters tore down and removed
three of these pillars and also took the cobalt sources from two of
them. (See fig. 1.) After several days of extensive searches in the
area, DTRA recovered both stolen sources. According to a DTRA official,
the metal pillars were probably the looters' intended target, and the
sources may have been taken unintentionally when they became caught in
the pulley mechanisms.
Figure 1: An Intact Pillar and a Looted Metal Pillar That Contained
Cobalt Sources:
[See PDF for image]
[End of figure]
DOD Was Not Ready to Collect and Secure Radiological Sources in Iraq at
the Start of the Hostilities in March 2003:
For about the first 6 months after the war began in March 2003,
military commanders had insufficient guidance and equipment appropriate
for collecting and securing radiological sources that they discovered.
As a result, they were forced to make ad hoc decisions about recovering
and securing these sources. During this time, DTRA--the agency DOD had
assigned to the WMD elimination mission 12 days before the war began--
was working to fill gaps in preparations for the mission to collect and
secure radiological sources. It was not until September 2003 that DTRA
finalized the terms of the contract for collecting the radiological
sources and collections began throughout Iraq.
Insufficient Guidance and Equipment Left Military Commanders to Make Ad
Hoc Decisions about Collecting Radiological Sources from March to
September 2003:
Military commanders in Iraq initially had no policy guidance on which
radiological sources to collect, and what to do with them once they
were collected. DOD did have some specialized teams with radiological
expertise, such as the 11-person Nuclear Disablement Team, which had
been set up to disable WMD and associated production facilities in
Iraq. This team had the expertise to move radiological sources,
including packaging radioactive material and designing safety
procedures to minimize radiation exposure. However, military commanders
lacked sufficient equipment appropriate for safely collecting and
moving radiological sources.
Without adequate official guidance and equipment to handle the
radiological sources they encountered in Iraq, military commanders were
left to make ad hoc decisions about recovering and securing the
sources. They acted because they were concerned about the inherent
health and safety risks of radiological sources to coalition soldiers
and the Iraqi populace, as well as the potential for enemy or terrorist
forces to use the sources to construct dirty bombs. For example,
lacking the proper radiation shielding equipment, the Nuclear
Disablement Team moved a radiological source to Tuwaitha with
improvised shielding because an officer judged that the unshielded
source posed the risk of radiation exposure to Iraqis working in the
vicinity. The team created what was described as "field expedient"
packaging by lining an ice chest with lead bricks that were brought
from the Tuwaitha Nuclear Research Center. However, the container did
not sufficiently shield the driver of the military vehicle carrying the
source from radiation exposure. Therefore, the team further improvised
shielding by placing metal sheets salvaged at the site between the
driver and the container in the back of the vehicle. This additional
shielding reduced the radiation at the driver's seat to a level that
just met the team's safety standard for exposure. However, the
radiation in the back of the vehicle still exceeded that standard.
Consequently, a second military vehicle followed the loaded vehicle at
a safe distance to prevent occupants of any other vehicles from
following so closely that they would be exposed to unsafe levels of
radiation. On the basis of his assessment of the team's experience with
moving the source described above, the commander of the Nuclear
Disablement Team decided it was too risky to allow his troops to move
any more sources without proper handling equipment and containers.
Because some military officers were reluctant to move radiological
sources to a single consolidation site without adequate handling and
packaging equipment or official guidance, coalition forces had their
troops guarding sources around Iraq. In some cases this posed health
risks--for example, some sources were secured in bases where U.S.
troops were already stationed, creating the need to protect the troops
from accidental exposure to radiation. When sources were secured
outside controlled areas, however, security risks resulted. For
example, according to a DTRA official, field commanders complained to
him after he arrived in July 2003 that protecting radiological sources
in some field locations exposed their troops to increased risks of
attacks. Estimates of how many soldiers were removed from their
military duties to guard sources were not available, but we were told
of instances in which troops were left guarding sources for several
months. According to a DOE expert involved in DTRA's later collections,
for example, a small group of troops had guarded sources at an oil
drilling operation from May until early September 2003.
While Military Commanders Improvised, DTRA Worked to Complete
Preparations for Collecting Radiological Sources:
Between March and September 2003, as individual military commanders
acted independently to collect or secure radiological sources when they
discovered them, DTRA was working to fill gaps in preparations for the
mission to collect and secure radiological sources. According to DTRA
officials, they only gradually became concentrated on radiological
sources as their initial focus on eliminating WMD diminished because
stockpiles of chemical, biological, and nuclear weapons were not found.
First, DTRA tried to establish much-needed guidance on which
radiological sources to collect and where to consolidate them.
According to a DTRA official, these and other issues had been discussed
in prewar planning in late 2002, but guidance had not been issued. In
July 2003, the DOD Office of Policy issued guidance on collecting and
securing radiological sources for field commanders, which a DTRA
official told us was all the policy guidance that DTRA needed. However,
DTRA still needed to specify standards for health and safety as well as
for transportation for its collection missions. According to the DTRA
commander who set up collection operations in Iraq, DTRA used U.S.
standards to ensure safety, but these standards were modified for the
Iraq situation. For example, instead of using radioactive cargo
placards on vehicles, which would be required by U.S. standards but
might attract an insurgent attack, DTRA notified local military
commanders along the route of its cargo when moving sources.
In addition, DTRA engaged in extensive, and ultimately unsuccessful,
coordination within DOD to provide protection for its contractor at the
Tuwaitha storage site through a contracted security force, but
eventually obtained protection for its collection mission through
coalition forces headquarters. This security force stood by for
deployment to Iraq while the Department of Defense General Counsel,
DOD's Central Command, and coalition military headquarters considered
DTRA's request to arm this force. When this request was denied, DTRA
decided in late 2003 that sufficient protection could be provided by
military forces. For each collection mission, DTRA coordinated
protection through the coalition forces headquarters, and could draw
upon a military police platoon for a security escort.
Also, starting in March 2003, DTRA worked to coordinate arrangements
with DOE for its assistance with collecting radiological sources. DOE
was to send both technical experts from one of its national
laboratories and shipping containers to Iraq for the collection effort.
However, the arrangements were complicated by DOE's concerns about
potential disposal of collected sources at its U.S. facilities and
about the safety of DOE experts working in Iraq, as well as by
communication difficulties. DOE had concerns about potential lawsuits
arising from disposing of sources at its U.S. facilities. A DOE
official told us that mislabeled or improperly packaged containers
could lead to lawsuits if, for example, a source in a container was
mislabeled and turned out to be a source that DOE's U.S. site was not
licensed to possess, or if poor packaging led to radiation leakage in
the United States. Consequently, DOE insisted that its technical
experts be present when the sources were collected to identify and
package them in Iraq, before they were transported to DOE's U.S.
facilities, and DTRA agreed. When collections began, however, the
danger of packaging sources in a hostile environment led DTRA to
instead use temporary packaging in the field, followed by interim
packaging at the Tuwaitha facility. The final packaging of the sources
did not occur until May 2004 when DOE experts packaged them for
shipment to the United States.
DOE also had concerns about the safety of its experts while overseeing
the packaging of the sources in Iraq. Consequently, DOE proposed a
contract provision that required DTRA to make every reasonable effort
to evacuate DOE experts to a safe area if hostilities broke out. DTRA
initially said it could not accept this contract provision because it
did not control the troops who could provide such protection.
Eventually the contract said that the DOE experts would not be exposed
to unreasonable risks, but, according to a DOE official, the discussion
about a military protection clause held up the contract for a couple of
weeks.
Unclear communications also affected the negotiations between DTRA and
DOE. For example, according to a DOE official, at one meeting DTRA told
DOE that DTRA either had shipping containers or could get them. But a
few weeks later, DTRA asked DOE to provide the containers. Then
communication about the number of containers needed became an issue
because DTRA could not know the number or type of radiological sources
that would need to be transported. Finally, the DOE expert preparing a
contract proposal had difficulty defining the scope of services to be
provided to DTRA because DTRA's plan was not clear to him. For example,
he was not initially aware that the DOE experts would have only an
oversight role and that DTRA was planning to use a contractor to do the
collection work.
In addition, between March and September 2003, DTRA was also
negotiating with its contractor to collect sources. This process was
delayed in large part by the contractor's refusal to begin work until
it obtained protection from legal claims for damages that could result
from their work--that is, until they were given indemnification.
Resolving this legal indemnification issue was delayed, in part,
because DTRA contracting officials, who were uncertain about the
infrequently used procedures for granting indemnification for work done
under potentially hostile conditions, asked the contractor to provide
what turned out to be unnecessary detail on the various damage
scenarios that indemnification would cover. For example, one concern
was that a convoy truck loaded with radiological sources would be fired
upon, resulting in the radiological contamination of the area. In the
end, DTRA decided that the indemnification language would be general
and provided the contractor with indemnification in September 2003.
Getting DOE experts working in Iraq was also delayed by indemnification
issues, but their indemnification was settled earlier.
The contractor's acquisition of equipment, such as helmets and body
armor, was also delayed, although not as long as the indemnification.
The State Department approves the export of such U.S.-origin defense
products to other countries under the International Traffic in Arms
Regulations; approval took over 50 days in the case of one request by
the DTRA contractor. According to a State official, this delay occurred
despite procedures to expedite approval of export applications for
Operation Iraqi Freedom because this particular approval required
congressional notification, a requirement State could not meet until
Congress returned to session. As a result of these delays, according to
a DTRA official, DTRA's contractor wore helmets obtained from other
countries because the helmets could be obtained sooner. In addition,
the contractor, which was responsible for obtaining all needed
equipment for the collection mission, initially lacked some equipment.
According to a DTRA official, in one instance, the contractor did not
allow its workers to perform a mission because of concerns that heat at
the work site exceeded safety standards even though the contractor
lacked the monitoring equipment to make that determination. According
to the contractor's project manager, some necessary items were
forgotten because the contractor team, which was being created for the
first time, did not have an established standard equipment list for
this mission.
Finally, DTRA's efforts to subcontract with Iraqis to help with
collections also took time. In July 2003, because of security concerns,
DOD's Office of Policy stopped Iraqis from the former Iraqi Atomic
Energy Commission from independently collecting sources and rescinded
their access to the secured bunker at Tuwaitha. By October 2003, DOD
had decided to authorize, and encourage the use of, experienced Iraqis
to locate sources, leave them secured in place when possible, and move
unsecured sources to Tuwaitha, but this was an unsuccessful strategy
for quickly increasing collection efforts. According to a DTRA
official, DTRA tried unsuccessfully to get Iraq's Coalition Provisional
Authority to fund Iraqis from the Ministry of Science and Technology to
collect sources, but restrictions on the Coalition Provisional
Authority's funds did not allow this. Eventually, DTRA arranged for its
contractor that was collecting sources to subcontract some tasks to
these Iraqis, but it took time to work out hiring, training, and
procedures. For example, DTRA told us that subcontracting with the
Iraqis was challenging because of difficulties with establishing
banking procedures to ensure they got paid. By the time procedures were
developed, training was finished, and the Iraqis began collection
missions, it was February 2004, and DTRA's collection mission was in
its final months.
DTRA Recovered or Left Secure in Place about 2,100 Radiological
Sources, but the Number of Unsecured Sources Remaining in Iraq Is
Unknown:
Between September 2003 and May 2004, DTRA collected and secured about
1,400 radiological sources from sites throughout Iraq and left in place
another 700 that it deemed secure. To further secure the most dangerous
sources it had collected, in June 2004, DTRA and DOE together removed
about 1,000 of the 1,400 previously collected sources from Iraq.
Despite DTRA's efforts, however, the total number of radiological
sources in Iraq remains unknown.
DTRA Collected and Secured about 1,400 Radiological Sources and Left
about 700 Sources in Place after Judging Them to Be Secure:
During approximately 140 collection missions conducted between
September 2003 and May 2004, DTRA and its contractor collected about
1,400 unsecured radiological sources and inventoried and left in place
about 700 sources that DTRA deemed secure.[Footnote 3] To collect the
1,400 sources, DTRA identified their locations, traveled to those
locations and found the sources, determined which sources to remove,
transported those selected for removal to Tuwaitha, and secured them in
a bunker there. According to DTRA officials, the collection missions
were conducted safely, despite increasing insurgent hostilities and
exposure risks associated with handling radioactive material.
About 450 of the 1,400 sources ultimately collected were removed from
radioactive lightning arrestors. Unlike conventional lightning
arrestors, radioactive ones use radiological sources to enhance the
attraction of lightning. One or more sources sat in a metal cylinder at
the top of each of the metal arrestor poles. Iraq had located these
arrestors around its munitions dumps, military bases, and industrial
complexes to protect them from lightning strikes. If these facilities
were abandoned, the lightning arrestors--including the radiological
sources--would have been easily accessible to looters. Coalition forces
also found sources used in commercial activities, such as oil
exploration, agriculture, and scientific research. The uses of many
other unsecured sources DTRA collected were unknown.
As figure 2 shows, DTRA collected unsecured radiological sources from
locations across Iraq, from the north at the Turkish border to the
south near Al Basrah. However, many of the sources were collected at
the Tuwaitha Nuclear Research Center, located about 25 miles from
DTRA's base camp near Baghdad International Airport.
Figure 2: Sites from Which Unsecured Sources Were Collected:
[See PDF for image]
[End of figure]
Upon arrival at locations, the radiological sources were sometimes not
where DTRA and its contractor expected to find them. For example, on
one mission, a radiological source from a lightning arrestor was found
outside its metal cylinder under about 2 inches of debris. A DTRA
official told us that looters apparently valued the metal lightning
arrestor poles and copper wire inside them more than the radiological
sources. At other times, DTRA and its contractor did not find the
expected sources at all, which the contractor's mission reports
sometimes attributed to faulty intelligence or looting.
If the radiological sources DTRA found were at an abandoned site or
otherwise not under legitimate control of the Iraqis, DTRA collected
them. For example, DTRA collected two large cesium sources from a
factory that was largely abandoned. Similarly, if a lightning arrestor
was damaged and the radiological source potentially subject to looting,
DTRA would collect the source, according to a DTRA commander.
After collecting and packaging the radiological sources, DTRA secured
them by transporting them to a protected bunker at Tuwaitha. According
to DTRA officials, DTRA had found a bunker at Tuwaitha that had blast-
proof doors. DTRA further improved the bunker's security, investing
over $1 million in improvements such as a chain link fence, gate, and
security system. In addition, DTRA placed an armored unit outside the
bunker to guard it. Figure 3 shows the protected bunker, under a mound
of earth at the Tuwaitha Nuclear Research Center.
Figure 3: Bunker Where DTRA Secured Radiological Sources, Tuwaitha,
Iraq:
[See PDF for image]
[End of figure]
In addition to the about 1,400 radiological sources DTRA collected
during its mission, DTRA left about 700 sources or source devices in
place after it determined that they were properly secured and in the
custody of responsible personnel. According to DOD's guidance,
coalition forces and DTRA could leave sources in place if they:
* had medical, agricultural, industrial, or other peaceful uses;
* were properly contained and adequately secured; and:
* were in the custody of trained personnel acting in a professional
capacity, such as hospital staff or agricultural ministry personnel.
DTRA relied on this guidance to determine whether radiological sources
it found could be left in place. In line with the guidance, when DTRA
left sources in place, it recorded information such as location, use,
and responsible institution or individual. Although the guidance did
not elaborate on the standard for adequate security, a DTRA commander
told us that the guidance was sufficient for DTRA to decide which
sources were secure enough to be left in place.
DTRA's initial planning had assumed that the war would be over when its
contractor went to work and, therefore, it would be collecting sources
in a peaceful environment. Instead, with insurgent attacks continuing
after major combat operations were declared over, the contractor's
staff was consistently exposed to danger. In fact, insurgent attacks
throughout Iraq significantly increased during the collection period
and generally became more sophisticated, widespread, and effective (see
fig. 4).
Figure 4: Number of DTRA Contractor Missions and Number of Insurgent
Attacks throughout Iraq, June 2003 to May 2004:
[See PDF for image]
Notes: Attacks were against infrastructure, Iraqi Security Forces,
civilians, or coalition forces.
The initial August 2003 missions were done only at Tuwaitha, as
contractor staff waited for indemnity to be granted.
[End of figure]
Although some areas were known as particularly dangerous for travel,
attacks were unpredictable and occurred in many places. For example,
according to a DTRA commander, during the first day of a mission in the
Sunni triangle, the DTRA team came under mortar and sniper attack;
during the second day, a helicopter involved in the mission experienced
a rocket-propelled grenade attack. On another occasion, a DTRA convoy
traveling through Baghdad was delayed by an explosion that left a
burning vehicle in the road. Even within the relative security of the
Tuwaitha Nuclear Research Center, DTRA's contractor reported hearing
shots fired and found an improvised bomb on the road.
To help decrease the danger, DTRA planned armed security for each of
its missions. DTRA officers told us they assessed the potential danger
associated with a particular mission and, if the anticipated security
risk was higher than usual, they increased the size of the security
force. For example, the number of vehicles with mounted weapons might
be increased from two to four. When the risks seemed particularly high,
missions were at times postponed. DTRA's security plan also specified
the route of the convoy, so its location could be tracked with a
communication system and a quick-response military team could be sent
if needed. In addition, military troops sometimes secured the area
around the source before the arrival of DTRA's contractor
staff.[Footnote 4]
Despite the attacks and the risk of exposure to radiation when
collecting radiological sources, DTRA officials reported that the
agency's missions to collect and secure radiological sources from
September 2003 to May 2004 were conducted safely. According to DTRA
officials, although the risks from hostilities were often greater than
the risks from handling the radiological sources, DTRA's team did not
sustain casualties during its collection missions. However, two
contractor staff were injured--one seriously--in a mortar attack at
DTRA's home base near Baghdad International Airport, but not during a
collection mission. With regard to radiation exposure, the contractor's
plan called for keeping the effect of individual exposures on a person
as low as reasonably achievable and cumulative exposures over the
mission below specified limits. Although six team members' hands or
feet were contaminated with radioactive powder in one instance,
according to DTRA and contractor officials, DTRA personnel and
contractor staff remained under the cumulative standard throughout the
overall mission.
DOE and DTRA Removed about 1,000 of the Most Dangerous Sources from
Iraq:
In March 2004, a National Security Council interagency policy committee
that included DOD and DOE made the final decision to remove the most
dangerous radiological sources from Iraq before the Coalition
Provisional Authority handed power over to the interim Iraqi government
at the end of June 2004. In the case of Iraq, DOE selected radiological
sources for removal based on its criteria for determining which
radioactive material posed a significant risk as dirty bomb material.
Normally, DOE applies its criteria to individual sources in determining
the risk. In this case, DOE consolidated some of these sources that,
individually would not have met the risk criteria, but did meet the
criteria once they were consolidated into waste shipment containers.
According to a DOE official, using the criteria this way was warranted
because the consolidation of the sources in the storage bunker created
a potential public health risk or a target for theft, and Iraq had
ongoing hostilities. As a result of applying its criteria in this way,
DOE removed from Iraq about 1,000 of the 1,400 collected sources,
accounting for a total of almost 2,000 curies, or over 99 percent of
the radioactivity of the collected sources. The remaining radiological
sources were generally small, accounting for a few curies of
radioactivity in total.
After the National Security Council approved the removal mission in
March 2004, final preparations for the mission were completed in about
2-1/2 months and the mission was finished in about 1 month. In late May
2004, DOE sent a team of 20 experts to Iraq to identify the type and
radioactive strength of each collected source and package the sources
for shipment to the United States. Given the escalating hostilities,
DTRA hired a contractor to create a protected living area for the DOE
team at the Tuwaitha site to reduce the exposure to attacks that would
have resulted from traveling daily from a base camp to work at
Tuwaitha. Figure 5 shows this living area and the concrete barriers
placed at the perimeter.
Figure 5: Protected Living Area for DOE Experts at the Tuwaitha Nuclear
Research Center:
[See PDF for image]
[End of figure]
DOE had difficulties coordinating with DTRA to get all the information
needed to determine the number and types of shipping containers for the
source recovery mission. DTRA constructed its inventory information on
radiological sources collected at the Tuwaitha bunker to try to meet
DOE's needs. However, DOE experts told us DTRA's information never
fully met DOE's expectations. Specifically, DOE wanted comprehensive
information on the type of isotope and radioactivity of the sources to
determine the number and types of containers needed to safely ship the
sources to the United States, as well as to do other planning tasks,
such as an environmental impact assessment. According to DOE experts,
DTRA could never provide, for example, complete and accurate
information on radioactivity. Deciding that full information would not
be forthcoming, the DOE experts overestimated radioactivity to ensure
that DOE would bring enough containers from the United States to ship
the radiological sources back safely.
Ultimately, DTRA and DOE were able to complete the task of analyzing,
packaging, and loading the containers into trucks in about 25 days.
DTRA and DOE successfully removed about 1,000 radiological sources and
about 1.7 metric tons of low-enriched uranium from Iraq on June 23,
2004, 5 days before the transfer of power from the Coalition
Provisional Authority to the interim Iraqi government. DTRA and DOE
transported the sources in a heavily guarded convoy to a military
airfield, and then departed from Iraq by military air transport. These
materials were taken to a DOE site within the United States and are
being evaluated for either reuse or permanent disposal. The disposal
activities, funded by both DTRA and DOE at an estimated $4.2 million,
are expected to continue through late fiscal year 2006.
According to DOE officials, the final disposition of the radiological
materials removed from Iraq may take longer and cost more than
estimated because a legal determination is needed regarding whether the
United States government owns the material or is merely serving as its
custodian. Currently, DOE is storing the sources temporarily at one of
its sites, but it is waiting for an interagency determination before
deciding on how to dispose of the material. According to DOE officials,
they raised this issue of ownership when the removal mission was being
planned, but it was never resolved. As of mid-April 2005, DOE was
prepared to start shipping sources to disposal facilities, but DOE
disposal facilities are unwilling to take possession of the sources
until ownership has been determined. Thus, DOE will hold the sources in
temporary storage longer than anticipated, leading to increased storage
costs.
An Unknown Number of Radiological Sources Remain Unsecured In Iraq:
Although DTRA's effort to collect unsecured sources and leave secured
sources in place identified about 2,100 radiological sources in Iraq,
it is likely that other sources remain unsecured in Iraq for three
reasons. First, the number and location of all sources in Iraq before
the war were not known. Second, DOD did not search in all places in
Iraq where sources might be found. Third, since the end of DTRA's
mission in June 2004, other unsecured sources have been found,
including at Iraq's borders.
The number of sources in Iraq prior to Operation Iraqi Freedom was not
precisely known because the former government of Iraq did not maintain
an inventory of radiological sources around the country. Around the
time that major combat operations were declared over in May 2003, DOD
received information on radiological sources in Iraq, but DOD and State
officials told us that this information was not reliable for the
purpose of locating and securing sources. For instance, DTRA officials
told us that the information on sources and their locations was not
precise because the names of locations were not clear, some sources
were reported twice at the same location, and the information was
sometimes outdated. However, DTRA used this information as a general
guide to where sources might be found. Lacking more reliable
information about the number and location of sources in Iraq at the
beginning of the war, DTRA first collected sources discovered by
coalition forces and then searched for other sources.
Because DOD and DTRA did not search all locations where radiological
sources might be found, it is likely that unknown sources remain
unsecured in Iraq. One DTRA official told us that DTRA was not tasked
to search all locations where sources might be found. In addition, DTRA
found evidence that sources had been taken from some locations before
DTRA arrived. According to State officials, neighboring countries
detected elevated radiation readings from cargo on trucks leaving Iraq
starting at least by September 2003, and some of these trucks were
turned back at the border. Although many of these incidents involved
radioactively contaminated scrap metal, some cargo included sources.
State officials said they did not know where the trucks and their cargo
went after returning to Iraq, but the State Department sought to
improve coordination with neighboring countries to manage these border
incidents. Because of the lack of a complete search for sources in
Iraq, officials of the interim Iraqi government told us that it
intended to perform a more comprehensive search.
Finally, sources continued to be found in Iraq and at its border after
DTRA completed its collection and removal mission in June 2004. In
addition, according to State officials, radioactive materials,
primarily contaminated scrap metal but also some sources, continued to
be detected on trucks leaving Iraq after that time. Separately, in
August and September 2004, for example, a country bordering Iraq found
radioactive sources on trucks leaving Iraq. Also, a U.S. Army officer
responsible for nuclear, biological, chemical, and radiological issues
in Iraq told us that, in at least one case, an unsecured source or
sources from lightning arrestors had been discovered by U.S. troops
since the end of DTRA's mission in Iraq.
The United States Helped Create an Iraqi Agency to Regulate Sources,
but Future Assistance Is Uncertain:
The Department of State supported the Coalition Provisional Authority
in creating an independent Iraqi agency, the Iraqi Radiological Source
Regulatory Authority (IRSRA), to regulate sources, and State and DOE
are assisting the new agency by providing equipment, technical
assistance, and funding. However, the evolving Iraqi government--
including the transitional government formed after the January 2005
election and the permanent government to be formed through an upcoming
election--and the ongoing insurgency are creating uncertainties for
both IRSRA and U.S. assistance.
State Facilitated the Creation of an Iraqi Radiological Source
Regulatory Agency:
Before the transition to the interim Iraqi government in June 2004,
State's Bureau of Nonproliferation encouraged the creation of IRSRA. It
saw this effort as an extension of U.S. support for international
standards for safe and secure management of radiological sources, such
as those coordinated and administered by IAEA. Specifically, IRSRA will
further several U.S. foreign policy goals. First, an Iraqi agency that
controls radiological materials will promote the health and safety of
Iraqis, as well as provide the capability for Iraq to meet
international commitments for the safe and secure management of
radiological sources. Second, an effective Iraqi agency for regulating
sources will promote U.S. national security goals by decreasing the
likelihood of terrorists trafficking in or deliberately releasing
radioactive material. Third, the new agency will employ former Iraqi
scientists who might otherwise seek employment with terrorists or
countries seeking WMD expertise.
State officials enlisted Iraqi officials within the Coalition
Provisional Authority to support the formation of IRSRA. In particular,
State negotiated with the Minister of the Ministry of Science and
Technology (MOST), who played a leading part in supporting the creation
of IRSRA. The Minister agreed to allow IRSRA to regulate Iraq's
radiological sources, while MOST will retain ownership and control of
secured nuclear and radiological materials at research facilities. The
Minister also agreed to continue DTRA's efforts to find and collect
unsecured radioactive sources, but under contract with IRSRA. The
Minister further agreed that IRSRA would be legally and financially
independent--a key element in State's plan for IRSRA. According to
State officials, IRSRA was designed as an independent agency to avoid
conflicts of interest. While Iraqi ministries, such as the Ministry of
Health, the Ministry of Oil, and MOST, own or track many of the
radiological sources in Iraq, their activities will be subject to the
regulation of IRSRA, which will inspect, inventory, and regulate all
sources in Iraq.
In addition, through discussions with Iraqi and Coalition Provisional
Authority officials, State helped draft the 2004 budget plan and the
organizational structure of IRSRA. The plan included providing $7.5
million to the new agency within the Iraqi Government Budget developed
by the Coalition Provisional Authority for fiscal year 2004. These
funds are to be spent on salaries, the search for sources, assistance
from U.S. experts, office space, and facility security. State's
organizational plans for IRSRA identified the departments and staffing
needed to accomplish agency tasks, such as regulating radiological
sources in use, managing unwanted radiological sources, and creating
regulations in cooperation with IAEA and other experts. In addition, to
further State's efforts, DTRA trained Iraqis to collect, store, and
secure radiological sources during its own collection operations and
subsequently provided Iraqis with an upgraded secure storage facility
and its inventories of sources removed from the country, left at the
facility, or identified around Iraq.
In June 2004, the Coalition Provisional Authority issued an order
establishing IRSRA.[Footnote 5] According to the order, IRSRA will
promulgate and enforce regulations to allow for beneficial uses of
radioactive sources, provide for adequate protection of humans against
the harmful effects of radiation, and ensure the safety and security of
radiological sources. For example, it will require hospitals,
universities, oil production facilities, and others to obtain licenses
to possess radiological sources, which will enable the agency to
maintain records on radiological sources in the country. Licensees will
be obliged to follow procedures and regulations that define how they
will secure, inventory, and work with their licensed radiological
sources. In addition, IRSRA is responsible for collecting unsecured
sources when they are found, creating radiation health and safety
criteria, and researching the possibility of constructing a low-level
radioactive waste disposal facility in Iraq. The Coalition Provisional
Authority disbanded shortly after it created IRSRA, but its order will
continue to have legal authority in Iraq until it is amended or changed
by the Iraqi government, according to State officials.
By the summer of 2005, State officials told us, they perceived signs
that IRSRA was beginning to function and was becoming more established
as part of the Iraqi government. For example, IRSRA had started
drafting regulations and was requiring ministries to notify it about
their radiological sources. Moreover, it had an appointed chairman,
developed a budget, and obtained its own building and office space, as
well as about 50 staff.
State and DOE Are Providing Assistance to the New Regulatory Agency:
In addition, State and DOE are assisting IRSRA by providing equipment,
facilitating technical assistance, and providing funding. First, to
help the Iraqis collect unsecured sources under the direction of IRSRA,
State has initiated an effort to transfer to Iraqi agencies equipment
that had been purchased by DTRA to collect sources. This equipment
includes radiological handling, measurement, and protective equipment,
such as radiation meters, respirators, and protective clothing.
According to State officials, preparations for the transfer of this
equipment began in mid-2004; as of early 2005, State and DOD were
discussing how this equipment would be transferred to the Iraqis. In
the meantime, this equipment has been made available to MOST for
collecting radiological materials.
State is also facilitating technical assistance. With funding and
logistical support from DOE, State coordinated several meetings in
Amman, Jordan, in December 2004 to provide IRSRA personnel training by
IAEA staff and to help them draft an action plan for regulating
radiological sources. IRSRA's action plan is based on the IAEA Model
Project program, through which IAEA is helping about 100 developing
countries establish effective regulatory controls for radioactive
sources. Under the Model Project program, developing countries adopt
action plans to help them establish or strengthen radiation protection
infrastructures in order to meet international standards and to follow
the guidance in the IAEA Code of Conduct on the Safety and Security of
Radioactive Sources.
Under the action plan, which was finalized in March 2005 meetings in
Washington, D.C., IRSRA will establish a regulatory framework; work to
control radiation exposure in occupational, medical, and public
settings; and set up emergency preparedness and response capabilities.
IAEA plans to provide expert assistance to help IRSRA meet these goals.
In addition, to help IRSRA find unsecured sources, IAEA will offer
radiation detection equipment and training in border control. To
complement the action plan, IAEA is sharing with IRSRA a computer
program designed to track information about radiological sources'
locations, radioactive strengths, licensing, and responsible parties.
IRSRA intends to use this program to manage information it gathers on
Iraqi radiological sources.
In addition, in coordination with IRSRA's action plan, DOE is offering
IRSRA technical assistance to help ensure the security of radiological
sources. For example, DOE plans to provide experts to review draft
Iraqi laws and regulations for their relevance to security. DOE also
plans to assist IRSRA with facility upgrades to address security
vulnerabilities of sources used for medical, industrial, or other
peaceful purposes. Moreover, in conjunction with IAEA, DOE may also
offer field equipment and training workshops for inspecting the
security of sources.
Finally, to financially support IRSRA's action plan, State intends to
use $1.25 million from its Nonproliferation and Disarmament Fund, which
provides funding for projects to prevent the spread of WMD. State plans
to provide part of these funds to IAEA for training and other
assistance to IRSRA, including an IAEA review of Iraq's draft laws and
regulations. State plans to also use the funds to purchase a specially
equipped vehicle that can be driven through neighborhoods to detect
unsecured radiological sources. In addition, State plans to hire a
contractor to coordinate security matters with coalition forces to
minimize the risk of attacks, while the Iraqis are working to control
sources.
Iraq's Political Transition and Continuing Hostilities Are Creating
Uncertainties for IRSRA and U.S. Assistance:
According to State officials, because of uncertainties associated with
the continuing formation of the Iraqi government, State will have to
monitor Iraqi efforts to ensure the continued growth and success of an
independent, competent, and sustainable regulatory authority for the
control of radioactive sources and materials. According to these
officials, the ongoing formation of the Iraqi government could affect
the future of IRSRA in several ways. First, potential changes to the
government's organization or personnel could affect IRSRA's funding and
enforcement powers. For example, the transitional government formed
from the January 2005 election chose new government ministers--
including replacing the Minister of Science and Technology, who had
aided the formation of IRSRA. In addition, according to State and Iraqi
officials, in early 2005, the Iraqi government froze all new
expenditures until the transitional government takes action on the
budget. Therefore, the funds for the IRSRA contract with the ministry
to search and recover sources were not available. However, State
officials told us the collection missions are important for public
safety and would go forward in anticipation of later payment. Finally,
the Iraqi government will have to enact the laws and regulations that
IRSRA will be drafting under its action plan.
In addition, State officials told us that the evolving relationship of
the northern Kurdish-controlled territories with the rest of Iraq could
affect IRSRA's operation. Before Operation Iraqi Freedom, the Kurds
enjoyed some independence from the former Iraqi regime, and State
officials told us that this partial independence has continued. IRSRA
and Kurdish officials will be discussing whether and how IRSRA will
operate in Kurdish-controlled territory. According to the Chairman of
IRSRA, Kurdish officials are likely to accept a proposal to create a
branch office of IRSRA in Kurdish territory. This proposed office would
be staffed by Kurds, but IRSRA would provide equipment, training, and
protocols.
Finally, the continuing insurgency is hindering IRSRA's ability to find
and collect unsecured radiological sources as well as the ability of
the United States to provide assistance. Iraqi and State officials are
concerned that insurgents will target Iraqis who are seen associating
with coalition forces on their official duties. For example, a MOST
official told us that Iraqi workers entering a U.S. military base to
collect sources would likely be ambushed by insurgents upon leaving the
military base. The hostile environment also impairs the ability of the
United States to provide certain kinds of assistance. For example, DOE
has decided not to send its experts into Iraq because of the ongoing
hostilities, according to a DOE official. However, State and DOE are
devising ways to assist without going to Iraq, such as organizing
training for Iraqis at sites outside of the country.
DOD Has Not Assessed Its Source Recovery Effort, but DOE Is Considering
Lessons Learned:
Although DOD has assessed its overall WMD mission in Iraq, the agency
has not assessed its narrower mission to collect and secure
radiological sources. In contrast, DOE has considered actions to
address specific lessons learned from its experience in removing
radiological sources from Iraq.
DOD Has Assessed Its Broader WMD Mission but Has Not Focused on the
Radiological Sources Effort:
DOD asked its National Defense University (NDU) to study DOD's overall
mission to find and eliminate WMD in Iraq, determine what lessons could
be learned from it, and recommend improvements. The resulting report
stated that DOD had not sufficiently planned and prepared for the WMD
mission; had shortfalls in the needed transportation, military
security, and logistics resources; and had operational difficulties
arising from the extensive looting, public disorder, and hostile
security environment. The report recommended that DOD develop the
capability to quickly eliminate WMD in hostile environments and
establish a permanent organization for eliminating WMD. (See app. II
for more information on the report.) DOD is responding to the report,
in part, by seeking stronger planning and capacity for eliminating WMD,
which a DOD Joint Staff officer told us would include the elimination
of radiological materials. Specifically, DOD's Strategic Command, which
was assigned responsibility for this planning in January 2005 by the
Secretary of Defense, will first determine the needed capacities.
The NDU report did not, however, offer any observations or
recommendations regarding the narrower mission to collect and secure
radiological sources in Iraq, in part because this was not the main
focus of the original WMD mission in Iraq. Nevertheless, the author of
the NDU report and a DOD Joint Staff officer told us that DOD's efforts
to solve overarching issues with its preparation for eliminating WMD
will also address problems experienced with the mission to collect and
dispose of radiological sources.
DOE Is Considering Lessons Learned from Removal of Iraqi Radiological
Sources:
DOE asked its contractor at one of its national laboratories to analyze
the removal mission to identify lessons learned and recommend
improvements. The resulting analysis highlights the lessons that timing
of funds and availability of equipment hindered rapid preparation for
the mission.[Footnote 6] First, the contractor noted that the short
amount of time between when the project was funded and when the team
left for Iraq meant that almost every preparation task had to be
conducted in emergency mode. DTRA funding became available in March
2004 after the National Security Council approved the mission, leaving
less than 2-1/2 months for the team of DOE experts to complete all
preparations in the United States. Needed preparations included
establishing a liaison with DTRA in Iraq; determining the list of
sources to be removed based on DTRA's inventory; developing safety and
handling procedures for those specific sources; completing safety
assessments for those procedures; determining the need for, and
obtaining, a National Security Exemption to bring some of the
radioactive sources to the United States; recruiting the remainder of
the team members; cross training team members to be able to complete
another member's work if necessary; getting the DOD training and
authority necessary for the team to enter Iraq; obtaining contractor
indemnification for the mission; preparing a U.S. staging facility for
equipment; and procuring, testing, and packaging such equipment as
protective clothing, tents, and communication equipment.
In addition, according to the contractor, preparation for the mission
was almost critically delayed by difficulties in acquiring containers
for transporting the radiological sources. DOE and its laboratories did
not have a sufficient number and variety to meet the projected needs of
the removal mission--a shortfall that proved challenging to overcome in
time to successfully conduct the mission. Specifically, certain special
containers could not be procured in time from U.S. domestic suppliers
as a result of shortages. Consequently, DOE arranged to lease four of
these special containers from a foreign company by agreeing to provide
the company blanket indemnity with up to approximately $1 billion in
liability coverage in case of an accident involving the containers. The
containers arrived a few days before the team and its equipment were to
leave for Iraq. According to the contractor, if DOE's negotiations to
get the special containers had failed, the removal mission would have
been delayed, and it is likely that many radiological sources with high
radiation levels would not have been able to be removed.
To support timely action in future removal operations, the contractor
recommended that DOE seek ways to ensure the existence of advanced
funding and maintain a small fleet of versatile containers. DOE
officials told us they saw merit in having a way to quickly fund future
missions, although their agency's funding--used solely for the disposal
rather than the removal of the sources--was available early enough in
the case of Iraq. With regard to maintaining a reserve of containers
and other equipment, the officials solicited proposals and cost
estimates from their national laboratories and have determined they
cannot pursue this option given current budget constraints.
Conclusions:
Because DOD has not comprehensively reviewed its experiences in
collecting and securing radiological sources in Iraq, its current
efforts to improve its preparations to secure or destroy WMD in future
missions will not benefit from important lessons learned from its
radiological source mission. Reviewing such experiences and identifying
lessons learned would help prepare for any future missions involving
similar circumstances.
In addition, DOD's lack of readiness to quickly collect and secure
sources after the war began indicates that additional planning and
preparation could have been completed in advance of the mission.
Specifically, DOD had not:
* planned to collect sources in a hostile environment and thus had to
act during the operation to integrate the objective of collecting and
securing sources with military combat objectives;
* established criteria to determine which radiological sources needed
to be collected, which were being properly used and thus could be left
in place, and which posed minimal threat and thus did not need to be
collected;
* specified health and safety standards for handling, securing,
transporting, and disposing of sources;
* specified the organization responsible for collecting and securing
sources in Iraq until shortly before the invasion of Iraq, nor
established agreements within DOD regarding issues such as using armed
private security forces to protect contractors involved in collecting
and securing sources;
* established agreements or points of contact with DOE to determine the
support that DOE could provide, including the type of expertise,
equipment, and disposal facilities;
* identified and addressed the legal and contractual issues associated
with using private contractors to assist in collecting and securing
sources, including using such contractors in hostile environments; and:
* established guidelines to utilize the skills and address security
concerns associated with the use of Iraqi radiological experts.
Recommendations for Executive Action:
To ensure that the types of problems experienced with the planning and
preparing for securing Iraqi radiological sources do not recur, we
recommend that the Secretary of Defense comprehensively review DOD's
experience for lessons learned for potential future missions.
In addition, to ensure that planning and preparing for potential future
missions is carried out in advance, we recommend that the Secretary of
Defense provide specific guidance for collecting and securing
radiological sources, including:
* integrating the objective of collecting and securing radiological
sources with military combat objectives, including specifying how
security protection, if needed, would be provided to the organization
with responsibility for managing radiological sources and whether
combat troops would be required to secure sources and provide
protection for operations to collect and secure radiological sources;
* determining criteria to define which radiological sources (1) are of
greatest risk and should be collected, (2) are being properly used and
secured and thus can be left in place, and (3) pose minimal threat and
thus do not need to be collected;
* specifying the health and safety standards, after considering how
U.S. standards for handling, securing, transporting, and disposing of
radiological sources were modified for use in Iraq;
* officially designating the organization responsible within DOD for
collecting, securing, and disposing of sources and establishing
agreements between that organization and other DOD organizations that
may be involved with these efforts;
* establishing agreements and points of contact with DOE and other
federal agencies, as needed, to specify the coordination, technical
expertise, equipment, and facilities that may be needed to collect and
secure sources in, or remove them from, a foreign country;
* identifying under which circumstances and for what purposes DOD will
contract with private firms to conduct activities to collect and secure
radiological sources, and address legal and contracting issues to
ensure the timely use of contractors; and:
* establishing guidelines concerning the role of radiological experts
from the country where sources need to be collected and secured.
Agency Comments and Our Evaluation:
We provided the Departments of Defense, State, and Energy with draft
copies of this report for their review and comment.
DOD agreed with four of our recommendations, partially concurred with
two, and did not concur with two. DOD stated that it had previously
addressed a number of issues identified in the recommendations and is
currently addressing the others. DOD also stated that the draft report
did not adequately address those efforts of the Nuclear Disablement
Team (NDT) during the earlier operations in Operation Iraqi Freedom
involving radiological source recovery operations. DOD stated that the
focus of the draft report appeared to be largely on the elimination
phase of the operation and that it accepted our recommendations in that
area. Our report assessed all phases of DOD's planning and preparing
for this mission, including the experiences of the NDT and its decision
to forgo collecting sources because it lacked the proper equipment. We
believe our report was appropriately focused on the elimination phase
because that was when most sources were collected from around Iraq.
DOD partially concurred with our recommendation to develop lessons
learned, indicating that lessons learned have been developed from the
NDT's experiences for the phase of the operation before DTRA began to
collect sources. That effort is in line with our recommendation, but
unless DOD completes a more comprehensive review, we are concerned that
it will miss the experience of all relevant DOD organizations and the
full range of lessons learned.
DOD also partially concurred with our recommendation about integrating
the objective for securing radiological sources with military combat
objectives, saying that this recommendation applies only to the later
phase involving DTRA's work. However, we disagree that our
recommendation applies only to DTRA's work. As our report points out,
there were problems with integrating the mission of collecting and
securing sources with military combat objectives during the NDT phase
of operations as well. Specifically, our report notes that during the
NDT phase of operations, military commanders were left to make ad hoc
decisions about recovering and securing sources, including using combat
troops to guard sources. DOD's response to this recommendation also
noted problems DOD encountered in obtaining support from DOE. We
believe our report adequately discusses problems DOD encountered in
obtaining DOE assistance in collecting radiological sources--these
problems stemmed from the lack of advanced coordination that our report
recommends DOD resolve prior to any future missions. DOD also commented
that our recommendation demonstrated a lack of understanding by
suggesting that combat troops should be involved in handling
radioactive materials. We revised our recommendation to more clearly
indicate that DOD should decide whether combat troops would again be
required to secure sources and protect missions to collect sources, as
they did in Iraq.
DOD did not concur with our recommendation concerning health and safety
criteria and suggested that our recommendation was too broad and ill
defined. DOD's rationale for this response is not clear. First, DOD
said that guidance is and always has been available. Then, DOD said
that since Operation Iraqi Freedom was the first time in recent history
that a capability was developed and deployed to counter a WMD threat,
no unit level standard operating procedures existed. DOD then said that
the NDT did develop procedures to "address all these issues" and that
the NDT continues to work to develop changes to existing regulations to
"address all these particulars." We have clarified our recommendation
to indicate that DOD, in specifying health and safety standards, should
consider how U.S. health and safety standards were modified in Iraq
during the mission to collect and secure sources. We continue to
believe that DOD should fully implement our recommendation.
Finally, DOD did not concur with our recommendation to establish the
organization responsible within DOD for collecting, securing, and
disposing of sources. DOD said that it had already identified this
organization as the NDT and that the Commander of Strategic Command has
overall responsibility for issues related to WMD, a subset of which is
collecting, securing, and disposing of sources. However, based on a
conversation we had in August 2005 with a DOD Joint Staff officer,
Strategic Command has not yet issued its plan for combating WMD, in
which the specific organization responsible for collecting, securing,
and disposing of sources will be officially designated. DOD's complete
comments are reprinted in appendix III.
State suggested clarifications of its current outlook for U.S.
assistance to Iraq for radioactive source regulation and the reason for
the delay in State's approval of export licensing, which we have
incorporated into this report. Separately, State provided technical
comments, which we incorporated as appropriate. State's written
comments are reproduced in appendix IV.
DOE had no written comments on the report but did state that it will
work with DOD to determine criteria to define which radiological
sources are of greatest risk.
We are sending copies of this report to the Secretary of Defense, the
Secretary of Energy, the Secretary of State, and interested
congressional committees. We will also make copies available to others
upon request. In addition, this report will be available at no charge
on the GAO Web site at [Hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-3841 or [Hyperlink, aloisee@gao.gov]. Contact
points for our Offices of Congressional Relations and Public Affairs
may be found on the last page of this report. GAO staff who made major
contributions to this report are listed in appendix V.
Signed by:
Gene Aloise:
Director, Natural Resources and Environment:
[End of section]
Appendixes:
Appendix I: Scope and Methodology:
This report (1) assesses Department of Defense (DOD) readiness to
collect and secure radiological sources in Iraq from the start of the
2003 war, (2) presents information on the number of radiological
sources the Defense Threat Reduction Agency (DTRA) secured by the time
of the June 2004 transition to the interim Iraqi government, (3)
describes the assistance the United States has provided, and plans to
provide in the future, to the Iraqi government to help regulate
radiological sources in Iraq, and (4) examines DOD and Department of
Energy (DOE) actions to assess their experiences in Iraq and apply any
lessons learned to possible future radiological source collection
missions.
For our first objective, to assess DOD's readiness to collect and
secure radiological sources, we reviewed planning efforts before the
war began in March 2003; concerns and efforts regarding radiological
sources before DTRA began its collection mission in late 2003; relevant
policy guidance; and DTRA's preparations to collect unsecured sources
in Iraq. To understand DTRA's prewar plans, we interviewed a division
chief of DTRA's Combat Support Directorate, who prepared these plans,
and other DOD officials involved in planning before the war. For
concerns and efforts before DTRA began to collect sources, we
interviewed the Nuclear Disablement Team commander and other team
members and reviewed an unclassified report on their activities in
Iraq. We also interviewed the senior chemical officer for the commander
of coalition land forces who secured radiological sources in Iraq. For
policy guidance, we examined two DOD policy memorandums on radiological
sources in Iraq and interviewed DTRA and DOD officials involved with
the development of the guidance. For specific preparations to collect
sources, we interviewed DTRA officials who prepared for the mission,
including the two commanders who sequentially prepared for the mission
in Iraq and the DTRA director responsible for the mission. We also
reviewed the contract between DTRA and its contractor, and the contract
agreement between DTRA and DOE. We interviewed DTRA officials who
developed and managed the contract, the DOE official who facilitated
the development and execution of the contracts, and contractor's
project managers and staff.
For our second objective, to present information on the number of
radiological sources secured, we assessed the data reliability of five
inventories of radiological sources in Iraq and summary data about the
sources' radioactivity. We asked those responsible for creating or
maintaining the inventories a series of questions focused on data
reliability, covering issues such as internal control procedures and
the accuracy and completeness of the data. Our assessment follows:
1. We assessed the reliability of an inventory of the location, number,
and type of sources in Iraq at the beginning of the war that DTRA
received during its mission, and based on our work, we determined that
these data were not sufficiently reliable for the purposes of this
report to specify the number of sources at the beginning of the war.
Because the source of this information is sensitive, we did not report
its origin. DTRA officials told us they found this data to be
unreliable, but it did match well with sources found at some sites. For
our assessment of the data, we reviewed the inventory and interviewed
key DTRA and contractor staff who worked with this information. We
found major discrepancies, including duplications resulting in multiple
counts of the same sources and evidence of incomplete data. Therefore,
we did not use this data in our report.
2. We assessed the reliability of a May 2004 inventory of sources
collected in Iraq that DTRA had created before the removal mission, and
we determined that, for the purposes of this report, the inventory was
not sufficiently reliable to ascertain the number and types of sources,
but the inventory was reliable enough to identify the general locations
of places where sources were found. To assess this data, we obtained
responses to questions regarding data reliability by interviewing key
DTRA and contractor staff who worked with this information. We also
corroborated the data whenever possible with DOE experts and DOE's
inventories of collected sources taken to the United States and those
left in Iraq. DTRA's contractor staff told us they were unable to open
some containers and counted each of them as one source. However, when
DOE experts opened these containers, they found that some containers
held multiple sources, increasing the count of sources from about 700
sources to about 1,400 sources. Also in the DTRA inventory, the type of
radiological material was misidentified for some sources, according to
DOE experts and documents. Therefore, we reported the number of sources
based on DOE's work.
3. We assessed the reliability of DOE's inventory of the approximately
1,000 sources collected in Iraq and taken to the United States, and
determined that these data were sufficiently reliable for the purposes
of this report. To assess this data, we obtained responses to questions
regarding data reliability by interviewing key DOE experts who worked
with this information. We were told that the number of sources taken to
the United States may be a close approximation, due to some instances
where DOE experts relied on counts by DTRA, and therefore we reported
them approximately.
4. We assessed the reliability of a DOE inventory of the approximately
400 sources collected in Iraq and remaining in Iraqi custody, and
determined that these data were sufficiently reliable for the purposes
of this report. To assess this data, we obtained responses to questions
regarding data reliability by interviewing key DOE experts who worked
with this information. They told us that the number is a close
approximation, and therefore we reported it approximately.
5. We assessed the reliability of a DTRA inventory of the approximately
700 sources determined to be secured and in use in Iraq, and determined
that these data were sufficiently reliable for the purposes of this
report. To assess this data, we obtained responses to questions
regarding data reliability by interviewing key DTRA and contractor
staff who worked with this information. DTRA's contractor staff told us
they did not open the devices that contained sources and, therefore,
depended on the labeling and documentation of the devices, if
available, to record information about their number, type, and
radioactive strength. The inventory assumed that there was one source
per device, but contractor staff told us that some of these devices may
have had multiple sources, and therefore we reported them
approximately.
To report the radioactivity of sources collected in Iraq and taken to
the United States or remaining in Iraq, we depended on information
provided to us in a DOE summary of the sources removed from Iraq, and
determined that these data were sufficiently reliable for the purposes
of this report. We discussed this data with DOE experts who worked with
this information. They told us that the radioactivity of the sources
taken from Iraq was accurate to within 10 percent to 20 percent of the
total reported, and we therefore reported the total approximately. They
also told us that the radioactivity of the collected sources remaining
in Iraq was somewhat more accurate because these less-radioactive
sources could be handled and measured individually, but that the total
was an approximation. Therefore, we reported the total approximately.
To present information on the missions performed to collect and remove
radiological sources, we examined the available contractor reports on
the approximately 140 missions to find and collect sources in Iraq, as
well as contractor reports on the mission to remove sources from Iraq.
We interviewed DTRA officers and staff and DOE experts who accompanied
these missions. We also interviewed contractor staff who performed this
mission and the contractor's project manager for the mission in Iraq.
For our third objective, to describe U.S. efforts to help the new Iraqi
government regulate sources, we examined Department of State planning
documents and a Coalition Provisional Authority order to establish an
Iraqi agency to regulate radiological sources. We discussed assistance,
as well as uncertainties and challenges for assisting Iraq, with
officials from State and DOE. In addition, we discussed DTRA's actions
to support State's effort to assist Iraq with DTRA officials. We also
discussed efforts to secure radiological sources with the Chairman of
the Iraqi Radiological Source Regulatory Authority during his visit to
Washington, D.C., in March 2005; at the same meeting, we discussed
efforts to search for unsecured sources with an Iraqi program director
from the Ministry of Science and Technology. We interviewed State and
DOE officials about their current and intended contributions to the
action plan drafted in December 2004 and further discussed in March
2005 meetings.
For our fourth objective, to describe what DOD and DOE have done to
learn from their experience in Iraq, and how such lessons might be
applied in the future, we interviewed DOD and DOE officials about their
efforts to document lessons learned. We also reviewed a February 2004
National Defense University study of lessons learned from the mission
to eliminate weapons of mass destruction (WMD), and discussed the study
with its author. We discussed DOD's work to assess its capability to
interdict and eliminate WMD materials, including radiological sources,
and reviewed the DOD memorandum initiating this effort, and held
discussions with DOD planning officials. We also examined DOE's
preliminary analysis of lessons learned with DOE officials and
interviewed the DOE expert who prepared it.
Because of the continuing hostilities, we did not travel to Iraq. We
performed our work from May 2004 through August 2005 in accordance with
generally accepted government auditing standards.
[End of section]
Appendix II: The National Defense University Study:
The Center for the Study of Weapons of Mass Destruction (WMD Center) at
the National Defense University (NDU) has developed lessons and
recommendations for WMD elimination operations, as the result of the
Department of Defense's (DOD) request for this study in late 2002. The
WMD Center conducted meetings with DOD and interagency personnel to
discuss elimination operations, and also examined prewar planning and
its execution in Iraq. In February 2004, the WMD Center hosted a
conference with those who had been engaged in the elimination mission
in Iraq to identify lessons learned and ways to institutionalize WMD
elimination capacity for the future. Major findings and key
recommendations from the study were subsequently published in an NDU
report.[Footnote 7]
The NDU report suggests three wrong lessons from the Iraq experience
that should be avoided to arrive at the correct lessons. A first wrong
lesson is that Iraq is a rare situation. According to the report, since
most of the United States' potential adversaries have actual or
suspected WMD capabilities and terrorists appear committed to acquiring
WMD from weak, poor, or failed states, the U.S. military will likely
confront WMD elimination missions as often as it engages in war. A
second wrong lesson is that the failure of intelligence on WMD explains
all of the failures of the WMD elimination mission. While faulty
intelligence contributed to problems, the Iraq experience revealed
substantial problems with DOD's ability to eliminate WMD, including
problems in planning, training and exercises, capabilities, and
resources. A third wrong lesson is that elimination should not be a DOD
mission, but rather should mostly be done by civilian or international
organizations with the proper expertise after the military minimally
secures WMD sites. Instead, the Iraq experience suggests that the U.S.
military must quickly attend to finding, securing, and disposing of WMD
to prevent the loss of information about WMD programs and the potential
dispersal of WMD occurring in the chaos following an invasion.
Even though WMD was not found, the report suggests that the Iraq
experience reveals that major improvements must be made if the United
States is to succeed in a possible future WMD elimination mission. For
example, according to the study, DOD had not sufficiently planned and
prepared for the mission to locate, secure, and dispose of WMD, in
part, because DOD only began to rapidly plan for operations and develop
capacities for the elimination mission in late 2002. Before the end of
major combat operations, the study observed that the teams searching
for WMD experienced important operational problems. One key problem was
that operations had to be adjusted because existing intelligence was
directing teams to suspected sites that proved to have little evidence
of WMD activity. Operations thus shifted from the expected focus on WMD
to a more geographically dispersed investigation of potential WMD
sites. Operations also shifted toward gathering information about WMD
programs, but most teams lacked sufficient training and expertise for
retrieving important information contained in documents and computers
as well as for interviewing Iraqis who might be knowledgeable about WMD
programs. Further, the organization responsible for searching for WMD
was dependent on other military commands for capabilities such as
transportation, logistics, communications, linguists, and security.
When these other military commands experienced competing priorities for
these capabilities, shortfalls for these capabilities occurred and the
search for WMD was delayed. Additionally, the extensive looting, public
disorder, and uncertain security environment made the search for WMD
complex, resource intensive, and dangerous.
Based on the Iraq experience, the NDU report recommended that DOD
develop and maintain the capability to quickly eliminate WMD in hostile
environments. More specifically, the report included eight key
recommendations: (1) DOD should institutionalize the WMD elimination
mission, embedding it into the planning and budget process along with
other tasks undertaken in combat operations. (2) To have a clear
organization responsibility, DOD should create a standing military
organization that is ready to perform the WMD elimination mission,
including in a combat situation. Although this organization should be
military, it should develop strong links with interagency and
international partners, civilian experts, and the private sector. (3)
DOD should be prepared to conduct this mission in an inhospitable
environment and as quickly as possibly--concurrently with major combat
operations, if necessary. (4) Elimination planning must assume
imperfect intelligence on WMD, operations should be prepared to respond
to emerging intelligence, and intelligence sharing must be improved.
(5) To test plans as well as identify and address problems with
procedures, the organization with WMD elimination responsibility should
conduct training and exercises. (6) Rather than focusing on WMD sites,
as initially occurred in Iraq, future elimination missions should
target WMD programs, using a balanced examination of WMD sites, people,
and documentation. (7) DOD should seek technical innovations to improve
the efficiency, speed, and overall effectiveness of elimination
operations. The objective is to reduce the needed manpower because it
is in extreme demand before, during, and after a war, as shown in Iraq,
and to address technical issues in Iraq operations, such as false
readings on chemical detectors and electronic communication
limitations. (8) Finally, senior-level government advocates are
necessary to ensure adequate and sustained funding and prioritization
to develop a significant WMD elimination capacity.
[End of section]
Appendix III: Comments from the Department of Defense:
ASSISTANT TO THE SECRETARY OF DEFENSE:
NUCLEAR AND CHEMICAL AND BIOLOGICAL DEFENSE PROGRAMS:
3050 DEFENSE PENTAGON:
WASHINGTON, DC 20301-3050:
JUL 28 2005:
Mr. Gene Aloise:
Director, Natural Resources and Environment:
U.S. Government Accountability Office:
Washington, D.C. 20548:
Dear Mr. Aloise,
This is the Department of Defense (DoD) response to the GAO draft
report, "Radiological Sources in Iraq: DoD Should Evaluate Its Source
Recovery Effort and Apply Lessons Learned to Future Recovery
Operations," dated May 18, 2005 (GAO Code 360459).
The DoD generally concurs with the draft report's recommendations. The
Department had previously addressed a number of the issues identified
in your recommendations and are currently addressing the others. The
GAO's focus in this report does not adequately address those efforts
employed during earlier operations in Operation Iraqi Freedom involving
radiological source recovery operations. The focus of this report
appears to be placed largely on the elimination phase of the operation
and we accept your recommendations in that area.
The Department appreciates the opportunity to comment on the draft
report. Technical comments were provided separately. For further
questions concerning this report, please contact the undersigned, (703)
697-1771, raymond.freeland@osd.mil.
GAO DRAFT REPORT DATED MAY 18, 2005 GAO-05-XXX (GAO CODE 360459):
"RADIOLOGICAL SOURCES IN IRAQ: DOD Should Evaluate Its Source Recovery
Effort and Apply Lessons Learned to Future Recovery Missions"
DEPARTMENT OF DEFENSE COMMENTS TO THE GAO RECOMMENDATIONS:
RECOMMENDATION l: The GAO recommended that the Secretary of Defense
review DOD's experience with collecting and securing radiological
sources in Iraq for lessons learned for potential future missions. (p.
36/GAO Draft Report):
DOD RESPONSE: Partially concur. The GAO report focuses on the
Department of Energy (DOE) and Defense Threat Reduction Agency (DTRA)
role in the elimination phase of operations. Little credence is given
to the pre-elimination phase operations of the Nuclear Disablement
Team. The lessons learned garnered from activities of the NDT during
Operation Iraqi Freedom (OIF) has been documented and incorporated into
the Army's new organization for combating issues of weapons of mass
destruction (WMD), the 20th Support Command and have been used to make
equipment and training adjustments to better meet the operational needs
of the Department in the future.
RECOMMENDATION 2: The GAO recommended that the Secretary of Defense
integrate the objective to secure radiological sources with military
combat objectives, including specifying how security protection, if
needed would be provided to the organization with responsibility for
managing radiological sources and whether combat troops would be
required to directly collect and secure sources, and including plans
for the possibility of collecting, securing, and disposing of sources
in a hostile military environment with widespread looting. (p. 36/GAO
Draft Report):
DOD RESPONSE: Partially concur. Again, the GAO fails to distinguish
between post conflict elimination operations and other operations. OSD
provided for operations in theater with the deployment of the NDT. Had
the NDT received the support promised by DOE, all discovered sources
would have been collected into a single location, thereby easing
elimination requirements. DOE was unresponsive to DTRA's requests for
support, which resulted in burdening the elimination phase of the
operation. The Department has provided guidance to its operational
theater on the conduct of operations. To expect combat troops to safely
handle these materials demonstrates a total lack of understanding of
the problem and would present serious health and safety issues. The
Department concurs with that part of the recommendation that addresses
elimination operations. As a new mission, much work is being done and
more is required to adequately address the shortfalls encountered.
RECOMMENDATION 3: The GAO recommended that the Secretary of Defense
work with DOE, to determine criteria that define which radiological
sources: (a) are of greatest risk and should be collected; (b) are
being properly used and secured, and thus can be left in place; and (c)
pose minimal threat and thus do not need to be collected. (p. 36/GAO
Draft Report):
DOD RESPONSE: Concur. DTRA and DOE have established a list of
radiological sources that is prioritized in accordance with risk
factors.
RECOMMENDATION 4: The GAO recommended that the Secretary of Defense
specify the health and safety criteria, and ensure the commensurate
expertise and equipment needed for collecting, securing, and disposing
of sources. (p. 36/GAO Draft Report):
DOD RESPONSE: Non-concur. Recommendation is too broad and ill defined.
Guidance is and always has been available. Since OIF was the first time
in recent history that a capability was developed and deployed to
counter a WMD threat, no unit level standard operating procedures (SOP)
existed. However, the NDT developed a SOP as well as Tactics,
techniques and procedures to address all these issues. The NDT
continues to work with the 20tH Support Command to develop changes to
existing regulations to address all these particulars.
RECOMMENDATION 5: The GAO recommended that the Secretary of Defense
establish and coordinate the organization(s) responsible within DOD for
collecting, securing, and disposing of sources. (p. 37/GAO Draft
Report):
DOD RESPONSE: Non-concur. The Department has already identified this
organization as the NDT. Additionally, the Secretary signed a letter on
January 6, 2005 establishing the Commander of Strategic Command to have
overall responsibility for issues relating to combating WMD. A subset
of this broader mandate is collecting, securing and deposing of
sources.
RECOMMENDATION 6: The GAO recommended that the Secretary of Defense
establish agreements and points of contact with DOE and other federal
agencies, as needed, to specify the coordination, technical expertise,
and equipment that may be needed in conducting operations to collect
and secure sources in, or remove them from, a foreign country. (p. 37/
GAO Draft Report):
DOD RESPONSE: Concur. STRATCOM in concert with DTRA is establishing all
the plans and procedures for elimination operations. They are
developing this within the inner agency to ensure all interested
parties have input.
RECOMMENDATION 7: The GAO recommended that the Secretary of Defense
identify under which circumstances and for what purposes DOD will
contract with private firms to conduct activities to collect and secure
radiological sources, and address legal and contracting barriers to the
timely use of contractors. (p. 37/GAO Draft Report):
DOD RESPONSE: Concur. STRATCOM and DTRA are working together to
determine best path forward.
RECOMMENDATION 8: The GAO recommended that the Secretary of Defense
establish guidelines concerning the role of radiological experts from
the country where sources need to be collected and secured. (p. 37/GAO
Draft Report):
DOD RESPONSE: Concur. STRATCOM is developing the plans and procedures
for elimination operations and will include support from Host Nation
assets.
[End of section]
Appendix IV: Comments from the Department of State:
United States Department of State:
Assistant Secretary and Chief Financial Officer:
Washington, D.C. 20520:
Ms. Jacquelyn Williams-Bridgers:
Managing Director:
International Affairs and Trade:
Government Accountability Office:
441 G Street, N.W.
Washington, D.C. 20548-0001:
JUN 9 2005:
Dear Ms. Williams-Bridgers:
We appreciate the opportunity to review your draft report,
"RADIOLOGICAL SOURCES IN IRAQ: DOD Should Evaluate Its Source Recovery
Effort and Apply Lessons Learned to Future Recovery Missions," GAO Job
Code 360459.
The enclosed Department of State comments are provided for
incorporation with this letter as an appendix to the final report.
If you have any questions concerning this response, please contact
Andrew Sowder, Physical Scientist, Bureau of Nonproliferation at (202)
736-4431.
Sincerely,
Signed by:
Sid Kaplan (Acting):
cc: GAO - Terry Hanford;
NP - Stephen Rademaker;
State/OIG - Mark Duda:
Department of State Comments on GAO Draft Report RADIOLOGICAL SOURCES
IN IRAQ: DOD Should Evaluate Its Source Recovery Effort and Apply
Lessons Learned to Future Recovery Missions GAO-05-XXX, GAO Code
360459:
The Department of State appreciates the opportunity to comment on the
report of the Government Accountability Office entitled, Radiological
Sources in Iraq: DOD Should Evaluate Its Source Recovery Effort and
Apply Lessons Learned to Future Recovery Missions.
1. The report appears to characterize the outlook for U.S. assistance
to Iraq for radioactive source regulatory development in an overly
pessimistic fashion. For example, the following phrase and various
permutations occur repeatedly in the text (e.g., on pages 1 (summary),
8, 27, and elsewhere):
"...However, according to State officials, the transition to a new
Iraqi government is creating uncertainties for the source regulatory
agency and U.S. assistance."
The outlook, while still uncertain, has improved in the interim. We are
much less concerned now about the survival of the Iraqi Radioactive
Source Regulatory Authority (IRSRA) and are focussing our support on
the continued development of IRSRA into a sustainable, independent, and
competent regulatory authority. To this end, the discussion on pages 29-
30 reflects the progress we have made and our continuing support of
Iraqi regulatory development. Perhaps a better characterization of
State Department views would be captured in the following:
"However, according to State officials, unavoidable uncertainties
associated with the continued evolution of the Iraqi government calls
for monitoring of the program to ensure continued growth and success of
an independent, competent, and sustainable regulatory authority for the
control of radioactive sources and materials."
2. Clarification is needed in the discussion of State Department
approval of export licensing of U.S. origin defense products under the
International Traffic in Arms Regulations (ITAR). We suggest amending
paragraph 3 on page 16, to include the following explanation for the
delayed approval of a DTRA export request cited in the text:
"The Department has established procedures for expedited processing of
export applications submitted in support of Operation Iraqi Freedom.
However, the application in question was required by law, Section 1514
of the Emergency Wartime Supplemental, to have a national Interest
Determination at the Deputy Secretary level and subsequent
congressional notification. As the application was received when
Congress was not in session and notifications cannot be forwarded when
they are not, the notification was made when they returned and the
license subsequently issued."
[End of section]
Appendix V: GAO Contact and Staff Acknowledgments:
GAO Contact:
Gene Aloise, (202) 512-3841:
Staff Acknowledgments:
In addition to the contact named above, Lee Carroll, Nancy Crothers,
Davi M. D'Agostino, Dan Feehan, Peter Grana, Terry Hanford, Dave
Maurer, Judy Pagano, and Keith Rhodes (GAO's Chief Technologist) made
key contributions to this report.
(360459):
FOOTNOTES
[1] For information on DTRA's broader mission to address the threat of
WMD, see GAO, Weapons of Mass Destruction: Defense Threat Reduction
Agency Addresses Broad Range of Threats, but Performance Reporting Can
Be Improved, GAO-04-330 (Washington, D.C.: Feb. 13, 2004).
[2] The Coalition Provisional Authority, led by the United States and
the United Kingdom, was responsible for temporarily governing Iraq.
[3] The count of approximately 700 sources left in place may be an
undercount because devices with radiological sources, such as medical
equipment, were counted as one source in DTRA's inventory, but could
possibly include more than one source inside. Appendix I includes a
discussion of the reliability of the data on sources.
[4] Iraqi subcontractors provided their own armed security during their
missions to collect sources or document sources left in place.
[5] Coalition Provisional Authority Order Number 72, "Iraqi Radioactive
Source Regulatory Authority," CPA/ORD/10 June 2004/72 (June 10, 2004).
[6] The analysis does not address DTRA's contracting of DOE experts for
the collection mission, which was conducted before the joint DOE and
DTRA removal mission.
[7] Rebecca K.C. Hersman, "Eliminating Adversary Weapons of Mass
Destruction: What's at Stake?" (occasional paper, National Defense
University Press, Washington, D.C., December 2004).
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