Combating Nuclear Smuggling
DHS Improved Testing of Advanced Radiation Detection Portal Monitors, but Preliminary Results Show Limits of the New Technology Gao ID: GAO-09-655 May 21, 2009The Department of Homeland Security's (DHS) Domestic Nuclear Detection Office (DNDO) is testing new advanced spectroscopic portal (ASP) radiation detection monitors. DNDO expects ASPs to reduce both the risk of missed threats and the rate of innocent alarms, which DNDO considers to be key limitations of radiation detection equipment currently used by Customs and Border Protection (CBP) at U.S. ports of entry. Congress has required that the Secretary of DHS certify that ASPs provide a significant increase in operational effectiveness before obligating funds for full-scale procurement. GAO was asked to review (1) the degree to which DHS's criteria for a significant increase in operational effectiveness address the limitations of existing radiation detection equipment, (2) the rigor of ASP testing and preliminary test results, and (3) the ASP test schedule. GAO reviewed the DHS criteria, analyzed test plans, and interviewed DHS officials.
The DHS criteria for a significant increase in operational effectiveness require a minimal improvement in the detection of threats and a large reduction in innocent alarms. Specifically, the criteria require a marginal improvement in the detection of certain weapons-usable nuclear materials, considered to be a key limitation of current-generation portal monitors. The criteria require improved performance over the current detection threshold, which for certain nuclear materials is based on the equipment's limited sensitivity to anything more than lightly shielded materials, but do not specify a level of shielding that smugglers could realistically use. In addition, DNDO has not completed efforts to improve current-generation portal monitors' performance. As a result, the criteria do not take the current equipment's full potential into account. With regard to innocent alarms, the other key limitation of current equipment, meeting the criteria could result in hundreds fewer innocent alarms per day, thereby reducing CBP's workload and delays to commerce. DHS increased the rigor of ASP testing in comparison with previous tests. For example, DNDO mitigated the potential for bias in performance testing (a concern GAO raised about prior testing) by stipulating that there would be no ASP contractor involvement in test execution. Such improvements added credibility to the test results. However, the testing still had limitations, such as a limited set of scenarios used in performance testing to conceal test objects from detection. Moreover, the preliminary results are mixed. The results show that the new portal monitors have a limited ability to detect certain nuclear materials at anything more than light shielding levels: ASPs performed better than current-generation portal monitors in detection of such materials concealed by light shielding approximating the threat guidance for setting detection thresholds, but differences in sensitivity were less notable when shielding was slightly below or above that level. Testing also uncovered multiple problems in ASPs meeting the requirements for successful integration into operations at ports of entry. CBP officials anticipate that, if ASPs are certified, new problems will appear during the first few years of deployment in the field. While DNDO's schedule underestimated the time needed for ASP testing, test delays have allowed more time for review and analysis of results. DNDO's original schedule anticipated completion in September 2008. Problems uncovered during testing of ASPs' readiness to be integrated into operations at U.S. ports of entry caused the greatest delays to this schedule. DHS's most recent schedule anticipated a decision on ASP certification as early as May 2009, but DHS recently suspended field validation due to ASP performance problems and has not updated its schedule for testing and certification. In any case, DNDO does not plan to complete computer simulations that could provide additional insight into ASP capabilities and limitations prior to certification even though delays have allowed more time to conduct the simulations. DNDO officials believe the other tests are sufficient for ASPs to demonstrate a significant increase in operational effectiveness.
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-09-655, Combating Nuclear Smuggling: DHS Improved Testing of Advanced Radiation Detection Portal Monitors, but Preliminary Results Show Limits of the New Technology
This is the accessible text file for GAO report number GAO-09-655
entitled 'Combating Nuclear Smuggling: DHS Improved Testing of Advanced
Radiation Detection Portal Monitors, but Preliminary Results Show
Limits of the New Technology' which was released on June 22, 2009.
This text file was formatted by the U.S. Government Accountability
Office (GAO) to be accessible to users with visual impairments, as part
of a longer term project to improve GAO products' accessibility. Every
attempt has been made to maintain the structural and data integrity of
the original printed product. Accessibility features, such as text
descriptions of tables, consecutively numbered footnotes placed at the
end of the file, and the text of agency comment letters, are provided
but may not exactly duplicate the presentation or format of the printed
version. The portable document format (PDF) file is an exact electronic
replica of the printed version. We welcome your feedback. Please E-mail
your comments regarding the contents or accessibility features of this
document to Webmaster@gao.gov.
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed
in its entirety without further permission from GAO. Because this work
may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this
material separately.
Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
May 2009:
Combating Nuclear Smuggling:
DHS Improved Testing of Advanced Radiation Detection Portal Monitors,
but Preliminary Results Show Limits of the New Technology:
GAO-09-655:
GAO Highlights:
Highlights of GAO-09-655, a report to congressional requesters.
Why GAO Did This Study:
The Department of Homeland Security‘s (DHS) Domestic Nuclear Detection
Office (DNDO) is testing new advanced spectroscopic portal (ASP)
radiation detection monitors. DNDO expects ASPs to reduce both the risk
of missed threats and the rate of innocent alarms, which DNDO considers
to be key limitations of radiation detection equipment currently used
by Customs and Border Protection (CBP) at U.S. ports of entry. Congress
has required that the Secretary of DHS certify that ASPs provide a
significant increase in operational effectiveness before obligating
funds for full-scale procurement. GAO was asked to review (1) the
degree to which DHS‘s criteria for a significant increase in
operational effectiveness address the limitations of existing radiation
detection equipment, (2) the rigor of ASP testing and preliminary test
results, and (3) the ASP test schedule. GAO reviewed the DHS criteria,
analyzed test plans, and interviewed DHS officials.
What GAO Found:
The DHS criteria for a significant increase in operational
effectiveness require a minimal improvement in the detection of threats
and a large reduction in innocent alarms. Specifically, the criteria
require a marginal improvement in the detection of certain weapons-
usable nuclear materials, considered to be a key limitation of current-
generation portal monitors. The criteria require improved performance
over the current detection threshold, which for certain nuclear
materials is based on the equipment‘s limited sensitivity to anything
more than lightly shielded materials, but do not specify a level of
shielding that smugglers could realistically use. In addition, DNDO has
not completed efforts to improve current-generation portal monitors‘
performance. As a result, the criteria do not take the current
equipment‘s full potential into account. With regard to innocent
alarms, the other key limitation of current equipment, meeting the
criteria could result in hundreds fewer innocent alarms per day,
thereby reducing CBP‘s workload and delays to commerce.
DHS increased the rigor of ASP testing in comparison with previous
tests. For example, DNDO mitigated the potential for bias in
performance testing (a concern GAO raised about prior testing) by
stipulating that there would be no ASP contractor involvement in test
execution. Such improvements added credibility to the test results.
However, the testing still had limitations, such as a limited set of
scenarios used in performance testing to conceal test objects from
detection. Moreover, the preliminary results are mixed. The results
show that the new portal monitors have a limited ability to detect
certain nuclear materials at anything more than light shielding levels:
ASPs performed better than current-generation portal monitors in
detection of such materials concealed by light shielding approximating
the threat guidance for setting detection thresholds, but differences
in sensitivity were less notable when shielding was slightly below or
above that level. Testing also uncovered multiple problems in ASPs
meeting the requirements for successful integration into operations at
ports of entry. CBP officials anticipate that, if ASPs are certified,
new problems will appear during the first few years of deployment in
the field.
While DNDO‘s schedule underestimated the time needed for ASP testing,
test delays have allowed more time for review and analysis of results.
DNDO‘s original schedule anticipated completion in September 2008.
Problems uncovered during testing of ASPs‘ readiness to be integrated
into operations at U.S. ports of entry caused the greatest delays to
this schedule. DHS‘s most recent schedule anticipated a decision on ASP
certification as early as May 2009, but DHS recently suspended field
validation due to ASP performance problems and has not updated its
schedule for testing and certification. In any case, DNDO does not plan
to complete computer simulations that could provide additional insight
into ASP capabilities and limitations prior to certification even
though delays have allowed more time to conduct the simulations. DNDO
officials believe the other tests are sufficient for ASPs to
demonstrate a significant increase in operational effectiveness.
What GAO Recommends:
GAO recommends that DHS assess ASPs against the full potential of
current equipment and revise the program schedule to allow time to
conduct computer simulations of ASPs‘ capabilities and to uncover and
resolve problems with ASPs before full-scale deployment. DHS agreed to
a phased deployment that should allow time to uncover ASP problems but
disagreed with GAO‘s other recommendations. GAO believes its
recommendations remain valid.
View [hyperlink, http://www.gao.gov/products/GAO-09-655] or key
components. For more information, contact Gene Aloise at (202) 512-3841
or aloisee@gao.gov.
[End of section]
Contents:
Letter:
DHS's Criteria for Significant Increase in Operational Effectiveness
Require a Marginal Improvement in the Detection of Certain Nuclear
Materials and a Large Reduction in Innocent Alarms:
DHS Increased the Rigor of Advanced Portal Monitor Testing:
Schedule Delays Have Allowed More Time for Analysis and Review of Test
Results, but DNDO's Latest Schedule Does Not Include Computer
Simulations to Provide Additional Insight into ASP Capabilities:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Department of Homeland Security:
Appendix III: GAO Contact and Staff Acknowledgments:
Figures:
Figure 1: DHS Criteria for Demonstrating a Significant Increase in
Operational Effectiveness:
Figure 2: Test Sequence Leading Up to ASP Certification:
Figure 3: Preliminary Results from 2008 Performance Testing for
Detection of Certain Nuclear Materials:
Abbreviations:
ASP: advanced spectroscopic portal:
CBP: Customs and Border Protection:
DHS: Department of Homeland Security:
DNDO: Domestic Nuclear Detection Office:
DOE: Department of Energy:
HEU: highly enriched uranium:
PVT: polyvinyl toluene:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
May 21, 2009:
Congressional Requesters:
Preventing radioactive material from being smuggled into the United
States is a key national security objective. In particular, terrorists
could use special nuclear material such as highly enriched uranium
(HEU) or plutonium in a nuclear weapon; other radioactive materials
could be used in a radiological dispersal device (a "dirty bomb"). The
national security mission of U.S. Customs and Border Protection (CBP),
an agency within the Department of Homeland Security (DHS), includes
screening for smuggled nuclear or radiological material while
facilitating the flow of legitimate trade and travel. To screen cargo
at ports of entry, CBP conducts primary inspections with radiation
detection equipment called portal monitors--large stationary detectors
through which cargo containers and vehicles pass as they enter the
United States. When radiation is detected, CBP conducts secondary
inspections using a second portal monitor to confirm the original alarm
and a handheld radioactive isotope identification device to identify
the radiation's source and determine whether it constitutes a threat.
CBP officers must investigate each alarm until they are convinced that
the vehicle, occupants, and any cargo pose no threat and can be allowed
to enter the United States.
According to DHS's Domestic Nuclear Detection Office (DNDO), the
current generation of radiation detection equipment has limitations.
[Footnote 1] Specifically, the polyvinyl toluene (PVT) portal monitors
currently in use can detect radiation but cannot identify the source.
As a result, the monitors' radiation alarms can be set off even by
benign, naturally occurring radioactive material. One way to reduce the
rate of such innocent alarms--and thereby minimize unnecessary
secondary inspections and enhance the flow of commerce--is to adjust
the operational thresholds for the level of radiation required for PVTs
to alarm (i.e., operate the PVTs at a reduced level of sensitivity).
However, reducing the sensitivity may make it more difficult to detect
certain nuclear materials.
Since 2005, DNDO has been developing and testing advanced spectroscopic
portals (ASP), a new type of portal monitor designed to both detect
radiation and identify the source. The new portal monitors use
technology similar to that in handheld identification devices currently
used for secondary screening. Key differences from handheld
identification devices include a larger number of detectors, more
sophisticated software, and a more extensive library of radiation
signatures that may provide more consistent and rapid screening and may
increase the likelihood of correct identification. DNDO hopes to use
the new portal monitors to replace at least some PVTs currently used
for primary screening, as well as PVTs and handheld identification
devices currently used for secondary screening. However, the new portal
monitors cost significantly more than PVTs. We estimated in September
2008 that the lifecycle cost of each standard cargo version of the ASP
(including deployment costs) is about $822,000, compared with about
$308,000 for the PVT standard cargo portal, and that the total program
cost for DNDO's latest plan for deploying radiation portal monitors--
which relies on a combination of ASPs and PVTs and does not deploy
radiation portal monitors at all border crossings--would be about $2
billion.[Footnote 2] Moreover, CBP officials expect operation and
maintenance costs to be significantly higher for ASPs than for PVTs
because of the greater complexity of ASP equipment.
Concerned about the performance and cost of the new ASP monitors,
Congress required the Secretary of Homeland Security to certify that
the monitors will provide a "significant increase in operational
effectiveness" before DNDO obligates funds for full-scale ASP
procurement.[Footnote 3] The Secretary must submit separate
certifications for primary and secondary inspection. In response, DNDO,
CBP, and the DHS management directorate jointly issued criteria in July
2008 for determining whether the new technology provides a significant
increase in operational effectiveness--four criteria for primary
screening and two for secondary screening (see figure 1). The primary
screening criteria require that the new portal monitors detect
potential threats as well as or better than PVTs, show improved
performance in detection of HEU, and reduce innocent alarms. To meet
the secondary screening criteria, the new portal monitors must reduce
the probability of misidentifying special nuclear material (e.g., HEU
and plutonium) and the average time to conduct secondary screenings.
Figure 1: DHS Criteria for Demonstrating a Significant Increase in
Operational Effectiveness:
[Refer to PDF for image: illustration]
Primary screening criteria:
When special nuclear material is present in cargo without naturally
occurring radioactive material, the ASP probability of a correct
operational outcome must be equal to or greater than that of the PVT.
(For HEU, ASPs must show improved performance compared to PVTs at
operational thresholds.)
When special nuclear material is present in cargo with naturally
occurring radioactive material, the ASP in primary must increase the
probability of a correct operational outcome compared to the current
end-to-end system.
When licensable medical or industrial isotopes are present in cargo,
the ASP probability of a correct operational outcome must be equal to
or greater than that of the PVT.
When the only radioactive source present in the cargo is naturally
occurring radioactive material, the ASP must refer at least 80 percent
fewer conveyances for further inspection than the PVT.
Secondary screening criteria:
When compared to the handheld radioactive isotope identification device,
ASP must reduce, by at least a factor of two, the probability that
special nuclear material is misidentified as naturally occurring
radioactive material, a medical/industrial radionuclide, unknown, or no
source at all.
When compared to the handheld radioactive isotope identification device,
the ASP must reduce the average time required to correctly release
conveyances from secondary screening.
Source: DHS.
[End of figure]
To demonstrate a significant increase in operational effectiveness for
either primary or secondary screening, ASPs must satisfy all of the
criteria for that deployment option, independent of satisfying the
criteria for the other option. The criteria generally compare the new
portal monitors to current-generation equipment as used under CBP's
standard operating procedure. For example, the standard operating
procedure for secondary screening calls for inconclusive readings to be
sent for additional analysis to CBP's Laboratories and Scientific
Services, which has access to additional software and trained experts.
DNDO designed and coordinated a series of tests, originally scheduled
to run from April 2008 through September 2008, to determine whether the
new portal monitors meet the certification criteria for primary and
secondary screening and are ready for deployment. Key phases of testing
completed to date include verifying that ASPs meet DNDO's performance
specification, which was followed by concurrent testing of the new and
current equipments' ability to detect and identify threats and of ASPs'
readiness to be integrated into operations for both primary and
secondary screening at ports of entry. Two remaining phases not yet
completed include field validation at four northern and southern border
crossings and two seaports, as well as an independent evaluation,
conducted by the DHS Science and Technology Directorate at one of the
seaports, of the new portal monitors' effectiveness and suitability
(see figure 2). Two ASP vendors have contracts with DNDO to develop the
new portal monitors and are participating in the round of testing that
began in 2008.[Footnote 4] DNDO designed the testing to allow each
vendor's system to complete all test phases and be certified based on
its own performance as providing a significant increase in operational
effectiveness.
Figure 2: Test Sequence Leading Up to ASP Certification:
[Refer to PDF for image: illustration]
Lead agency: DNDO;
Phase: System qualification test: Verify technical achievement of
ASP performance specification.
Lead agency: DNDO;
Phase: Concurrent performance and integration testing: Performance
testing: Evaluate ASP performance for detection and identification of
threats; Integration testing: Demonstrate that ASPs are ready to be
integrated into the interdiction systems at U.S. ports of entry and to
advance to field validation.
Lead agency: CBP;
Phase: Field validation: Perform system installation procedures and
process, train CBP officers in ASP use, and use ASPs to screen cargo.
Lead agency: DHS Science and Technology Directorate;
Phase: Operational test and evaluation: Conduct an independent
evaluation of ASP effectiveness and suitability when operated by CBP.
Source: GAO analysis of DNDO information.
[End of figure]
We have raised concerns since 2006 regarding DNDO's previous efforts to
develop and test the new portal monitors. In October 2006, we found
that DNDO's analysis of the benefits and costs of deploying the new
portal monitors relied on assumptions of their anticipated performance
level instead of actual test data.[Footnote 5] Among other things, we
recommended that DNDO conduct further testing before spending
additional funds to purchase the new equipment. In September 2007, we
testified that DNDO's testing at the Department of Energy's (DOE)
Nevada Test Site did not represent an objective or rigorous assessment
because DNDO used biased test methods that enhanced the apparent
performance of the ASPs and did not test the limitations of their
detection capabilities.[Footnote 6] Most recently, we found in
September 2008 that a DNDO report on testing conducted in 2007 did not
accurately depict test results and could potentially be misleading.
[Footnote 7] We concluded that the results could identify areas for
improvement but should not be used as indicators of ASPs' overall
performance.
In this context, you asked us to review the 2008 round of testing
leading up to the Secretary of Homeland Security's decision on ASP
certification. We reviewed (1) the degree to which DHS's criteria for a
significant increase in operational effectiveness address the
limitations of the current generation of radiation detection equipment,
(2) the rigor of the testing as a basis for determining ASPs'
operational effectiveness and preliminary results of testing completed
to date, and (3) the extent to which the test schedule allows time for
DHS to review and analyze results. This report updates our September
2008 testimony, which included preliminary observations on the DHS
criteria for a significant increase in operational effectiveness and
the 2008 round of testing.[Footnote 8]
To conduct our review, we analyzed DHS's criteria for a significant
increase in operational effectiveness and DNDO's written response to
our detailed questions regarding the criteria. Because the criteria
compare the new portal monitors to existing equipment, we analyzed the
threat guidance used to set detection thresholds for PVTs and
interviewed DOE and national laboratory officials responsible for the
guidance. In addition, we analyzed the test plans for the 2008 round of
testing, including the test schedule and reasons for any delays. We
interviewed DNDO, CBP, and other DHS officials responsible for
conducting and monitoring tests, and we observed 1 day each of
performance testing at the Nevada Test Site and integration testing at
DOE's Pacific Northwest National Laboratory. We analyzed preliminary or
final results for the phases of testing completed during our review,
and we interviewed DNDO and CBP officials regarding the results.
(Appendix I presents a detailed discussion of the scope and methodology
of our review.)
We conducted this performance audit from May 2008 to May 2009 in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.[Footnote 9]
DHS's Criteria for Significant Increase in Operational Effectiveness
Require a Marginal Improvement in the Detection of Certain Nuclear
Materials and a Large Reduction in Innocent Alarms:
Although the DHS criteria for primary screening require an improved
ability to detect certain nuclear materials at operational thresholds,
ASPs could meet the criteria for improvement while still failing to
detect anything more than lightly shielded material. DNDO officials
acknowledge that passive radiation detection equipment, which includes
both the new and current-generation portal monitors, is capable of
detecting certain nuclear materials only when this material is
unshielded or lightly shielded.[Footnote 10] For this reason, the DOE
threat guidance used to set PVTs' detection threshold is based on the
equipment's limited sensitivity to anything more than lightly shielded
nuclear material rather than on the assumption that smugglers would
take effective shielding measures. DOE developed the guidance in 2002
and 2003 when CBP began deploying PVTs for primary screening. DOE and
national laboratory officials responsible for the guidance told us the
assumption of light shielding was based not on an analysis of the
capabilities of potential smugglers to take effective shielding
measures but rather on the limited sensitivity of PVTs to detect
anything more than certain lightly shielded nuclear materials. In
contrast, PVTs are more sensitive to the relatively strong radiation
signature of other nuclear materials, and the threat guidance assumes a
higher level of shielding for setting the operational threshold for
detection of such materials. However, even for such materials, the DOE
threat guidance assumes that shielding would not exceed a level
provided by the contents of an average cargo container.
Moreover, DNDO has not completed efforts to fine-tune PVTs' software
and thereby improve sensitivity to nuclear materials. As a result, the
criteria compare ASPs to the current performance of PVTs and do not
take potential improvements into account, which affects any assessment
of "significant" improvement over current technology. DNDO officials
expect they can achieve small improvements to PVTs' performance through
additional development of "energy windowing," a technique currently
being used in PVTs to provide greater sensitivity than otherwise
possible. Pacific Northwest National Laboratory officials responsible
for developing the technique also told us small improvements may be
possible, and CBP officials have repeatedly urged DNDO to investigate
the potential of the technique. DNDO collected the data needed to
further develop energy windowing during the 2008 performance testing at
the Nevada Test Site but has not yet funded Pacific Northwest National
Laboratory efforts to analyze the data and further develop the
technique.
Other aspects of the criteria for a significant increase in operational
effectiveness require that ASPs either provide more than a marginal
improvement in addressing other limitations of current-generation
equipment or at least maintain the same level of performance in areas
in which the current-generation equipment is considered adequate:
* The primary screening requirement for an 80 percent reduction in the
rate of innocent alarms could result in hundreds of fewer secondary
screenings per day, thereby reducing CBP's workload and delays to
commerce. The actual reduction in the volume of innocent alarms would
vary and would be greatest at the nation's busiest ports of entry, such
as Los Angeles/Long Beach, where CBP officials report that PVTs
generate up to about 600 innocent alarms per day.[Footnote 11] A DNDO
official said the requirement for an 80 percent reduction in innocent
alarms was developed in conjunction with CBP and was based on a level
that would provide meaningful workload relief.
* The primary screening criteria requiring that ASPs provide at least
the same level of sensitivity to plutonium and medical and industrial
isotopes, but not specifying an improvement, were based on DNDO's
assessment that PVTs adequately detect such materials, which have a
stronger radiation signature than HEU.[Footnote 12] In addition, CBP
officials said that including medical and industrial isotopes in the
criteria addressed a CBP requirement for verifying that those
transporting certain quantities of these materials into the United
States are properly licensed.[Footnote 13]
* The secondary screening requirement that ASPs reduce the probability
of misidentifying special nuclear material by one-half addresses the
inability of relatively small handheld devices to consistently locate
and identify potential threats in large cargo containers. For example,
a handheld device may fail to correctly identify special nuclear
material if the material is well-shielded or the device is not placed
close enough to a radiation source to obtain a recognizable
measurement. According to CBP and DNDO, the requirement for a reduction
in the average time to conduct secondary screenings is not more
specific because the time varies significantly among ports of entry and
types of cargo being screened.
DHS Increased the Rigor of Advanced Portal Monitor Testing:
Improvements to the 2008 round of testing addressed concerns we raised
about earlier rounds of ASP testing. However, the testing still had
limitations, and the preliminary results are mixed.
Improvements to Testing Provided Credibility to Test Results:
As we testified in September 2008, DHS's improvements to the 2008 round
of ASP testing addressed concerns we raised about previous tests. A
particular area of improvement was in the performance testing at the
Nevada Test Site, where DNDO compared the capability of ASP and current-
generation equipment to detect and identify nuclear and radiological
materials, including those that could be used in a nuclear weapon. The
improvements addressed concerns we previously raised about the
potential for bias and provided credibility to the results within the
limited range of scenarios tested by DNDO. For example, we reported in
2007 that DNDO had allowed ASP contractors to adjust their systems
after preliminary runs using the same radiological materials that would
be used in the formal tests. In contrast, the plan for the 2008
performance test stipulated that there would be no system contractor
involvement in test execution, and no ASP contractors were at the test
location on the day we observed performance testing. Furthermore, DNDO
officials told us, and we observed, that they did not conduct
preliminary runs with threat objects used in the formal tests. In 2007,
we reported that DNDO did not objectively test the handheld
identification devices because it did not adhere to CBP's standard
operating procedure for using the devices to conduct a secondary
inspection, which is fundamental to the equipment's performance in the
field. DNDO addressed this limitation in the 2008 round of performance
testing: CBP officers operated the devices and adhered as closely to
the standard operating procedure as test conditions allowed. While the
test conditions did not allow CBP officers to obtain real-time
technical support in interpreting the device's measurements, as they
would in the field to increase the probability of correctly identifying
a radiation source, DNDO officials said they addressed this limitation.
For example, they treated a decision by a CBP officer to indicate the
need for technical support as a correct outcome if the test scenario
involved the use of a potential threat, such as HEU.
Other aspects of testing, while not specifically addressing concerns we
previously raised, also added credibility to the test results. Based on
our analysis of the performance test plan, we concluded that the test
design was sufficient to identify statistically significant differences
between the new technology and current-generation systems when there
were relatively large differences in performance. Specifically, DNDO
conducted a sufficient number of runs of each scenario used in the 2008
performance testing to identify such differences.
With regard to the general conduct of the 2008 round of testing, two
aspects, in particular, enhanced the overall rigor of the tests: (1)
criteria for ensuring that ASPs met the requirements for each phase
before advancing to the next, and (2) the participation of CBP and the
DHS Science and Technology Directorate.[Footnote 14] The test and
evaluation master plan established criteria requiring that the ASPs
have no critical or severe issues rendering them completely unusable or
impairing their function before starting or completing any test phase.
In addition, the criteria established a cumulative limit of 10 issues
requiring a work-around (e.g., a straightforward corrective step, such
as a minor change in standard operating procedures) and 15 cosmetic
issues not affecting proper functioning. DNDO and CBP adhered to the
criteria even though doing so resulted in integration testing conducted
at the Pacific Northwest National Laboratory taking longer than
anticipated and delaying the start of field validation. For example,
DNDO and CBP did not allow a vendor's ASP system to complete
integration testing until all critical or severe issues had been
resolved.
The involvement of CBP and the DHS Science and Technology Directorate
provided an independent check, within DHS, of DNDO's efforts to develop
and test the new portal monitors. For example, the lead CBP official
involved in ASP testing told us that DNDO provided an initial
assessment of the severity of issues uncovered during testing, but CBP
made the final decision on categorizing them as critical, severe, work-
around, or cosmetic issues. CBP also added a final requirement to
integration testing before proceeding to field validation to
demonstrate ASPs' ability to operate for 40 hours without additional
problems. According to CBP officials, their efforts to resolve issues
prior to field validation reflect the importance CBP places on ensuring
that ASPs are sufficiently stable and technically mature to operate
effectively in a working port of entry and thereby provide for a
productive field validation.
The DHS Science and Technology Directorate, which is responsible for
developing and implementing the department's test and evaluation
policies and standards, will have the lead role in the final phase of
ASP testing; the final phase, consisting of 21 days of continuous
operation, is scheduled to begin at one seaport after the completion of
field validation. The Science and Technology Directorate identified two
critical questions to be addressed through operational testing: (1)
Will the ASP system improve operational effectiveness (i.e., detection
and identification of threats) relative to the current-generation
system, and (2) is the ASP system suitable for use in the operational
environment at land and sea ports of entry? The suitability of ASPs
includes factors such as reliability, maintainability, and
supportability. Because the operational testing conducted at one
seaport is not sufficient to fully answer these questions--for example,
because the testing will not allow threat objects to be inserted into
cargo containers--the directorate plans to also conduct an independent
analysis of the results from previous test phases, including
performance testing.
The 2008 testing still had limitations, which do not detract from the
test results' credibility but do require that results be appropriately
qualified. Limitations included the following:
* The number of handheld identification device measurements collected
during performance testing was sufficient to distinguish only
particularly large differences from ASPs' identification ability. In
particular, the standard operating procedure for conducting secondary
inspections using ASPs, which requires less time than when using
handheld devices, allowed DNDO to collect more than twice as many ASP
measurements and to test ASPs' identification ability against more
radiation sources than used to test handheld identification devices.
* The performance test results cannot be generalized beyond the limited
set of scenarios tested. For example, DNDO used a variety of masking
and shielding scenarios designed to include cases where both systems
had 100 percent detection, cases where both had zero percent detection,
and several configurations in between so as to estimate the point where
detection capability ceased.[Footnote 15] However, the scenarios did
not represent the full range of possibilities for concealing smuggled
nuclear or radiological material. For example, DNDO only tested
shielding and masking scenarios separately, to differentiate between
the impacts of shielding and masking on the probabilities of detection
and identification. As a result, the performance test results cannot
show how well each system would detect and identify nuclear or
radiological material that is both shielded and masked, which might be
expected in an actual smuggling incident. Similarly, DNDO used a
limited number of threat objects to test ASPs' detection and
identification performance, such as weapons-grade plutonium but not
reactor-grade plutonium, which has a different isotopic composition. A
report on special testing of ASPs conducted by Sandia National
Laboratories in 2007 recommended that future tests use plutonium
sources having alternative isotopic compositions. Sandia based its
recommendations on results showing that the performance of ASP systems
varied depending on the isotopic composition of plutonium.
* The Science and Technology Directorate's operational testing is
designed to demonstrate that the average time between equipment
failures (the measure of ASPs' reliability) is not less than 1,000
hours. Thus, the testing will not show how reliable the equipment will
be over a longer term. DHS Science and Technology Directorate officials
recognize this limitation and said they designed operational testing
only to demonstrate compliance with the ASP performance specification.
Furthermore, to the extent that the Science and Technology Directorate
relies on performance test results to evaluate ASPs' ability to detect
and identify threats, its analysis of ASPs' effectiveness will be
subject to the same limitations as the original testing and analysis
conducted by DNDO.
Preliminary Test Results Are Mixed:
The preliminary results presented to us by DNDO are mixed, particularly
in the capability of ASPs used for primary screening to detect certain
shielded nuclear materials. However, we did not obtain DNDO's final
report on performance testing conducted at the Nevada Test Site until
early April 2009, and thus we had limited opportunity to evaluate the
report. In addition, we are not commenting on the degree to which the
final report provides a fair representation of ASPs' performance.
Preliminary results from performance testing show that the new portal
monitors detected certain nuclear materials better than PVTs when
shielding approximated DOE threat guidance, which is based on light
shielding. In contrast, differences in system performance were less
notable when shielding was slightly increased or decreased: Both the
PVTs and ASPs were frequently able to detect certain nuclear materials
when shielding was below threat guidance, and both systems had
difficulty detecting such materials when shielding was somewhat greater
than threat guidance. DNDO did not test ASPs or PVTs against moderate
or greater shielding because such scenarios are beyond both systems'
ability. (See figure 3 for a summary of performance test results for
detection of certain nuclear materials.)
Figure 3: Preliminary Results from 2008 Performance Testing for
Detection of Certain Nuclear Materials:
[Refer to PDF for image: table]
Portal monitor system: ASP;
At lowest shielding levels tested: Frequent;
Light shielding: At about DOE threat guidance: Frequent;
Light shielding: At more than DOE threat guidance: Difficult;
Moderate to heavy shielding: Difficult.
Portal monitor system: PVT;
At lowest shielding levels tested: Difficult;
Light shielding: At about DOE threat guidance: Difficult;
Light shielding: At more than DOE threat guidance: Difficult;
Moderate to heavy shielding: Difficult.
Source: GAO analysis of DNDO information.
Note: The specific amount and type of shielding assumed in DOE threat
guidance is classified.
[End of figure]
With regard to secondary screening, ASPs performed better than handheld
devices in identification of threats when masked by naturally occurring
radioactive material. However, differences in the ability to identify
certain shielded nuclear materials depended on the level of shielding,
with increasing levels appearing to reduce any ASP advantages over the
handheld identification devices--another indication of the fundamental
limitation of passive radiation detection.
Other phases of testing, particularly integration testing, uncovered
multiple problems meeting requirements for successfully integrating the
new technology into operations at ports of entry. Of the two ASP
vendors participating in the 2008 round of testing, one has fallen
several months behind in testing due to the severity of the problems it
encountered during integration testing; the problems were so severe
that it may have to redo previous test phases to be considered for
certification. The other vendor's system completed integration testing,
but CBP suspended field validation of the system after 2 weeks because
of serious performance problems that may require software revisions. In
particular, CBP found that the performance problems resulted in an
overall increase in the number of referrals for secondary screening
compared to the existing equipment. According to CBP, this problem will
require significant corrective actions before testing can resume; such
corrective actions could in turn change the ability of the ASP system
to detect threats. The problem identified during field validation was
in addition to ones identified during integration testing, which
required multiple work-arounds and cosmetic changes before proceeding
to the next test phase. For example, one problem requiring a work-
around related to the amount of time it takes for the ASP to sound an
alarm when a potential threat material has been detected.
Specifications require that ASPs alarm within two seconds of a vehicle
exiting the ASP. However, during testing, the vendor's ASP took longer
to alarm when a particular isotope was detected. The work-around to be
implemented during field validation requires that all vehicles be
detained until cleared by the ASP; the effect on commerce must
ultimately be ascertained during field validation.
CBP officials anticipate that they will continue to uncover problems
during the first few years of use if the new technology is deployed in
the field. The officials do not necessarily regard such problems to be
a sign that testing was not rigorous but rather a result of the
complexity and newness of the technology and equipment.
Schedule Delays Have Allowed More Time for Analysis and Review of Test
Results, but DNDO's Latest Schedule Does Not Include Computer
Simulations to Provide Additional Insight into ASP Capabilities:
Delays to the schedule for the 2008 round of testing have allowed more
time for analysis and review of results, particularly from performance
testing conducted at the Nevada Test Site. The original schedule, which
underestimated the time needed for testing, anticipated completion of
testing in mid-September 2008 and the DHS Secretary's decision on ASP
certification between September and November 2008. DHS officials
acknowledged that scheduling a certification decision shortly after
completion of testing would leave limited time to complete final test
reports and said the DHS Secretary could rely instead on preliminary
reports if the results were favorable to ASPs. DHS's most recent
schedule anticipated a decision on ASP certification as early as May
2009, but DHS has not updated its schedule for testing and
certification since suspending field validation in February 2009 due to
ASP performance problems.
Problems uncovered during testing of ASPs' readiness to be integrated
into operations at U.S. ports of entry have caused the greatest delays
to date and have allowed more time for DNDO to analyze and review the
results of performance testing. Integration testing was originally
scheduled to conclude in late July 2008 for both ASP vendors. The one
ASP system that successfully passed integration testing did not
complete the test until late November 2008--approximately 4 months
behind schedule. (The delays to integration testing were due in large
part to the adherence of DNDO and CBP to the criteria discussed earlier
for ensuring that ASPs met the requirements for each test phase.) In
contrast, delays to performance testing, which was scheduled to run
concurrently with integration testing, were relatively minor. Both ASP
systems completed performance testing in August 2008, about a month
later than DNDO originally planned.
The schedule delays have allowed more time to conduct injection
studies--computer simulations for testing the response of ASPs and PVTs
to the radiation signatures of threat objects randomly "injected"
(combined) into portal monitor records of actual cargo containers
transported into the United States, including some containers with
innocent sources of radiation. However, DNDO does not plan to complete
the studies prior to the Secretary of Homeland Security's decision on
certification even though DNDO and other officials have indicated that
the studies could provide additional insight into the capabilities and
limitations of advanced portal monitors. According to DNDO officials,
injection studies address the inability of performance testing
conducted at the Nevada Test Site to replicate the wide variety of
cargo coming into the United States and the inability to bring special
nuclear material and other threat objects to ports of entry and place
them in cargo during field validation. Similarly, while they
acknowledged that injection studies have limitations, DOE national
laboratory officials said the studies can increase the statistical
confidence in comparisons of ASPs' and PVTs' probability of detecting
threats concealed in cargo because of the possibility of supporting
larger sample sizes than feasible with actual testing. A February 2008
DHS independent review team report on ASP testing also highlighted the
benefits of injection studies, including the ability to explore ASP
performance against a large number of threat scenarios at a practical
cost and schedule and to permit an estimate of the minimum detectable
amount for various threats.[Footnote 16]
DNDO has the data needed to conduct the studies. It has supported
efforts to collect data on the radiation signatures for a variety of
threat objects, including special nuclear materials, as recorded by
both ASP and PVT systems. It has also collected about 7,000 usable
"stream-of-commerce" records from ASP and PVT systems installed at a
seaport. Furthermore, DNDO had earlier indicated that injection studies
could provide information comparing the performance of the two systems
as part of the certification process for both primary and secondary
screening. However, addressing deficiencies in the stream-of-commerce
data delayed the studies, and DNDO subsequently decided that
performance testing would provide sufficient information to support a
decision on ASP certification. DNDO officials said they would instead
use injection studies to support effective deployment of the new portal
monitors.
Conclusions:
Given that radiation detection equipment is already being used at ports
of entry to screen for smuggled nuclear or radiological materials, the
decision whether to replace existing equipment requires that the
benefits of the new portal monitors be weighed against the costs. DNDO
acknowledges that ASPs are significantly more expensive than PVTs to
deploy and maintain, and based on preliminary results from the 2008
testing, it is not yet clear that the $2 billion cost of DNDO's
deployment plan is justified. Even if ASPs are able to reduce the
volume of innocent cargo referred for secondary screening, they are not
expected to detect certain nuclear materials that are surrounded by a
realistic level of shielding better than PVTs could. Preliminary
results of DNDO's performance testing show that ASPs outperformed the
PVTs in detection of such materials during runs with light shielding,
but ASPs' performance rapidly deteriorated once shielding was slightly
increased. Furthermore, DNDO and DOE officials acknowledged that the
performance of both portal monitors in detecting such materials with a
moderate amount of shielding would be similarly poor. This was one of
the reasons that performance testing did not include runs with a
moderate level of shielding.
Two additional aspects of the 2008 round of testing call into question
whether ASPs' ability to provide a marginal improvement in detection of
nuclear materials and reduce innocent alarms warrants the cost of the
new technology. First, the DHS criteria for a significant increase in
operational effectiveness do not take into account recent efforts to
improve the current-generation portal monitors' sensitivity to nuclear
materials through the "energy windowing" technique, most likely at a
much lower cost. Data on developing this technique were collected
during the 2008 round of performance testing but have not been
analyzed. Second, while DNDO made improvements to the 2008 round of ASP
testing that provided credibility to the test results, its test
schedule does not allow for completion of injection studies prior to
certification even though the studies could provide additional insight
into the performance of the new technology. Without results from
injection studies, the Secretary of Homeland Security would have to
make a decision on certification based on a limited number of test
scenarios conducted at the Nevada Test Site.
Assuming that the Secretary of Homeland Security certifies ASPs, CBP
officials anticipate that they will discover problems with the
equipment when they start using it in the field. Integration testing
uncovered a number of such problems, which delayed testing and resulted
in ASP vendors making multiple changes to their systems. Correcting
such problems in the field could prove to be more costly and time
consuming than correcting problems uncovered through testing,
particularly if DNDO proceeds directly from certification to full-scale
deployment, as allowed under the congressional certification
requirement that ASPs provide a significant increase in operational
effectiveness.
Recommendations for Executive Action:
We recommend that the Secretary of Homeland Security direct the
Director of DNDO to take the following two actions to ensure a sound
basis for a decision on ASP certification:
* Assess whether ASPs meet the criteria for a significant increase in
operational effectiveness based on a valid comparison with PVTs' full
performance potential, including the potential to further develop PVTs'
use of energy windowing to provide greater sensitivity to threats. Such
a comparison could also be factored into an updated cost-benefit
analysis to determine whether it would be more cost-effective to
continue to use PVTs or deploy ASPs for primary screening at particular
ports of entry.
* Revise the schedule for ASP testing and certification to allow
sufficient time for review and analysis of results from the final
phases of testing and completion of all tests, including injection
studies.
If ASPs are certified, we further recommend that the Secretary of
Homeland Security direct the Director of DNDO to develop an initial
deployment plan that allows CBP to uncover and resolve any additional
problems not identified through testing before proceeding to full-scale
deployment--for example, by initially deploying ASPs at a limited
number of ports of entry.
Agency Comments and Our Evaluation:
We provided a draft of this report to DOE and DHS for their review and
comment. DOE provided technical comments, which we have incorporated
into our report as appropriate. DHS's written comments are reproduced
in appendix II.
DHS agreed in part with our recommendations. Specifically, DHS stated
that it believes its plan to deploy ASPs in phases, starting at a small
number of low-impact locations, is in accordance with our
recommendation to develop an initial deployment plan that allows
problems to be uncovered and resolved prior to full-scale deployment.
We agree that this deployment plan would address our recommendation and
note that DHS's comments are the first indication provided to us of the
department's intention to pursue such a plan.
In contrast, DHS did not concur with our recommendations to (1) assess
whether ASPs meet the criteria for a significant increase in
operational effectiveness based on a comparison with PVTs' full
potential, including further developing PVTs' use of energy windowing;
and (2) revise the ASP testing and certification schedule to allow
sufficient time for completion of all tests, including injection
studies. With regard to energy windowing, DHS stated that using current
PVT performance as a baseline for comparison is a valid approach
because the majority of increased PVT performance through energy
windowing has already been achieved. While DHS may be correct, its
assessment is based on expert judgment rather than the results of
testing and analysis being considered by the department to optimize the
use of energy windowing. Given the marginal increase in sensitivity
required of ASPs, we stand by our recommendation to assess ASPs against
PVTs' full potential. DHS can then factor PVTs' full potential into a
cost-benefit analysis prior to acquiring ASPs. On this point, DHS
commented that its current cost-benefit analysis is a reasonable basis
to guide programmatic decisions. However, upon receiving DHS's
comments, we contacted DNDO to obtain a copy of its cost-benefit
analysis and were told the analysis is not yet complete.
With regard to injection studies, DHS agreed that the schedule for ASP
certification must allow sufficient time for review and analysis of
test results but stated that DHS and DOE experts concluded injection
studies were not required for certification. DHS instead stated that
the series of ASP test campaigns would provide a technically defensible
basis for assessing the new technology against the certification
criteria. However, DHS did not rebut the reasons we cited for
conducting injection studies prior to certification, including test
delays that have allowed more time to conduct the studies and the
ability to explore ASP performance against a large number of threat
scenarios at a practical cost and schedule. On the contrary, DHS
acknowledged the delays to testing and the usefulness of injection
studies. Given that each phase of testing has revealed new information
about the capabilities and limitations of ASPs, we believe conducting
injection studies prior to certification would likely offer similar
insights and would therefore be prudent prior to a certification
decision.
DHS provided additional comments regarding our assessment of the
relative sensitivity of ASPs and PVTs and our characterization of the
severity of the ASPs' software problems uncovered during field
validation. With regard to sensitivity, DHS implied that our
characterization of the relative ability of ASPs and PVTs is inaccurate
and misleading because we did not provide a complete analysis of test
results. We disagree. First, in meetings to discuss the preliminary
results of performance testing conducted at the Nevada Test Site, DNDO
officials agreed with our understanding of the ability of ASPs and PVTs
deployed for primary screening to detect shielded nuclear materials.
Furthermore, contrary to the assertion that a complete analysis
requires a comparison of ASPs to handheld identification devices, our
presentation is consistent with DHS's primary screening criterion for
detection of shielded nuclear materials, which only requires that ASPs
be compared with PVTs. Finally, while we agree that the performance
test results require a more complete analysis, DNDO did not provide us
with its final performance test report until early April 2009, after
DHS provided its comments on our draft report. In the absence of the
final report, which DNDO officials told us took longer than anticipated
to complete, we summarized the preliminary results that DNDO presented
to us during the course of our review as well as to congressional
stakeholders.
With regard to ASP software problems uncovered during field validation,
we clarified our report in response to DHS's comment that the severity
of the problems has not yet been determined. DHS stated that its
preliminary analysis indicates the problems should be resolved by
routine adjustments to threshold settings rather than presumably more
significant software "revisions." However, given the history of lengthy
delays during ASP testing, we believe that DHS's assessment of the
severity of problems encountered during field validation may be overly
optimistic.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies to the
Secretaries of Homeland Security and Energy; the Administrator of NNSA;
and interested congressional committees. The report will also be
available at no charge on the GAO Web site at [hyperlink,
http://www.gao.gov].
If you or your staffs have any questions about this report, please
contact me at (202) 512-3841 or 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 key contributions to
this report are listed in appendix III.
Signed by:
Gene Aloise:
Director, Natural Resources and Environment:
List of Requesters:
The Honorable Joseph I. Lieberman:
Chairman:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Henry A. Waxman:
Chairman:
The Honorable John D. Dingell:
Chair Emeritus:
The Honorable Joe Barton:
Ranking Member:
Committee on Energy and Commerce:
House of Representatives:
The Honorable Bennie G. Thompson:
Chairman:
The Honorable Peter T. King:
Ranking Member:
Committee on Homeland Security:
House of Representatives:
The Honorable Edolphus Towns:
Chairman:
Committee on Oversight and Government Reform:
House of Representatives:
The Honorable Bart Gordon:
Chairman:
Committee on Science and Technology:
House of Representatives:
The Honorable Bart Stupak:
Chairman:
The Honorable Greg Walden:
Ranking Member:
Subcommittee on Oversight and Investigations:
Committee on Energy and Commerce:
House of Representatives:
The Honorable Yvette D. Clarke:
Chairwoman:
The Honorable Daniel E. Lungren:
Ranking Member:
Subcommittee on Emerging Threats, Cybersecurity, and Science and
Technology:
Committee on Homeland Security:
House of Representatives:
The Honorable Charles E. Schumer:
United States Senate:
The Honorable James R. Langevin:
House of Representatives:
The Honorable Michael T. McCaul:
House of Representatives:
[End of section]
Appendix I: Scope and Methodology:
To evaluate the degree to which Department of Homeland Security's (DHS)
criteria for a significant increase in operational effectiveness
address the limitations of the current generation of radiation
detection equipment, we clarified the intent of the criteria through
the Domestic Nuclear Detection Office's (DNDO) written answers to our
questions and through interviews with U.S. Customs and Border
Protection (CBP) officials. We also took steps to gain a fuller
understanding of the strengths and limitations of the current-
generation equipment, which the criteria use as a baseline for
evaluating the effectiveness of advanced spectroscopic portals (ASP).
In particular, we obtained copies of the Department of Energy (DOE)
threat guidance and related documents used to set polyvinyl toluene
(PVT) thresholds for detection of nuclear materials. We interviewed DOE
and national laboratory officials responsible for the threat guidance
about the process for developing it and the basis for its underlying
assumptions, including shielding levels. We also interviewed DNDO and
Pacific Northwest National Laboratory officials regarding the extent to
which PVTs currently deployed at ports of entry meet the guidance and
the development and use of energy windowing to enhance PVTs'
sensitivity to nuclear materials.
To evaluate the rigor of the 2008 round of testing as a basis for
determining ASPs' operational effectiveness, we reviewed the test and
evaluation master plan and plans for individual phases of testing,
including system qualification testing conducted at vendors'
facilities, performance testing conducted at the Nevada Test Site for
evaluating ASP detection and identification capabilities, and
integration testing conducted at Pacific Northwest National Laboratory
for evaluating the readiness of ASPs to be used in an operational
environment at ports of entry. We also reviewed draft plans for field
validation conducted at CBP ports of entry and the DHS Science and
Technology Directorate's independent operational test and evaluation.
In reviewing these documents, we specifically evaluated the extent to
which the performance test design was sufficient to identify
statistically significant differences between the ASP and current-
generation systems and whether DHS had addressed our concerns about
previous rounds of ASP testing. We interviewed DNDO, CBP, and other DHS
officials responsible for conducting and monitoring tests, and we
observed, for one day each, performance testing at the Nevada Test Site
and integration testing at DOE's Pacific Northwest National Laboratory.
We also interviewed representatives of entities that supported testing,
including DOE's National Nuclear Security Administration and Pacific
Northwest National Laboratory, the National Institute of Standards and
Technology, and the Johns Hopkins University Applied Physics
Laboratory. We reviewed the DHS independent review team report of
previous ASP testing conducted in 2007, and we interviewed the chair of
the review team to clarify the report's findings. Finally, we examined
preliminary or final results for the phases of testing completed during
our review, and we interviewed DNDO and CBP officials regarding the
results.
To evaluate the test schedule, we analyzed the initial working schedule
DNDO provided to us in May 2008 and the schedule presented in the
August 2008 test and evaluation master plan, and we tracked changes to
the schedule and the reasons for any delays. We interviewed DNDO and
other officials with a role in testing to determine the amount of time
allowed for analysis and review of results. We interviewed DNDO and
Pacific Northwest National Laboratory officials regarding the injection
studies, including reasons for delays in the studies and plans for
including the results as part of the ASP certification process.
We conducted this performance audit from May 2008 to May 2009 in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
[End of section]
Appendix II: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20529:
March 24, 2009:
Mr. Gene Aloise:
Director, Natural Resources and Environment:
U.S Government Accountability Office:
441 G Street NW:
Washington, DC 20548:
Dear Mr. Aloise:
RE: Draft Report GAO-09-354SU, Combating Nuclear Terrorism: DHS
Improved Testing of Advanced Radiation Detection Portal Monitors, But
Preliminary Results Show Limits of the New Technology (360961):
The Department of Homeland Security (DHS) appreciates the opportunity
to comment on the above referenced draft report and clarify several
points. DHS is committed to rigorous testing prior to the deployment of
new technologies and is pleased that the Government Accountability
Office (GAO) recognizes improvements that the Domestic Nuclear
Detection Office (DNDO) has incorporated into its testing programs.
The comments provided below in response to the subject report are
restricted to points that are directly relevant to the three areas that
GAO was asked to review: (1) the degree to which DHS's criteria for
significant increase in operational effectiveness address the
limitations of existing radiation detection equipment, (2) the rigor of
Advanced Spectroscopic Portal (ASP) testing and preliminary test
results, and (3) the ASP test schedule.
Report Recommendation: "Assess whether ASPS meet the criteria for
significant increase in operational effectiveness based on a valid
comparison with PVTs' full performance potential, including the
potential to further develop PVTs' use of energy windowing to provide
greater sensitivity to threats. Such a comparison could also be
factored in to an updated cost-benefit analysis to determine whether it
would be more cost-effective to continue to use PVTs or deploy ASPs for
primary screening at particular ports of entry."
DHS does not concur with this recommendation.
It is the judgment of experts that the majority of any increased
Polyvinyl Toluene (PVT) performance from energy windowing has already
been achieved in the existing systems; therefore we are confident that
using the current understanding on PVT energy windowing as a baseline
is a valid approach. DHS believes that Customs and Border Protection
(CBP), the Office of the Undersecretary for Management, and DNDO have
collaborated to establish a meaningful set of criteria to measure the
relative operational effectiveness of the current ASP and PVT systems.
Therefore, the current cost-benefit analysis is a reasonable basis to
guide programmatic decisions. However, given that PVT systems will
continue to be operated in the field, DNDO has initiated efforts to
continuously improve the capability of the PVT systems. These efforts
include an ongoing analysis of potential optimization of the PVT energy
windowing capability that will proceed in parallel with other
activities related to Certification.
Report Recommendation. "Revise the schedule for ASP testing and
certification to allow sufficient time for review and analysis of
results from the final phases of testing and completion of all tests,
including injection studies."
DHS does not concur with aspects of this recommendation.
We agree that there must be sufficient time to review the analyses and
results. The current schedule for certification is predicated on
completing all of the requisite testing and analysis of results
required to satisfy the criteria for demonstrating significantly
improved operational effectiveness. DHS has demonstrated that it is
implementing a deliberate process to ensure all the pre-established
exit criteria have been achieved prior to concluding the relevant phase
of testing.
However, a team of subject matter experts from the Department of Energy
(DOE) and DHS concluded that injection studies were not required for
Certification. The basis of this decision was a review of the series of
test campaigns planned for ASP and the joint determination that these
tests would provide a technically defensible basis for assessing the
ASP technology against the Certification criteria. "Accordingly,
Certification will be based on the whole body of experimental knowledge
collected on ASP, including technical performance at Nevada Test Site
(NTS), integration testing at 33I-G, field validation at ports of
entry, reanalysis of selected raw data files through a validated replay
tool, and independent Operational Test & Evaluation. Nevertheless, DHS
believes that injection studies are useful and will continue to support
and perform them as an aid for deployment decisions and for future
development.
Regarding the conclusions section in your report, we offer the
following additional comments:
* Conclusions regarding the relative effectiveness of PVT and ASP to
detect Highly Enriched Uranium (HEU) require a more complete analysis
than given in your report. For example, the effectiveness of a system
should include the entire system (primary plus secondary inspection).
Such an analysis would necessarily incorporate a comparison of ASP to a
hand-held RIID. Without including the whole system, conclusions about
overall detection effectiveness are inaccurate and misleading.
* We agree with CBP that we will inevitably discover problems with this
highly advanced and complex system as it transitions into field
operation. There is simply no way to fully anticipate and replicate all
real-world problems before deployment to the field: computer modeling
and simulation does not provide the same level of experience or
exposure. In anticipation of this fact, deployment will be accomplished
in phases, starting with a small number of low impact locations. As the
issues with the system are corrected, we will gradually build up to
wider deployment. The process will be similar to what was used in the
successful deployment of PVTs. Therefore, DHS believes ASP deployment
will be implemented in accordance with your recommendation to the
Secretary to discover and resolve problems through initial deployment
to a limited number of locations.
Finally, there were a few conclusions in the body of your report that
we would like to comment on:
* We agree that the NTS test did not "represent the full range of
possibilities for concealing smuggled nuclear or radiological
materials" because such a range is impractically large to create.
However, the NTS test campaign included an extensive array of shielding
and masking configurations in a plan designed jointly by DHS and DOE to
cover a range relevant to a passive radiation scanning application.
* Your report states that "CBP suspended field validation after one
week because of serious performance problems requiring software
revisions." Although it remains for analysis to determine the severity
of the problems encountered, preliminary analysis indicates that the
problems should be resolved by making adjustments to threshold
settings. Such adjustments are part of any installation of an RPM (PVT
or ASP) and are not software revisions. As mentioned above, it is
impossible to anticipate all the problems that will occur in real-world
operation, so it is not surprising to encounter problems, given that
this is the first opportunity for the latest version of ASP to operate
in the flow of real commerce.
Thank you for the opportunity to review and provide comments on your
report. We look forward to working with you on future homeland security
issues.
Sincerely,
Signed by:
Jerald E. Levine:
Director:
Departmental GAO/0IG Liaison Office:
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
Gene Aloise, (202) 512-3841 or aloisee@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, Ned Woodward, Assistant
Director; Dr. Timothy Persons, Chief Scientist; James Ashley; Steve
Caldwell; Joseph Cook; Omari Norman; Alison O'Neill; Rebecca Shea;
Kevin Tarmann; and Eugene Wisnoski made key contributions to this
report.
[End of section]
Footnotes:
[1] DNDO was established within DHS in 2005; its mission includes
developing, testing, acquiring, and supporting the deployment of
radiation detection equipment at U.S. ports of entry. CBP began
deploying portal monitors in 2002, prior to DNDO's creation, under the
radiation portal monitor project. For additional information on DNDO's
overall efforts to combat nuclear smuggling, see GAO, Nuclear
Detection: Domestic Nuclear Detection Office Should Improve Planning to
Better Address Gaps and Vulnerabilities, [hyperlink,
http://www.gao.gov/products/GAO-09-257] (Washington, D.C.: Jan. 29,
2009).
[2] GAO, Combating Nuclear Smuggling: DHS's Program to Procure and
Deploy Advanced Radiation Detection Portal Monitors Is Likely to Exceed
the Department's Previous Cost Estimates, [hyperlink,
http://www.gao.gov/products/GAO-08-1108R] (Washington, D.C.: Sept. 22,
2008).
[3] Consolidated Appropriations Act, 2007, Pub. L. No. 110-161, 121
Stat. 1844, 2069 (2007); Consolidated Security, Disaster Assistance,
and Continuing Appropriations Act, 2009, Pub. L. No. 110-329, 121 Stat.
3574, 3679 (2008).
[4] DNDO had a contract with a third ASP vendor whose system uses a
more expensive type of detector that must be cooled by liquid nitrogen.
DNDO determined it was not in the best interests of the government to
exercise the option on the contract and allowed it to expire in
November 2008. The vendor's ASP did not participate in the 2008 round
of testing.
[5] GAO, Combating Nuclear Smuggling: DHS's Cost-Benefit Analysis to
Support the Purchase of New Radiation Detection Portal Monitors Was Not
Based on Available Performance Data and Did Not Fully Evaluate All the
Monitors' Costs and Benefits, [hyperlink,
http://www.gao.gov/products/GAO-07-133R] (Washington, D.C.: Oct. 17,
2006).
[6] GAO, Combating Nuclear Smuggling: Additional Actions Needed to
Ensure Adequate Testing of Next Generation Radiation Detection
Equipment, [hyperlink, http://www.gao.gov/products/GAO-07-1247T]
(Washington, D.C.: Sept. 18, 2007).
[7] GAO, Combating Nuclear Smuggling: DHS's Phase 3 Test Report on
Advanced Portal Monitors Does Not Fully Disclose the Limitations of the
Test Results, [hyperlink, http://www.gao.gov/products/GAO-08-979]
(Washington, D.C.: Sept. 30, 2008).
[8] GAO, Combating Nuclear Smuggling: DHS Needs to Consider the Full
Costs and Complete All Tests Prior to Making a Decision on Whether to
Purchase Advanced Portal Monitors, [hyperlink,
http://www.gao.gov/products/GAO-08-1178T] (Washington, D.C.: Sept. 25,
2008).
[9] This report does not include certain details about the capabilities
and limitations of PVTs and ASPs that DHS considers to be "for official
use only." We have prepared a "for official use only" version of this
report in which we include such details (GAO-09-354SU).
[10] According to DNDO and CBP officials, active imaging techniques
(e.g., radiography systems to provide images of the contents of cargo
containers) and other measures complement radiation detection
equipment. In particular, such measures provide the capability to spot
smuggled nuclear materials that are too heavily shielded to be detected
by PVTs or ASPs.
[11] About 45 percent of all sea containers arriving in the United
States come through Los Angeles/Long Beach. In fiscal year 2006, CBP
cleared more than 5 million containers through the port.
[12] The criteria require an improvement when the radiation emitted by
naturally occurring radioactive material is used to mask smuggled
special nuclear material, including both HEU and plutonium.
[13] For additional information regarding the requirement to verify the
legitimacy of radioactive material shipments, see GAO, Nuclear
Security: NRC and DHS Need to Take Additional Steps to Better Track and
Detect Radioactive Materials, [hyperlink,
http://www.gao.gov/products/GAO-08-598] (Washington, D.C.: June 19,
2008).
[14] In the case of ASP testing, the Science and Technology Directorate
serves as the independent operational test authority, which reports
directly to the DHS Under Secretary for Management.
[15] Masking is the use of naturally occurring radioactive material to
make the radiation emitted by smuggled material appear to be caused by
innocent cargo. In contrast, shielding blocks radiation from being
emitted.
[16] DHS Homeland Security Institute, Independent Review of the
Department of Homeland Security Domestic Nuclear Detection Office
Advanced Spectroscopic Portal: Final Report (Feb. 20, 2008).
[End of section]
GAO's Mission:
The Government Accountability Office, the audit, evaluation and
investigative arm of Congress, exists to support Congress in meeting
its constitutional responsibilities and to help improve the performance
and accountability of the federal government for the American people.
GAO examines the use of public funds; evaluates federal programs and
policies; and provides analyses, recommendations, and other assistance
to help Congress make informed oversight, policy, and funding
decisions. GAO's commitment to good government is reflected in its core
values of accountability, integrity, and reliability.
Obtaining Copies of GAO Reports and Testimony:
The fastest and easiest way to obtain copies of GAO documents at no
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each
weekday, GAO posts newly released reports, testimony, and
correspondence on its Web site. To have GAO e-mail you a list of newly
posted products every afternoon, go to [hyperlink, http://www.gao.gov]
and select "E-mail Updates."
Order by Phone:
The price of each GAO publication reflects GAO‘s actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAO‘s Web site,
[hyperlink, http://www.gao.gov/ordering.htm].
Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537.
Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional
information.
To Report Fraud, Waste, and Abuse in Federal Programs:
Contact:
Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]:
E-mail: fraudnet@gao.gov:
Automated answering system: (800) 424-5454 or (202) 512-7470:
Congressional Relations:
Ralph Dawn, Managing Director, dawnr@gao.gov:
(202) 512-4400:
U.S. Government Accountability Office:
441 G Street NW, Room 7125:
Washington, D.C. 20548:
Public Affairs:
Chuck Young, Managing Director, youngc1@gao.gov:
(202) 512-4800:
U.S. Government Accountability Office:
441 G Street NW, Room 7149:
Washington, D.C. 20548:
