Nuclear Security
NRC and DHS Need to Take Additional Steps to Better Track and Detect Radioactive Materials Gao ID: GAO-08-598 June 19, 2008Concerns have grown that terrorists could use radioactive materials and sealed sources (materials sealed in a capsule) to build a "dirty bomb"-- a device using conventional explosives to disperse radioactive material. In 2003, GAO found weaknesses in the Nuclear Regulatory Commission's (NRC) radioactive materials licensing process and made recommendations for improvement. For this report, GAO assesses (1) the progress NRC has made in implementing the 2003 recommendations, (2) other steps NRC has taken to improve its ability to track radioactive materials, (3) Customs and Border Protection's (CBP) ability to detect radioactive materials at land ports of entry, and (4) CBP's ability to verify that such materials are appropriately licensed prior to entering the United States. To perform this work, GAO assessed documents and interviewed NRC and CBP officials in headquarters and in several field locations.
NRC has implemented three of the six recommendations in GAO's 2003 report on the security of radioactive sources. It has worked with the 35 states to which it ceded primary authority to regulate radioactive materials and sources and others to (1) identify sealed sources of greatest concern, (2) enhance requirements to secure radioactive sources, and (3) ensure security requirements are implemented. In contrast, NRC has made limited progress toward implementing recommendations to (1) modify its process for issuing licenses to ensure that radioactive materials cannot be purchased by those with no legitimate need for them, (2) determine how to effectively mitigate the potential psychological effects of malicious use of such materials, and (3) examine whether certain radioactive sources should be subject to more stringent regulations. Beyond acting on GAO's recommendations, NRC has also taken four steps to improve its ability to monitor and track radioactive materials. First, NRC created an interim national database to monitor the licensed sealed sources containing materials that pose the greatest risk of being used in a dirty bomb. Second, NRC is developing a National Source Tracking System to replace the interim database and provide more comprehensive, frequently updated information on potentially dangerous sources. However, this system has been delayed by 18 months and is not expected to be fully operational until January 2009. Third, NRC is also developing a Web-based licensing system that will include more comprehensive information on all sources and materials that require NRC or state approval to possess. Finally, NRC is developing a license verification system that will draw information from the other new systems to enable officials and vendors to verify that those seeking to bring these radioactive materials into the country or purchase them are licensed to do so. However, these systems are more than 3 years behind schedule and may not include the licensing information, initially at least, on radioactive materials regulated by agreement states--which represent over 80 percent of all U.S. licenses for such materials. The delays in the deployment and full development of these systems are especially consequential because NRC has identified their deployment as key to improving the control and accountability of radioactive materials. While CBP has a comprehensive system in place to detect radioactive materials entering the United States at land borders, some equipment that is used to protect CBP officers is in short supply. Specifically, vehicles, cargo, and people entering the United States at most ports of entry along the Canadian and Mexican borders are scanned for radioactive materials with radiation detection equipment capable of detecting very small amounts of radiation. However we found that personal radiation detectors are not available to all officers who need them. Moreover, while CBP has systems in place to verify the legitimacy of radioactive materials licenses, it has not effectively communicated to officers at the borders when they must contact officials to verify the license for a given sealed source. Consequently, some CPB officers are not following current guidance, and some potentially dangerous radioactive materials have entered the country without license verification.
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-08-598, Nuclear Security: NRC and DHS Need to Take Additional Steps to Better Track and Detect Radioactive Materials
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Report to the Permanent Subcommittee on Investigations, Committee on
Homeland Security and Governmental Affairs, U.S. Senate:
United States Government Accountability Office:
GAO:
June 2008:
Nuclear Security:
NRC and DHS Need to Take Additional Steps to Better Track and Detect
Radioactive Materials:
GAO-08-598:
GAO Highlights:
Highlights of GAO-08-598, a report to the Permanent Subcommittee on
Investigations, Committee on Homeland Security and Governmental
Affairs, U.S. Senate.
Why GAO Did This Study:
Concerns have grown that terrorists could use radioactive materials and
sealed sources (materials sealed in a capsule) to build a ’dirty bomb“”
a device using conventional explosives to disperse radioactive
material. In 2003, GAO found weaknesses in the Nuclear Regulatory
Commission‘s (NRC) radioactive materials licensing process and made
recommendations for improvement. For this report, GAO assesses (1) the
progress NRC has made in implementing the 2003 recommendations, (2)
other steps NRC has taken to improve its ability to track radioactive
materials, (3) Customs and Border Protection‘s (CBP) ability to detect
radioactive materials at land ports of entry, and (4) CBP‘s ability to
verify that such materials are appropriately licensed prior to entering
the United States. To perform this work, GAO assessed documents and
interviewed NRC and CBP officials in headquarters and in several field
locations.
What GAO Found:
NRC has implemented three of the six recommendations in GAO‘s 2003
report on the security of radioactive sources. It has worked with the
35 states to which it ceded primary authority to regulate radioactive
materials and sources and others to (1) identify sealed sources of
greatest concern, (2) enhance requirements to secure radioactive
sources, and (3) ensure security requirements are implemented. In
contrast, NRC has made limited progress toward implementing
recommendations to (1) modify its process for issuing licenses to
ensure that radioactive materials cannot be purchased by those with no
legitimate need for them, (2) determine how to effectively mitigate the
potential psychological effects of malicious use of such materials, and
(3) examine whether certain radioactive sources should be subject to
more stringent regulations. Beyond acting on GAO‘s recommendations, NRC
has also taken four steps to improve its ability to monitor and track
radioactive materials. First, NRC created an interim national database
to monitor the licensed sealed sources containing materials that pose
the greatest risk of being used in a dirty bomb. Second, NRC is
developing a National Source Tracking System to replace the interim
database and provide more comprehensive, frequently updated information
on potentially dangerous sources. However, this system has been delayed
by 18 months and is not expected to be fully operational until January
2009. Third, NRC is also developing a Web-based licensing system that
will include more comprehensive information on all sources and
materials that require NRC or state approval to possess. Finally, NRC
is developing a license verification system that will draw information
from the other new systems to enable officials and vendors to verify
that those seeking to bring these radioactive materials into the
country or purchase them are licensed to do so. However, these systems
are more than 3 years behind schedule and may not include the licensing
information, initially at least, on radioactive materials regulated by
agreement states”which represent over 80 percent of all U.S. licenses
for such materials. The delays in the deployment and full development
of these systems are especially consequential because NRC has
identified their deployment as key to improving the control and
accountability of radioactive materials.
While CBP has a comprehensive system in place to detect radioactive
materials entering the United States at land borders, some equipment
that is used to protect CBP officers is in short supply. Specifically,
vehicles, cargo, and people entering the United States at most ports of
entry along the Canadian and Mexican borders are scanned for
radioactive materials with radiation detection equipment capable of
detecting very small amounts of radiation. However we found that
personal radiation detectors are not available to all officers who need
them. Moreover, while CBP has systems in place to verify the legitimacy
of radioactive materials licenses, it has not effectively communicated
to officers at the borders when they must contact officials to verify
the license for a given sealed source. Consequently, some CPB officers
are not following current guidance, and some potentially dangerous
radioactive materials have entered the country without license
verification.
What GAO Recommends:
GAO recommends NRC take steps to ensure that the current target dates
for launching new systems are not further postponed. GAO recommends CBP
more effectively communicate guidance on when officers must verify the
legitimacy of radioactive materials and take steps to ensure that this
guidance is being followed. NRC neither agreed nor disagreed with GAO‘s
findings and recommendations but described its efforts to implement
GAO‘s 2003 recommendations and its plans to implement GAO‘s 2008
recommendations. CBP agreed with GAO‘s recommendations.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-598]. For more
information, contact Gene Aloise at (202) 512-3841 or aloisee@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
NRC Has Implemented Three of the Six Recommendations from GAO's 2003
Report:
NRC Has Improved Its Ability to Monitor and Track Radioactive Sealed
Sources, but New Systems Have Been Delayed:
CBP Has a Comprehensive System for Detecting Radiation at Ports of
Entry on the Northern and Southern Borders:
CBP Guidance on When to Verify Licenses for Radioactive Materials
Entering the United States Was Not Communicated to the Field:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Potential Effects of a Radiological Dispersal Device with
Category 1, 2, and 3 Quantities of Radioactive Material:
Appendix II: Comments from the Nuclear Regulatory Commission:
Appendix III: Comments from the Department of Homeland Security:
Appendix IV: Comments from the Organization of Agreement States:
Appendix V: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: 16 Radionuclides of Concern:
Table 2: Increased Controls on Category 2 or Greater Quantities of the
16 Radionuclides of Concern:
Table 3: Potential Contamination from an RDD:
Figures:
Figure 1: Cesium-137 Sources at a Hospital Used for Cancer Treatment
Are Kept in a Secure Room with Limited Access:
Figure 2: Passenger Vehicles at a Port of Entry on the Southern Border:
Figure 3: Trucks Passing through Portal Monitors on the Northern
Border:
Figure 4: Truck-Sized Portal Monitor in the Inspection Area at a Port
of Entry on the Southern Border:
Abbreviations:
CBP: Customs and Border Patrol:
DHS: Department of Homeland Security:
EPA: Environmental Protection Agency:
IAEA: International Atomic Energy Agency:
IND: improvised nuclear devices:
NRC: Nuclear Regulatory Commission:
NSTS: National Source Tracking System:
PAG: Protective Action Guides:
RIID: radiation isotope identification device:
RDD: radiological dispersal device:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
June 19, 2008:
The Honorable Carl Levin:
Chairman:
The Honorable Norm Coleman:
Ranking Member:
Permanent Subcommittee on Investigations:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
Radioactive sealed sources, which are commonly used throughout the
world for a variety of purposes, are radioactive materials sealed in a
capsule or permanently bonded in a solid form. These sealed sources are
used in medicine and in the oil and gas, electric power, construction,
and food industries. For example, devices containing radioactive sealed
sources are used to diagnose and treat millions of patients each year,
sterilize items such as medical instruments and food, and detect flaws
in the metal welds in pipelines. Currently, about 2 million sealed
sources are licensed for use in the United States. Since terrorists
attacked the United States in 2001, concerns have grown that they could
obtain and use sealed sources to build a "dirty bomb"--a type of
radiological dispersal device (RDD) that uses conventional explosives
to disperse radioactive material.
The consequences of detonating an RDD depend on the amount and type of
radioactive material used and the size and characteristics of the area
in which the material is dispersed. In many scenarios, an RDD would
cause few deaths or injuries, but significant economic effects could
result. In particular, the affected area would need to be
decontaminated and people who work or live in the affected area might
not return to their homes or businesses for an extended period of time
because they fear the consequences. Generally, the smaller or more
confined the area in which a given amount of radioactive material is
dispersed, the more severe the consequences. Accordingly, depending
upon the circumstances, even small amounts of material can be
potentially dangerous. For example, a relatively small quantity of a
particular material dispersed over many city blocks could be disruptive
and result in an evacuation while first responders assessed the extent
of the contamination and determined the need for a cleanup. In this
case, the small quantity of this material might not cause immediate
health effects or require significant cleanup, but it could result in
economic and psychological consequences if people were temporarily
evacuated from their businesses and homes. However, the same small
quantity of the same material dispersed in a more confined setting,
such as a restaurant or enclosed subway station, would also result in
an evacuation and would prevent people from returning to the affected
area until a more extensive cleanup could be completed. Moreover, those
exposed to radiation under this scenario could experience radiation
sickness, with symptoms that include nausea, vomiting, and diarrhea. If
exposure is extended, the result can be permanent injury or death.
Finally, larger amounts of this same radioactive material spread over a
larger area could produce more significant consequences. (For further
discussion of the potential effects of an RDD, see app. I.)
Until 2001, oversight of radioactive sealed sources in the United
States largely focused on ensuring that such sources were licensed as
required and used and stored safely. In the years after 2001, security
concerns surrounding radioactive sealed sources received greater
attention nationally and internationally. For example, in May 2003, the
Nuclear Regulatory Commission (NRC) and the Department of Energy (DOE),
relying in part on a 2002 study by Sandia National Laboratories
[Footnote 1] that, among other things, identified several
radionuclides--the particular types of radioactive material used in
sealed sources--that are most commonly used in the United States and
that pose the greatest risk of being used by terrorists to make an RDD.
[Footnote 2] Also that year, the International Atomic Energy Agency
(IAEA) published a system for ranking quantities of individual
radionuclides into one of five categories on the basis of their
potential to harm human health.[Footnote 3] Under IAEA's system, a
given radionuclide is considered "dangerous" when gathered in close
proximity to people in sufficient quantity to cause direct human health
effects.[Footnote 4] A category 1 quantity of a given radionuclide, the
most dangerous, is defined as an amount 1,000 times or more than the
amount necessary to cause permanent human injury; a category 2 quantity
is defined as an amount at least 10 times but less than 1,000 times the
amount necessary to cause permanent human injury. A category 3 quantity
of a given radionuclide is defined as at least the minimum amount, but
less than 10 times the amount, sufficient to cause permanent injury.
Category 4 and 5 quantities of radioactive materials are unlikely to
cause permanent injury. In September 2003, the United States and other
nations endorsed IAEA's Code of Conduct, which sets forth basic
principles and guidance to promote the safe and secure use of sealed
sources containing sufficient quantities of radioactive material to be
categorized as dangerous. The Code of Conduct applies to categories 1,
2, and 3--all of which are potentially dangerous to human health and
could, if not properly controlled, cause permanent injuries or death to
a person who handled it or who was otherwise in contact with it.
How dangerous any given type of radioactive material is depends on its
activity level, or intensity; how long exposure lasts; and the way in
which the body is exposed to it--via inhalation, ingestion, or external
exposure. The different types of radiation--including alpha, beta,
gamma, and neutron--also vary in how easy or difficult they are to
block, or shield, and this variation, in turn, affects the threat to
health that a particular type of radiation poses. Depending on the
intensity and length and manner of exposure, health effects range from
death, to severe injury, to the development of cancer, to no
discernable damage. For example, alpha radiation poses little threat to
human health from external exposure but poses considerable health risks
if inhaled or ingested. Gamma radiation is more penetrating and, if not
properly shielded, can cause injury or death through external exposure.
Although sources of neutron radiation are less common, neutron
radiation is emitted from some materials that are used to make nuclear
weapons. Thus, tools that can detect neutron radiation are particularly
important for national security purposes, such as securing our borders.
An underlying goal of federal and state regulation of radioactive
materials is to protect people from health effects caused by exposure
to harmful levels of radiation. The Atomic Energy Act gives NRC primary
responsibility for regulating most domestic industrial, medical, and
research uses of radioactive materials to protect public health and
safety. The act authorizes NRC to relinquish primary regulatory
authority over radioactive materials to states (called "agreement"
states) that agree to meet certain conditions. To date, NRC has
relinquished authority to 35 states to grant licenses to possess and
use radioactive materials and sealed sources and conduct regular
inspections of licensees to enforce compliance. NRC and numerous state
governments license, monitor, track, and require security for
radioactive materials in order to protect both workers and members of
the general public from exposure to hazardous levels of radiation
generated by the activities of their licensees. Given this mandate to
regulate the radioactive material covered by their licenses, NRC and
state regulators focus on the dangers posed by day-to-day occupational
exposure to radiation and the direct health effects from industrial
accidents. NRC periodically evaluates its own regulatory program and
evaluates each agreement state's program for compatibility with NRC
regulations.
NRC and agreement states issue two types of licenses to authorize the
possession of radioactive materials: specific licenses and general
licenses. Specific licenses are issued for devices that contain
relatively larger radioactive sealed sources. These devices, such as
medical equipment used to treat cancer, cameras used for industrial
radiography, and moisture and density gauges used in construction,
generally require training to be used safely and may also need to be
properly secured to avoid misuse. Organizations or individuals wanting
to obtain a specific license must submit an application and gain the
approval of either NRC or an agreement state. In contrast, devices
approved for use under general license, such as luminous exit signs,
normally contain relatively small radioactive sources. Such devices are
designed with inherent radiation safety features, are widely
commercially available, and do not require NRC or agreement state
approval to possess. Of the approximately 22,000 specific materials
licenses in the United States, NRC administers about 3,750, and the
agreement states administer the rest.
Other federal agencies' responsibilities related to regulation of
radioactive materials are focused on protecting the general public from
exposure to harmful levels of radiation (the Environmental Protection
Agency), establishing emergency response procedures (the Department of
Homeland Security), or preventing the illicit import of such materials
(Customs and Border Protection, a component of the Department of
Homeland Security). For example, the Environmental Protection Agency
(EPA) is responsible for developing and implementing standards for
protecting the general public from, among other things, radiation from
contaminated air, water, and soil--whether this contamination is the by-
product of industrial activities or occurred as a result of an
accidental or deliberate release of radioactive materials. EPA sets
cleanup standards for areas contaminated by radiation that consider the
direct health effects and the risks posed by very long-term exposure to
even very low levels of radiation, which has the potential to increase
the risk of developing cancer in the future. EPA is also responsible
for establishing a comprehensive set of guidelines for use by local,
state, and federal emergency services personnel and other first
responders in the event of a release of radioactive material--such as
that caused by an industrial accident or an RDD. The Department of
Homeland Security (DHS) incorporates the radiation exposure thresholds,
established primarily by EPA, into their guidance document, Application
of Protective Action Guides for Radiological Dispersal Device and
Improvised Nuclear Device Incidents. EPA's more general guidelines
identify steps that should be taken to respond to and mitigate the
effects of various types of radiological incidents--whether they are
industrial accidents or terrorist attacks. Finally, DHS's Customs and
Border Protection[Footnote 5] (CBP) is responsible for preventing the
smuggling of radioactive materials into the United States.
In August 2003, we reported that (1) the number of radioactive sealed
sources in the United States was unknown because NRC and agreement
states tracked licenses, which can be issued for more than one source,
rather than individual sealed sources; (2) despite concerns about the
need for heightened security of radioactive sources, NRC had only
recently issued requirements to improve the security of a relatively
small number of the very largest sealed sources, used for irradiating
food or medical supplies, leaving many others without increased
security; and (3) there were potential security weaknesses in NRC and
agreement state licensing processes. We made several recommendations to
correct these problems, including that NRC (1) collaborate with
agreement states to identify the types, amount, and availability of the
highest-risk radioactive sources and the associated health and economic
consequences of their malicious use; (2) re-examine its licensing
procedures and requirements; and (3) work with states to devise and
implement additional security measures, including performance measures
to make sure any new measures are effective.[Footnote 6] In addition,
we reported in March 2006 that, among other things, CBP did not have
access to NRC or agreement state licensing data, making it difficult
for officers at U.S. ports of entry to verify the legitimacy of
shipments of radioactive sealed sources or materials.[Footnote 7]
Accordingly, we recommended that CBP and NRC develop a capacity to
provide CBP border personnel with information needed to help determine
if radioactive sealed source shipments are legitimate, including NRC
licensing data. We also conducted two undercover operations to test
CBP's and NRC's ability to prevent those with malicious intent from
obtaining radioactive sources or from smuggling them into the United
States. In March 2006, we reported on an undercover operation in which
we used forged NRC documents to transport category 5 radioactive
sources across the northern and southern borders of the United States,
underscoring CBP's inability to verify the legitimacy of radioactive
sources entering the United States.[Footnote 8] In March 2007, using
the name of a fictitious business, we obtained a radioactive materials
license from NRC, which we altered and then used to obtain commitments
from private companies to purchase dangerous quantities of radioactive
sources.[Footnote 9] We did this only a few months after NRC had issued
guidance designed to prevent those with no legitimate need to possess
radioactive sources from acquiring a license.
In this context, this report assesses (1) the progress NRC has made in
implementing the recommendations in our August 2003 report, (2) other
steps NRC has taken to improve its ability to monitor and track
radioactive materials, (3) CBP's ability to detect radioactive
materials at ports of entry on the northern and southern borders, and
(4) CBP's ability to verify that such materials are appropriately
licensed before they are allowed to enter the United States.
To assess the progress NRC has made in implementing the recommendations
in our August 2003 report, we reviewed NRC's periodic reports to the
Congress on the status of these recommendations, reviewed the relevant
policy and procedural changes undertaken since the report was issued,
and interviewed NRC officials about the status of our recommendations
and actions taken and steps planned to implement them. We also spoke to
various state regulators of radioactive sources and materials. We
attended two annual meetings of the Organization of Agreement States
and interviewed each of the board members to obtain their perspectives
on NRC's implementation of the recommendations on issues affecting
states. We also obtained documents and interviewed several experts at
Sandia and Los Alamos National Laboratories in Albuquerque and Los
Alamos, New Mexico, respectively, and Lawrence Livermore National
Laboratory in Livermore, California, about the risks posed by RDDs. In
addition, we met with officials from the National Nuclear Security
Administration's Office of Global Threat Reduction, who are working on
a classified, comprehensive analysis of the potential social and
economic costs of various RDD scenarios. Finally, we obtained documents
and interviewed officials from EPA about their responsibilities for
developing and implementing standards for protecting the general public
from radiation in contaminated air, water, and soil.
To assess other steps NRC has taken to improve its ability to monitor
and track radioactive materials, we obtained documentation about the
capabilities, operations, and reliability of the NRC databases
currently in operation and those in various stages of development. We
also interviewed senior NRC database managers responsible for running
or developing these systems.
To assess CBP's ability to detect and verify the legitimacy of
radioactive sealed sources and materials before they are allowed to
enter the United States, we gathered documentation on the capabilities
and operations of DHS's National Targeting Center, toured the facility,
and interviewed the center's director. We gathered documents and
interviewed CBP officials, including port directors and CBP line
officers, during visits to a nonprobability sample[Footnote 10] of
several ports of entry on both the Canadian and Mexican borders. In
addition, we gathered documentation about the operations of four other
ports of entry and interviewed the principal CBP officials responsible
for running these land border crossings. We selected these ports of
entry because of their geographic locations and sizes, as well as the
estimated volume of entries into the United States of both passengers
and cargo (general and radioactive materials) at these locations. We
also gathered information about the technical capabilities of the
radiation detection equipment used by CBP officers. Finally, we
interviewed officers of the Organization of Agreement States and other
state officials to obtain the states' perspectives on their
collaboration with NRC and DHS. We conducted this performance audit
from August 2006 to May 2008 in accordance with generally accepted
government auditing standards. Those standards require that we plan and
perform the audit to obtain sufficient, appropriate evidence to provide
a reasonable basis for our findings and conclusions based on our audit
objectives. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based on our audit objectives.
Results in Brief:
NRC has implemented three of the six recommendations in our 2003 report
on the security of radioactive sources by working with agreement states
to (1) identify radioactive sealed sources of greatest concern, (2)
determine how agreement state and nonagreement state officials could
participate in the development and implementation of additional
security measures for radionuclides of concern, and (3) include
performance criteria for assessing NRC's and agreement states'
implementation of these additional security requirements in periodic
evaluations of both NRC and agreement state effectiveness.
Specifically, NRC, working with DOE, developed a list of 16
radionuclides of concern that, if gathered in sufficient quantities,
pose the greatest risk of being used by terrorists to make an RDD.
Second, NRC, working with agreement states, has required several
additional security measures called "increased controls" be taken to
protect such radionuclides from theft, diversion, or other unauthorized
access when they are gathered in quantities at or above a particular
threshold. Increased controls include such measures as implementing 24-
hour surveillance, multiple layers of physical security, and measures
to ensure the immediate notification of local law enforcement agencies
in the event of any actual or suspected breach in security. Finally,
NRC and agreement states also established criteria for assessing the
implementation of these increased controls and integrated these
criteria into NRC's existing oversight program. To date, inspection
teams comprised of inspectors from NRC (headquarters and regional
office staff) and agreement states have assessed the implementation of
increased controls by several agreement states and one of four NRC
regional offices.
In contrast, NRC has made limited progress toward implementing our
recommendations to (1) modify its process for issuing licenses to
ensure that radioactive materials cannot be purchased by individuals
who have no legitimate need for them, (2) determine how to effectively
mitigate the potential psychological effects of malicious use of
radioactive materials, and (3) re-examine whether certain radioactive
sources should be regulated through specific licenses rather than
general licenses. More specifically, although NRC did take steps in
December 2006 that it thought would ensure that radioactive materials
could not be purchased by those without a legitimate need for them,
these changes were not sufficient to prevent us from obtaining an NRC
license for a fictitious business and using this license to obtain
commitments from manufacturers of industrial devices containing
radioactive materials to sell them to us. Taken together, the devices
we could have acquired would have contained a potentially dangerous
quantity of one of the 16 radionuclides of concern. Moreover, NRC has
not yet taken steps to determine how to mitigate the potential
psychological effects of a terrorist attack using radioactive
materials, although it has participated in an interagency working group
that recently produced a draft version of a public education action
plan that seeks, among other things, to reduce public fears of
radioactivity and diminish the impact of a terrorist attack using such
materials. Finally, although NRC has gathered the data it needs to re-
examine whether certain radioactive sources should be regulated through
specific licenses rather than general licenses, it has only recently
begun the process of deciding, in consultation with agreement states,
whether and what sort of changes should be made.
Beyond responding to our previous recommendations, NRC has taken four
steps to improve its ability to monitor and track radioactive materials
since we issued our 2003 report. However, three of these efforts have
limitations and are not yet implemented. More specifically, NRC created
an interim national database to monitor all the licensed radioactive
sealed sources that contain the more dangerous quantities (categories 1
and 2) of the types of radioactive sources that pose the greatest risk
of being used in an RDD. This database, which relies on data that are
updated annually, is intended to provide limited monitoring and
tracking information on sealed sources until NRC can launch the
National Source Tracking System. This system is intended to replace the
interim database and provide more detailed, comprehensive, and
frequently updated information on radioactive sealed sources. The
National Source Tracking System will initially include information only
about the potentially more dangerous category 1 and 2 radioactive
sealed sources containing RDD-suitable radioactive materials, but will
eventually include information on category 3 and the largest category 4
sources which NRC also considers to be potentially dangerous. Also,
this system has already been delayed by 18 months and is not currently
expected to be launched until January 2009. In April 2008, NRC
announced plans to expand the National Source Tracking System to
include category 3 and the largest category 4 sources by July 31, 2009-
-a date which NRC told us the following month would slip to at least
March 2010. NRC is also developing a Web-based system that will include
information on all NRC specific licenses. This system is already more
than 3 years behind schedule, however, and may not include information,
initially at least, on radioactive materials licenses that are issued
by agreement states--which represent over 80 percent of all U.S.
licenses for these materials. NRC officials told us that they are
currently working with agreement states to determine the most efficient
means of including agreement state data in the Web-based licensing
system. Furthermore, NRC is in the early stages of developing a new,
third system--a license verification system--which NRC officials hope
to have operational by the time the Web-based licensing system is
deployed in the summer of 2010, and will draw on information in both
the National Source Tracking System and the Web-based licensing system
to provide regulators and vendors with the ability to verify that those
seeking to purchase additional radioactive sealed sources are licensed
to do so. Taken together, these systems will include detailed
information about what licensees are allowed to possess and,
importantly, whether a prospective licensee seeking to purchase
additional sealed sources is licensed to possess the additional types
and quantities. The delays in the deployment and full development of
both the National Source Tracking System and Web-based licensing
system, and the new license verification system, are especially
consequential because NRC has identified the deployment of these
systems as key to improving the security of radioactive materials in
the United States.
While CBP has a comprehensive system in place to detect radioactive
materials entering the United States at land borders, some equipment
that is used to protect CBP officers is in short supply. More
specifically, vehicles, cargo, and people entering the United States at
most ports of entry along the Canadian and Mexican borders are scanned
for radioactive materials with radiation detection equipment capable of
detecting even very small amounts of radiation--whether these materials
are in the form of industrial sources, raw materials, trace amounts of
radiation found in such common products as ceramics or bananas, or
radionuclides left in the human body in the aftermath of medical
procedures. If radiation is detected, CBP officers must investigate
until they are convinced that any vehicles, cargo, and people pose no
threat. When CBP officers cannot resolve the radiation alarm with the
information available to them at the border, they are required to
contact technical experts at CBP's National Targeting Center for
assistance. If radioactive materials are found, CBP officers must take
steps to ensure that those seeking entry to the United States appear to
have a legitimate reason to possess and transport such materials, and
are licensed as appropriate, before being allowed to enter the country.
However, while CBP has comprehensive systems in place for detecting
radiation, we found that personal radiation detectors--an important
component of the suite of radiation detection equipment in place at the
borders--are in short supply. Unlike other radiation detection
equipment that is designed to be used as screening tools for
radioactive materials, personal radiation detectors are designed to
alert the individual wearer when he or she is being exposed to
unusually high levels of radiation. While most CBP officers dealing
with the public in front-line positions are equipped with personal
radiation detectors, some are not. According to CBP officials, the
agency lacks sufficient resources to purchase the approximately 1,500
personal radiation detectors it needs to provide one for each officer
at the border who currently needs one.
While CBP has systems in place to verify that all licenses for
radioactive materials are legitimate, it has not effectively
communicated its guidance to CBP officers on when they must contact the
National Targeting Center to verify that radioactive materials are
legitimately licensed. Consequently, some CPB officers are not
following the most recent guidance, and some dangerous radioactive
materials have entered the country without license verification.
Specifically, according to a directive issued in 2003, there are
circumstances when even large shipments of radioactive materials could
be admitted without a CBP officer contacting the center to verify
legitimacy. In 2006, to tighten security, CBP issued a supplemental
memorandum revising the circumstances under which CBP officers are
required to contact the National Targeting Center. That is, as of 2006,
CBP officers must now contact the center to verify that radioactive
materials are legitimately licensed whenever they detect more than
incidental, trace amounts of radiation--for example, amounts higher
than the low levels found in such common products as ceramics and
bananas. However, headquarters has not effectively communicated this
updated guidance to CBP officers at the border. When we asked CBP
officers at several ports of entry about the current guidance for
regulating the flow of radioactive materials across the border, almost
all officers either provided us with the 2003 directive or confirmed
that the 2003 directive was current and operative; only one gave us
guidance reflecting the 2006 memorandum. Finally, at one port of entry,
CBP officers were confused about when to verify licenses and were
routinely permitting large shipments of neutron-emitting material to
enter the country. This situation was particularly troubling because
(1) some neutron-emitting materials can be used to make nuclear weapons
and (2) it has been CBP policy since 2003 to verify the legitimacy of
all neutron-emitting materials.
We are recommending that the Chairman of the NRC take steps, consistent
with sound systems development practices, to (1) ensure that priority
attention is given to meeting the current January 2009 and summer 2010
target dates for launching the National Source Tracking System, Web-
based licensing system, and the new license verification system,
respectively; and (2) complete the needed steps to include all
potentially dangerous radioactive sources in the National Source
Tracking System as quickly as is reasonably possible. In addition, to
improve the likelihood of preventing radioactive sources and materials
from being smuggled into the United States, we recommend that the
Secretary of Homeland Security direct the Commissioner of CBP to (1)
effectively communicate current CBP guidance to officers at ports of
entry regarding when they are required to contact the National
Targeting Center to verify the legitimacy of radioactive materials, and
(2) take measures to ensure that this guidance is being followed.
We provided a draft of this report to the Chairman of the NRC, the
Secretary of Homeland Security, the Secretary of Energy, the
Administrator of the EPA, and the Chair of the Organization of
Agreement States for comment. NRC neither agreed nor disagreed with the
report's findings and recommendations. Instead, NRC described its
current efforts to implement the recommendations from our 2003 report
and stated its intention to place the highest priority on the
completion and deployment of the National Source Tracking System and
the Web-based licensing system and a new, third system. Although we are
encouraged by NRC's efforts to finish implementing the recommendations
from our 2003 report, we remain concerned that nearly 5 years after we
issued our report these recommendations have yet to be fully
implemented. The other federal agencies that were offered the
opportunity to comment on our report either agreed with our
recommendations and outlined the steps to be taken to implement them,
or chose not to comment on the final draft. Specifically, according to
DHS's written comments, CBP concurred with our recommendations and
specified the steps it will take to implement them. DOE and EPA
reviewed and provided comments on earlier versions of our draft report
and, after reviewing our final draft, had no further comments. The
Organization of Agreement States neither agreed nor disagreed with our
findings and recommendations, but offered comments on the quality of
agreement state regulatory programs and NRC collaboration with
agreement states, which we incorporated into the report.
NRC Has Implemented Three of the Six Recommendations from GAO's 2003
Report:
Since 2003, NRC has worked with agreement states and others to identify
the radioactive materials that pose the greatest risk of being used to
make an RDD, established additional security measures for these
materials, and taken steps to ensure the increased security measures
are effectively implemented. However, NRC has not successfully
corrected the weaknesses in its radioactive materials licensing
processes. Further, NRC has taken limited steps to determine how to
effectively mitigate the potential psychological effects of an RDD.
Finally, NRC has not yet decided whether certain radioactive sources
need stronger licensing requirements.
NRC Has Worked with the States and Others to Identify Radioactive
Sources That Pose the Greatest Risk of Being Used to Make an RDD:
An NRC and DOE working group had established a tentative list of
radioactive materials under NRC license and DOE control and the
quantities at which they pose the greatest risk. However, according to
agreement states representatives, the agreement states were not
directly involved in creating this list prior to the release of our
August 2003 report. Our report recommended that the Chairman of NRC
collaborate with the agreement states on this list, which NRC did
before the list was finalized in August 2005. Specifically, in July
2002, the chairman of the NRC and the Secretary of Energy established a
working group to identify radioactive materials according to the
relative risk they posed of being used by terrorists to make an RDD.
The working group assessed the relative hazards of various radioactive
isotopes, taking into consideration both the nature of the materials
(their potential threat to human health) and their attractiveness for
use in an RDD (their half-lives, the quantities in which such materials
are typically found, the level of protection typically surrounding
them, and the ease with which they might be dispersed). The working
group completed its initial study in November 2002 and issued a final
report in May 2003. During this period, NRC, DOE, and other U.S.
government entities were also negotiating with other countries under
the auspices of the International Atomic Energy Agency (IAEA) to create
a single international threshold quantity at which nations adopting
IAEA's Code of Conduct would agree to take measures to more closely
track and consider increased security measures to protect radionuclides
of concern. NRC also consulted with agreement states on this issue. In
the end, it was agreed in September 2003 that the threshold for
increased concern--that is, the quantities at which various
radionuclides become subject to more stringent security--should be
category 2 quantities.
After our August 2003 recommendation that NRC consult with the
agreement states on this list, NRC officials formally provided it to
agreement state officials for their review. The agreement states agreed
with the list and the thresholds developed by the IAEA and
participating countries (see table 1).
Table 1: 16 Radionuclides of Concern:
Radionuclide: Americium-241;
Common abbreviation: Am-241;
Principal emission(s): alpha;
Threshold for concern in curies (IAEA category 2): 16.
Radionuclide: Americium-241/Beryllium;
Common abbreviation: Am-241/Be;
Principal emission(s): alpha/neutron;
Threshold for concern in curies (IAEA category 2): 16.
Radionuclide: Californium-252;
Common abbreviation: Cf-252;
Principal emission(s): alpha;
Threshold for concern in curies (IAEA category 2): 5.4.
Radionuclide: Cesium-137;
Common abbreviation: Cs-137;
Principal emission(s): beta/gamma;
Threshold for concern in curies (IAEA category 2): 27.
Radionuclide: Cobalt-60;
Common abbreviation: Co-60;
Principal emission(s): beta/gamma;
Threshold for concern in curies (IAEA category 2): 8.1.
Radionuclide: Curium-244;
Common abbreviation: Cm-244;
Principal emission(s): alpha;
Threshold for concern in curies (IAEA category 2): 14.
Radionuclide: Gadolinium-153;
Common abbreviation: Gd-153;
Principal emission(s): gamma;
Threshold for concern in curies (IAEA category 2): 270.
Radionuclide: Iridium-192;
Common abbreviation: Ir-192;
Principal emission(s): beta/gamma;
Threshold for concern in curies (IAEA category 2): 22.
Radionuclide: Plutonium-238;
Common abbreviation: Pu-238;
Principal emission(s): alpha;
Threshold for concern in curies (IAEA category 2): 16.
Radionuclide: Plutonium-239/Beryllium;
Common abbreviation: Pu-239/Be;
Principal emission(s): alpha/neutron;
Threshold for concern in curies (IAEA category 2): 16.
Radionuclide: Promethium-147;
Common abbreviation: Pm-147;
Principal emission(s): beta;
Threshold for concern in curies (IAEA category 2): 11,000.
Radionuclide: Radium-226;
Common abbreviation: Ra-226;
Principal emission(s): alpha;
Threshold for concern in curies (IAEA category 2): 11.
Radionuclide: Selenium-75;
Common abbreviation: Se-75;
Principal emission(s): gamma;
Threshold for concern in curies (IAEA category 2): 54.
Radionuclide: Strontium-90 (Yttrium-90);
Common abbreviation: Sr-90 (Y-90);
Principal emission(s): beta;
Threshold for concern in curies (IAEA category 2): 270.
Radionuclide: Thulium-170;
Common abbreviation: Tm-170;
Principal emission(s): gamma;
Threshold for concern in curies (IAEA category 2): 5,400.
Radionuclide: Ytterbium-169;
Common abbreviation: Yb-169;
Principal emission(s): gamma;
Threshold for concern in curies (IAEA category 2): 81.
Source: NRC.
Note: NRC published the list of 16 radionuclides of concern in the
Federal Register in 2007 as part of Orders Imposing Additional Security
Measures.
[End of table]
NRC and Agreement States Have Established Additional Security
Requirements and Taken Steps to Ensure Their Implementation:
NRC also implemented our recommendations to (1) determine how agreement
state and nonagreement state officials could participate in the
development and implementation of additional security measures for
radionuclides of concern and (2) include performance criteria for
assessing NRC's and agreement states' implementation of these
additional security requirements in periodic evaluations of both NRC
and agreement state effectiveness. First, NRC worked with agreement
states to devise and implement several additional security measures--
called "increased controls" --to protect category 2 or greater
quantities of radionuclides of concern from theft, diversion, and other
unauthorized access. In late 2003, NRC and state officials, some of
whom were also officers of the Organization of Agreement States or
Conference of Radiation Control Program Directors (an organization that
includes both agreement and nonagreement states), established several
working groups to facilitate the participation of state officials and
their organizations in developing and implementing additional security
measures for certain radioactive sources and materials. Several state
officials, including a former chair of the Organization of Agreement
States (OAS), told us that these working groups functioned in a highly
collaborative and deliberative manner. Another OAS official told us
that the fact that so many agreement state officials have been willing
to volunteer to serve in working groups, and that NRC has been willing
to provide some financial support for state officials' involvement, is
a testament to the importance that both NRC and agreement states placed
on federal-state collaboration. NRC and agreement states officially
issued requirements for the increased controls in December 2005. The
purposes of the increased controls, according to NRC, are to reduce the
risk of unauthorized use of radioactive materials and to aid the prompt
detection and assessment of and response to any such attempt. Increased
controls include such measures as 24-hour surveillance, multiple layers
of physical security, and measures to ensure the immediate notification
of local law enforcement agencies in the event of any actual or
suspected breach in security. For example, increased controls on
medical sources require some sources to be kept in heavily secured
rooms with limited access (see fig. 1).
Figure 1: Cesium-137 Sources at a Hospital Used for Cancer Treatment
Are Kept in a Secure Room with Limited Access:
[See PDF for image]
This figure is a photograph of the door to a secure room with limited
access.
Source: GAO.
[End of figure]
According to NRC, all increased controls were to be fully implemented
by June 2006. Some licensees with the highest-risk sources were
inspected by June 2007, while all increased controls must be fully
inspected by June 2009. NRC regional offices and agreement state
regulators are also currently in the process of reaching out to
licensees to help ensure they will be able to meet the June 2009
deadline and have already performed preliminary increased controls
inspections on approximately 1,100 of the 1,700 licensees subject to
the new controls (see table 2).
Table 2: Increased Controls on Category 2 or Greater Quantities of the
16 Radionuclides of Concern:
Control: Access controls;
General purpose: Control access to high-risk materials at all times.
Control: Background checks for unescorted access;
General purpose: Limit unescorted access only to those determined to be
trustworthy and reliable after background checks.
Control: Monitor, detect, and respond to unauthorized access;
General purpose: Ensure the establishment of the means to monitor and
immediately detect and respond to any unauthorized access.
Control: Advance coordination with local law enforcement;
General purpose: Response plans must include advanced cooperation with
local law enforcement agencies, and any actual response must include
this local law enforcement agency.
Control: Transportation controls;
General purpose: Additional security measures are required for
shipments of category 1 and 2 sources.
Control: Protection of sensitive physical plant information;
General purpose: Protecting security related information against
unauthorized disclosure by limiting access to trustworthy and reliable
individuals with a need to know.
Source: NRC.
[End of table]
Agreement state officials told us that they have already prevented at
least one attempted theft of an industrial radiography source typically
used to inspect metal parts and welds for defects. The would-be thieves
broke in to an area protected by an alarm system that had been recently
installed by the licensee to comply with the new requirement mandating
the capacity to monitor, detect, and respond quickly with local law
enforcement in the event of any unauthorized access. This new alarm
system immediately notified local law enforcement authorities, who
responded in time to prevent the criminals from obtaining an iridium-
192 radiography source--a potent gamma emitter that could cause
extensive radiation burns if handled improperly.
NRC and agreement states have also collaborated in establishing
criteria for assessing the implementation of increased controls and
integrated these criteria into NRC's existing oversight program, the
Integrated Materials Performance Evaluation Program (IMPEP).[Footnote
11] In March 2006, NRC established performance criteria devised in
working groups with agreement state officials for evaluating the
implementation of increased controls. Under each of the existing
performance categories--staffing and training, the technical quality of
inspections, licensing actions, incident and allegation activities, and
the overall status of the materials inspection program--NRC added
additional performance criteria. For example, NRC regional and
agreement state programs are now evaluated on whether they have
established a system to readily identify new licensees that should be
subject to increased controls and to determine whether sensitive
licensee information is being securely maintained. Although not all NRC
regional and agreement states' radioactive materials programs have been
evaluated on their implementation of the increased controls, 22 of the
35 agreement states and one of the three NRC regional offices with
responsibilities for regulating such materials have to date had aspects
of their implementation of increased controls at least partially
assessed in this manner. Moreover, agreement state officials familiar
with this revised performance evaluation process told us that the new
criteria were effective and valid measures of the implementation of the
increased controls.
Weaknesses Persist in NRC's Materials Licensing Process:
To increase the security of radioactive materials and sealed sources
and better ensure that they are used as intended, we recommended in
2003 that NRC modify its process for issuing specific licenses to
ensure that such sources cannot be purchased before NRC has verified,
through inspection or other means, that the materials and sources will
be used as intended. In December 2006, NRC issued new prelicensing
guidance to help NRC and agreement state licensing officials to make a
risk-based determination of whether an applicant for a license to
possess an amount of radioactive material or source sufficient to
require a specific (rather than a general) license should have to
undergo some sort of verification before being granted a license. This
guidance asked two screening questions: (1) whether "the applicant is
an entity or a licensee transferring control to an entity that has
never had a license or is unknown" and (2) whether the applicant is
seeking category 2 or greater quantities of one or more of the 16
radionuclides of concern and has not already been licensed to possess
materials subject to a security order or additional requirements for
increased controls. If the applicant answers yes to either question,
according to the guidance, the license examiner should consider whether
it is necessary to take any of the steps on a 12-item checklist. For
example, one checklist item suggests doing an Internet search on the
name of the applicant; another suggests conducting a site visit to the
stated place of business. In spring 2007, however, our investigators,
posed as first-time radioactive materials license applicants for
devices containing sources large enough to require specific licenses,
and therefore subject to the extra scrutiny from the 12-item checklist,
they were able to obtain a materials license from NRC, even though an
Internet search or a prelicensing site visit would have revealed the
application to be based on false claims.[Footnote 12] After being
notified of the results of our undercover investigation in June, NRC
stopped issuing specific licenses for radioactive materials and sources
until it could develop and issue "supplemental interim prelicensing
guidance." This supplemental guidance, issued 12 days after NRC stopped
issuing specific licenses, requires a first-time licensee to pass a
site visit inspection at the applicant's place of business or appear at
an NRC regional office for a face-to-face meeting with a license
application reviewer and satisfy this official that the radioactive
materials will be used as intended. Applicants would not be subject to
these requirements if they already have an established regulatory
relationship with NRC or an agreement state and meet other specific
criteria.
In September 2007, NRC announced in a public briefing that it had
developed a comprehensive plan for resolving all the vulnerabilities in
its radioactive materials licensing processes. NRC announced plans to
do several things to help make its program more secure, including the
following.
* Establish a panel of independent external reviewers to study NRC's
materials licensing program vulnerabilities, with particular scrutiny
of its "good faith assumptions" about applicants. This panel presented
a number of observations and recommendations to NRC in March 2008.
* Reconstitute the NRC and agreement state prelicensing working group
to develop solutions to vulnerabilities associated with verification,
counterfeiting, and general licenses.
* Establish a new materials program working group that would review the
results of an independent external review and comprehensively assess
the entire materials licensing program, including NRC's evaluation of
state programs.
* Leverage the capabilities of new databases currently under
development--the National Source Tracking System and Web-based
licensing.
To assure themselves that other radioactive materials licenses had not
been issued to fraudulent individuals, NRC also undertook a
retrospective review of a sampling of licenses to verify their
legitimacy. NRC officials stated that these reviews uncovered no other
incidences of fraud. We think all of these actions are useful steps
toward closing the long-standing vulnerabilities in NRC materials
licensing processes, but it is too early to evaluate whether these
steps will be successful.
NRC Has Taken No Significant Actions to Mitigate the Potential
Psychological Effects of an RDD:
In addition to recommending that NRC work with agreement states and
others to identify and better secure the radioactive sources that pose
the greatest risk of being used to make an RDD, we also recommended
that NRC determine how to effectively mitigate the potential
psychological effects of malicious use of radioactive materials. Since
we issued our 2003 report, DHS issued the National Response Plan in
December of 2004 to establish a comprehensive all-hazards approach to
domestic incident management. The National Response Plan, revised and
reissued as the National Response Framework in January 2008, details
how federal agencies and others should coordinate to ensure an
efficient and effective nationwide response to a broad spectrum of
domestic incidents, including those involving the malicious use of
radioactive materials. Under the National Response Framework, where a
radiological incident involves facilities or materials licensed by the
NRC or agreement states, NRC either coordinates federal response
activities or assists DHS in doing so, depending on the scope of the
incident.[Footnote 13] In our view, such coordination should include
taking actions to determine how to effectively mitigate all the effects
of such an RDD--including psychological effects.
However, NRC has not implemented this recommendation because, according
to NRC officials, NRC has only a very limited role to play in
mitigating the psychological effects that may occur in the aftermath of
an RDD event unless the amount of radioactive materials released is
sufficient to cause "prompt fatalities"--that is, fatalities directly
caused by exposure to radioactive materials. Accordingly, NRC has
identified and taken limited steps that it sees as consistent with its
prescribed role. Specifically, NRC points to its participation in the
interagency Radiation Source Protection and Security Task Force Public
Education Working Group with DHS, DOE, agreement and nonagreement
states, and others to design a coordinated public education campaign
to, among other things, reduce public fears of radioactivity and
diminish the impact of a terrorist attack using radioactive materials.
This working group issued a draft public education action plan in
December 2007 and provided an update on its efforts on May 15, 2008.
NRC is also a member of and has provided input to a Health Physics
Society[Footnote 14] working group that is putting together a program
to educate the public about radiation and help counteract unfounded or
irrational fears.
Despite these activities, in our view, NRC's response to our
recommendation is inadequate. Over 4 years after we made our
recommendation, NRC has not yet determined how to effectively mitigate
the potential psychological effects of the malicious use of radioactive
materials. Moreover, according to existing EPA protective action
guidelines, the amount of radioactive material needed to cause "prompt
fatalities"--the threshold at which NRC accepts having a significant
role--is significantly greater than would be necessary to cause
contaminated areas to be evacuated, a threshold at which psychological
effects could reasonably be expected to occur. According to NRC
officials, unless the prompt fatalities threshold is met, NRC believes
its job is to provide the public with prompt, complete information
about the effects of any release of radiation involving material the
agency regulates and, to the extent it is relevant, to inform the
public about the NRC regulations or guidance that may be relevant as a
result. Beyond participating in an interagency task force working
group, providing any additional information that may be needed is,
according to NRC, the responsibility of others (federal, state, or
local officials, etc.). This approach is consistent with NRC's view
that its primary responsibility is to regulate "inside the fence,
inside licensee-controlled areas." "Outside the fence," NRC views its
role as assisting those federal agencies that have primary
responsibility, namely DHS, DOE, and others and making sure that its
licensees comply with these agencies' legitimate concerns.
NRC Has Not Yet Decided Whether Certain Radioactive Sources Need
Stronger Licensing Requirements:
In light of growing concerns about the potential malicious use of
radioactive sealed sources, and to better secure generally licensed
devices containing such sources, we recommended that NRC, in
consultation with agreement states, re-examine whether certain
radioactive sources should be regulated through specific licenses
rather than general licenses. According to NRC, by November 2007 it had
gathered the necessary information about generally licensed devices
containing relatively larger radioactive sources (the largest category
4 sources or higher) to decide whether changes should be made.[Footnote
15] NRC and agreement state officials are currently analyzing the data
and conferring in working groups and, according to NRC officials,
initiated a rulemaking process in September 2007. Given the complexity
and range of the issue and the solutions to be considered, NRC
officials estimate the formal rulemaking process will take
approximately 2 years, depending on what form a new rule takes. Rules
that require states to make statutory changes typically take longer to
implement. NRC officials stressed that it is impossible to predict what
form a final rule would take. The various options--for example, a lower
activity cap for general licenses; specific licensing requirements for
particular radionuclides regardless of activity; or the development of
a new, more streamlined specific license--will continue to be a subject
of discussion among federal and state radioactive materials regulators
until a decision has been reached. If a revised rule is finalized by
September 2009, agreement states could have up to an additional 3 years
to fully implement any changes--meaning that any rule change may not be
fully implemented until the fall of 2012.
NRC Has Improved Its Ability to Monitor and Track Radioactive Sealed
Sources, but New Systems Have Been Delayed:
NRC has developed an interim database that can monitor and track the
more dangerous, category 1 and 2 radioactive sealed sources. However,
two additional systems--one to track radioactive sealed sources and one
to track licenses--have been repeatedly delayed. A third system under
development will draw on information in both of these systems to
provide regulators and vendors with the ability to verify that those
seeking to purchase radioactive sources are licensed to do so.
NRC Created an Interim National Database to Better Monitor the More
Dangerous Radioactive Sealed Sources:
NRC established the interim database in October 2003 to provide NRC and
agreement states a stop-gap means of more closely monitoring the
potentially more dangerous sources until the new National Source
Tracking System (NSTS) could be completed. This database is called
"interim" because it is intended to be a temporary measure for
implementing a quick, practical response to the recommendation in the
May 2003 DOE-NRC report on RDDs that the U.S. government develop a
database of sources at greatest risk of being used to make an RDD. The
interim database currently records information about category 1 and 2
radioactive sealed sources licensed by both NRC and agreement states.
[Footnote 16] For a given source, the interim database records the
radionuclide; the quantity (activity); the licensee address; and the
make, model, and serial number (where available) of the registered
source. Although participation is voluntary, NRC successfully persuaded
agreement states to provide data on their licensees for inclusion in
the interim database, and as a result, the database includes
information from 99 percent of all licensees. Originally, the database
was intended to be a one-time snapshot of what radioactive materials
existed in the United States during fiscal year 2004. However, NRC
began to update the database annually as it became apparent that the
development and launch of the NSTS would take longer than expected. The
result is an annual snapshot of information about radioactive sources
as they were at one point during a given year, not a system that tracks
the current location of sources. The information for any given source
in the database is, at any given time, 0 to 12 months old.
It is important to note that the licensee address listed in the interim
database may simply be the address for the licensee's administrative
offices--that is, the place where the company officials responsible for
dealing with NRC or state regulators have offices--and not necessarily
the address of the physical location of the material. A licensee may be
allowed to store radioactive materials in several locations throughout
one or more states but still provide only a single administrative
address for reporting purposes in the interim database. NRC and
agreement states check the completeness and accuracy of this inventory
of source locations during routine inspections of licensees.
New Systems to Track Radioactive Sealed Sources and Licenses Have
Limitations and Have Been Repeatedly Delayed:
The completion and implementation of the major new systems NRC is
developing to help it better track, and ultimately help secure,
radioactive sealed sources have been delayed repeatedly. The impetus
for the creation of the NSTS was a recommendation in the May 2003 DOE-
NRC report on RDDs that radionuclides identified as being at greatest
risk of use by terrorists to make an RDD be nationally tracked. The
Energy Policy Act of 2005 required the establishment of a mandatory
tracking system.[Footnote 17] The NSTS is also consistent with the
United States' endorsement of the IAEA Code of Conduct, which
recommends that nations establish a national source registry to
include, at a minimum, category 1 and 2 sources of radionuclides of
concern.
The NSTS will initially track category 1 and 2 sources of the 20
radionuclides that NRC has determined are sufficiently attractive for
use in an RDD or for other malicious purposes that warrant national
tracking. The 20 radionuclides include the 16 radionuclides of concern
plus four additional radionuclides: actinium-227, polonium-210, and
thorium-228 and -229.[Footnote 18] In April 2008, NRC proposed a rule
to expand the NSTS to include all category 3 sources and the largest
category 4 sources (at or about one-tenth of the activity threshold for
category 3). Although the NSTS was originally supposed to be
operational in mid-2007, difficulties in developing the system have led
NRC to postpone the launch of the NSTS multiple times. NRC's current
estimate for the launch of the NSTS (tracking category 1 and 2 sources)
is January 31, 2009. NRC estimates the expansion of the NSTS will be
implemented by March 2010.
According to NRC, the NSTS will initially be populated by the data from
the interim database. However, unlike the interim database, the NSTS
will not be an annual snapshot of source inventories. The NSTS will be
a transaction-based system that will track each major step that each
tracked radioactive source takes within the United States, from "cradle
to grave." That is, licensees will be responsible for recording the
manufacture, shipment, arrival, and disposal of all licensed and
tracked category 1 and 2 radioactive sources. More specifically, the
NSTS will include the radionuclide, quantity (activity),[Footnote 19]
manufacturer, manufacture date, model number, serial number, and site
address. The licensee will have until the close of the next business
day after a transaction takes place to enter it into the system. As a
result, the location of all such sources will be accounted for and more
closely tracked than in the interim database. While some sources may be
moved temporarily to different sites, any time that the source changes
its "home base," the transaction must be registered through the NSTS.
In this way, the data in the system should be kept up-to-date.
For security reasons, access to the information in the NSTS will be on
a need-to-know basis. Licensees will have access to information about
their sources, agreement state officials will have access to
information about licensees and sources in their state, and only
selected NRC officials will have access to the entire system.
While the NSTS is designed to track larger and potentially more
dangerous radioactive sealed sources, NRC's Web-based licensing system
is being developed to provide quick access to up-to-date information on
all NRC specific licenses for radioactive materials and sources in all
five IAEA categories. In its technical comments on a draft of this
report, NRC told us that it is developing a third system--a license
verification system--which, once operational, will draw on the
information in NSTS and the Web-based licensing system which will
provide regulators and vendors of radioactive sources with an easily
accessible ability to verify that those seeking to purchase nationally
tracked sources are licensed to do so. Taken together, these systems
will include detailed information about what licensees are allowed to
possess and, importantly, whether a prospective licensee seeking to
purchase additional sealed sources is authorized to possess the
additional types and quantities. For example, an individual from a
construction company wanting to purchase a piece of equipment
containing a radioactive sealed source must demonstrate to the vendor
that the company is licensed to possess such a source. Once all three
systems are operational, the vendor could easily verify that the
company is legitimately licensed to purchase a given piece of equipment
containing the particular sealed source. Although the Web-based
licensing system was originally supposed to be deployed in 2005, it is
now estimated be completed no earlier than the late summer of 2010.
Moreover, the Web-based licensing system may not initially include any
information on radioactive materials licenses issued by agreement
states--which represent over 80 percent of all U.S. licenses for these
materials. NRC officials told us that they are currently working with
agreement states to determine the most efficient means of including
agreement state data in the Web-based licensing system. Finally, NRC
has only recently begun developing its new license verification system
and has not yet established firm completion dates. However, NRC
officials told us that they expect it to be complete by the time that
the Web-based licensing is launched.
The delays in the development of both the NSTS and the Web-based
licensing system are especially consequential because NRC officials,
both commissioners and staff, have identified the deployment of these
systems as key to improving the control and accountability of
radioactive materials in the United States. More specifically, in NRC's
September 2007 public hearing addressing the weaknesses that we
uncovered in NRC's materials licensing program, the commissioners said
that an expanded NSTS including category 3 and perhaps the largest
category 4 sources, a Web-based licensing system including agreement
state data, and some means for making relevant information in both of
these systems available to vendors and officials at ports of entry,
would be a secure and effective means of verifying that those seeking
to obtain radioactive materials, or enter the United States with
licensable quantities of radioactive materials or sources, were doing
so for legitimate purposes.
CBP Has a Comprehensive System for Detecting Radiation at Ports of
Entry on the Northern and Southern Borders:
CBP has a comprehensive, layered system for detecting and identifying
radioactive materials as they enter the United States at land ports of
entry--whether they are in the form of industrial sources, raw
materials, trace amounts of radiation found in such common products as
ceramics or bananas, or radionuclides left in the human body in the
aftermath of medical procedures. However, some equipment that is used
to protect CBP officers is in short supply.
CBP's Radiation Portal Monitors Scan Most Vehicle, Cargo, and Passenger
Traffic Entering the United States:
According to CBP, over 90 percent of the personally owned vehicles
entering the United States at land ports of entry pass through
radiation portal monitors.[Footnote 20] Portal monitors are very
sensitive and can detect even the very small amounts of radiation. All
vehicles must pass through the monitors at every port of entry that
deploys them. Any vehicle triggering a portal monitor alarm is referred
to a secondary screening area, where it is sent through a second portal
monitor to confirm (or disconfirm) the original alarm. Whether the
second portal monitor confirms the alarm or not, the vehicle, the
driver, any passengers, and any cargo are scanned by a CBP officer with
a hand-held radiation isotope identification device (RIID). The RIID
can detect very small amounts of radiation and also identify many of
the most commonly used radionuclides by name and activity level. CBP
keeps detailed records on the cause of each alarm and its resolution
and sends them to a central location for archiving. All portal monitor
alarms must be resolved--that is, CBP officers must investigate each
alarm until they are convinced that the vehicle, occupants, and any
cargo pose no threat and, if radioactive materials are found, that the
vehicle occupants appear to have a legitimate reason to possess and
transport them--before the vehicle, driver, and any passengers can be
allowed to enter the United States.
The vast majority of portal monitor alarms are resolved by CBP officers
at the border using the information available to them directly from
portal monitor and RIID scans, documents provided by shippers and
passengers, and the explanations of the travelers (commercial and
passenger vehicle drivers and passengers) for why they are carrying
radioactive materials, whatever the amount or form. When CBP officers
cannot resolve the radiation alarm with information available to them
at the border, they are required to contact technical experts at CBP's
National Targeting Center for assistance. These experts offer
scientific expertise to help CBP officers interpret and use the portal
monitor and RIID data and will also verify whether any radioactive
sources have been properly licensed by checking NRC and agreement state
licensing data.[Footnote 21] Figures 2 and 3 show vehicles lining up
and passing through portal monitors at ports of entry. Figure 4 shows
an inspection area and a truck-sized portal monitor on the southern
border.
Figure 2: Passenger Vehicles at a Port of Entry on the Southern Border:
[See PDF for image]
Photograph of passenger vehicles at a port of entry on the southern
border.
Source: GAO.
[End of figure]
Figure 3: Trucks Passing through Portal Monitors on the Northern
Border:
[See PDF for image]
Photograph of trucks passing through portal monitors on the northern
border.
Source: GAO.
[End of figure]
Figure 4: Truck-Sized Portal Monitor in the Inspection Area at a Port
of Entry on the Southern Border:
[See PDF for image]
Photograph of truck-sized portal monitor in the inspection area at a
port of entry on the southern border.
Source: GAO.
[End of figure]
Most of the CBP officers we spoke with at the ports of entry we visited
told us they had never or rarely felt it necessary to contact the
National Targeting Center for assistance, but they all stated that they
would not hesitate to do so if they encountered anything out of the
ordinary or if they thought something might pose any threat to national
security. Those CBP officers who told us they had contacted the center
for assistance were very pleased with the timely and practical help
they received.
Some Radiation Detection Equipment Is in Short Supply:
Finally, we found that personal radiation detectors--an important
component of the suite of radiation detection equipment at the borders-
-are in short supply. Unlike portal monitors and RIIDs, personal
radiation detectors are not designed to be used as screening tools for
radioactive materials. Instead, they are designed to alert the
individual wearer when he or she is being exposed to unusually high
levels of radiation, permitting CBP officers to take protective
measures if needed. While most CBP officers dealing with the public in
frontline positions are equipped with personal radiation detectors,
some are not. According to CBP officials, the agency lacks sufficient
resources to purchase the approximately 1,500 personal radiation
detectors it needs to provide one for each officer at the border who
currently needs one. In fact, during our visit to one port of entry, we
found that some officers in frontline positions at the border did not
have a personal radiation detector. Moreover, CBP has no money
currently in the budget to acquire the approximately 2,000 additional
personal radiation detectors it would require to equip the new officers
it plans to hire--leaving a shortfall of about 3,500 personal radiation
detectors. CBP headquarters officials are aware of the shortage of
personal radiation detectors and they hope to procure enough of them
for each officer who needs one. However, they acknowledged that, in
doing so, they have to consider competing priorities at the border, and
also whether emerging technologies may provide a more effective
solution.
CBP Guidance on When to Verify Licenses for Radioactive Materials
Entering the United States Was Not Communicated to the Field:
In December 2003, CBP issued a radiation detection program directive
that contained, among other things, the requirement that CBP officers
at the border contact the National Targeting Center for assistance
under certain circumstances when radiation is detected. Under the
directive, even large shipments of radioactive materials can be
admitted without a CBP officer contacting the National Targeting Center
to verify whether the materials are legitimately licensed. The
radiation detection program directive was scheduled for review in
December 2006, but CBP officials told us that this review was delayed
pending the resolution of unrelated matters regarding the CBP's right
to search property for radioactive materials between ports of entry.
In response to our March 2006 reports[Footnote 22] assessing the
progress DHS has made deploying radiation detection equipment at U.S.
ports of entry and detailing how our investigators used fake documents
to bring licensable quantities of industrial radioactive sources into
the United States respectively, CBP revised its policy. Specifically,
in May 2006, CBP issued a memorandum that officials told us tightened
security by requiring CBP officers to contact the center to verify the
legitimacy of a license or obtain technical assistance whenever they
detect more than incidental, trace amounts of radiation, such as that
found in ceramics and bananas or in people who have recently undergone
a medical treatment using radionuclides. This memorandum, according to
headquarters officials, was intended to communicate to officers at the
border that they should verify the legitimacy of radioactive materials
because CBP officers at a port of entry cannot determine whether a
licensee or shipper is authentic without the assistance of the National
Targeting Center.
This updated guidance, however, was not effectively communicated to
officers at the border. Specifically, we asked border officials at the
several ports of entry we visited and the four others we interviewed on
the telephone about the current guidance they use for regulating the
flow of radioactive materials across borders. All either provided us
copies of the 2003 radiation detection program directive or confirmed
it was current and operative, and some gave us versions of the
directive that were port-specific, and therefore, more detailed. Only
one port of entry provided us with guidance reflecting the May 2006
memorandum and its requirement that CBP officers contact the National
Targeting Center to verify the legitimacy of all licensable quantities
of radioactive materials crossing the border. Moreover, officials at
all these ports of entry told us that they contact the National
Targeting Center for technical assistance when they need it; officials
at only one port of entry told us they would call solely to verify
whether radioactive materials are appropriately licensed. Officials
representing a few other ports of entry told us they had never called
the National Targeting Center to verify the legitimacy of a license and
that all of their inquiries had been made solely to seek technical
assistance.
In addition, the officers we spoke to had minimal knowledge of the
general regulatory structure established by NRC and agreement states.
While we found officers generally were aware that radioactive materials
and sources must be licensed, they typically did not take steps to
verify licenses, as required by the May 2006 guidance. At the ports of
entry we visited, we observed CBP officers working to ensure that when
radioactive materials triggered an alarm, the people carrying (or
contaminated with) these materials had a good explanation and that the
readings from the portal monitors and RIIDs were in accord with what
travelers said and what their documents attested to. In short, the
officers were focused on resolving the alarm according to the rules
established in the 2003 radiation detection program directive and on
attending to the many other tasks they have in monitoring what flows
through U.S. land ports of entry.
In fact, the approach to resolving radiation alarms according to the
procedures prescribed in the 2003 radiation detection directive has
been so ingrained in day-to-day practice at one port of entry that CBP
field office managers had discovered only in the week before our visit
that officers had been allowing large neutron radiation-emitting
shipments to enter the United States without contacting the National
Targeting Center for technical support and to verify their legitimacy.
While this situation has since been corrected, this is of particular
concern because (1) some neutron radiation-emitting materials can be
used to produce nuclear weapons and (2) it is in direct conflict with
CBP's 2003 directive and 2006 supplemental guidance.
A senior CBP headquarters official told us that the 2003 radiation
detection program directive, as supplemented by the additional criteria
established by the May 2006 memorandum on when CBP officers must call
to verify the legitimacy of radioactive materials, reflected current
policy. He told us that the May 2006 memorandum was always envisioned
as only an interim solution, pending a revision of the directive.
According to this official, CBP was still working on a revision to the
directive that would fully incorporate the heightened security of the
memorandum--but he could not give a firm date when an updated directive
would be issued. In our view, until CBP effectively communicates the
guidance in the 2006 memorandum to its border locations, CBP officers
at the border will not know when they should contact the National
Targeting Center to verify that radioactive materials being brought
into the United States are legitimately licensed.
Conclusions:
NRC has taken a number of important actions to implement several of our
recommendations from our 2003 report that will enhance the
accountability and control of radioactive sources and materials and its
ability to help protect the nation from nuclear smuggling. Still, its
actions in three key areas remain incomplete. In our view, the reasons
behind our recommendations 4 years ago are still valid today.
Accordingly, to further enhance public protection from the threats
posed by potentially dangerous quantities of radioactive sealed sources
and materials, we continue to believe that NRC should implement the
recommendations from our 2003 report. Specifically, NRC should:
* correct the vulnerabilities uncovered in NRC's materials licensing
process and implement the steps needed to ensure that radioactive
materials can only be purchased by those with a legitimate reason to
possess them, and:
* determine whether certain radioactive sources should be regulated
through specific licenses rather than general licenses and move quickly
to implement whatever changes are deemed necessary.
In addition, we continue to believe that a plan of how to effectively
mitigate the potential psychological effects of an RDD event needs to
be developed. For potential incidents involving radiological facilities
or materials licensed by NRC or agreement states, for which NRC has
coordinating responsibilities, NRC should work with DHS, other federal
agencies, and agreement states, respecting the roles described in the
National Response Framework, to take action to determine how to
effectively mitigate the potential psychological effects of such an
event.
Also, the causes of the delays in the development and implementation of
NRC's more comprehensive systems for securing, monitoring, and tracking
radioactive materials need to be confronted and addressed.
Specifically, NRC's National Source Tracking System and Web-based
licensing system have missed numerous milestones and are not expected
to be complete as currently envisioned until at least 2010. Past delays
in implementing these systems give reason to wonder whether these dates
will again be extended and whether NRC is firmly committed to
delivering these systems. The recent decision to develop a third new
system has added to these concerns. In our view, given the potential
consequences of the use of these materials in an RDD and the potential
for these systems to greatly improve the security of both NRC's and
agreement states' materials licensing processes, it is time for NRC to
make meaningful progress in successfully completing these important
initiatives.
While CBP has a comprehensive system in place to detect radiation at
ports of entry on the northern and southern borders, CBP's task of
preventing the smuggling of radioactive materials is made more
difficult by the fact that guidance on when officers should verify
whether radioactive materials being brought into the United States are
legitimately licensed has not been effectively communicated. The result
of this communication gap is that resources that are available to CBP
officers at the border to ensure that those possessing radioactive
materials are doing so legitimately are underutilized.
Recommendations for Executive Action:
Given the repeated delays in implementing improvements to the Nuclear
Regulatory Commission's ability to monitor and track radioactive sealed
sources, we recommend that the Chairman of the Nuclear Regulatory
Commission take steps, consistent with sound systems development
practices, to ensure that priority attention is given to meeting the
current January 2009 and summer 2010 target dates for launching the
National Source Tracking System, Web-based licensing system, and the
new license verification system, respectively.
In addition, because some quantities of radioactive materials are
potentially dangerous to human health if not properly handled, we
recommend that the Nuclear Regulatory Commission complete the steps
needed to include all potentially dangerous radioactive sources
(category 3 and the larger category 4 sources, as well as categories 1
and 2) in the National Source Tracking System as quickly as is
reasonably possible.
Finally, to improve the likelihood of preventing radioactive sources
and materials from being smuggled into the United States, we recommend
that the Secretary of Homeland Security direct the Commissioner of
Customs and Border Protection to:
* effectively communicate current Customs and Border Protection
guidance to officers at ports of entry regarding when they are required
to contact the National Targeting Center to verify that radioactive
materials are legitimately licensed, and:
* take measures to ensure that this guidance is being followed.
Agency Comments and Our Evaluation:
We provided the Chairman of the Nuclear Regulatory Commission, the
Secretary of Homeland Security, the Secretary of Energy, the
Administrator of the Environmental Protection Agency, and the Chair of
the Organization of Agreement States with draft copies of our report
for their review and comment.
In commenting on the draft of this report, NRC neither agreed nor
disagreed with our findings and recommendations. Instead, NRC described
its current efforts to implement the recommendations from our 2003
report. On this point, NRC outlined the steps it is taking to modify
and strengthen its processes and procedures for licensing radioactive
materials. NRC also provided an update on the status of the efforts of
the Radiation Source Protection and Security Task Force's subgroup on
public education--a subgroup led by DHS of which NRC is a member--to
proactively educate the general public about radiation with the goal of
reducing public anxiety and mitigating the adverse psychological
effects in the event of an RDD attack. Finally, NRC described its
proposed rule, expected to be issued in the fall of 2009, to limit the
quantity of radioactive material allowed in a generally licensed
device. Although we are encouraged by NRC's efforts to finish
implementing the recommendations from our 2003 report, we remain
concerned that nearly 5 years after we issued our report these
recommendations have yet to be fully implemented. Furthermore, NRC
stated that it is taking the steps necessary to launch the National
Source Tracking System (NSTS) and Web-based licensing and to complete
the needed steps to include all potentially dangerous radioactive
sources in the NSTS as quickly as is reasonably possible. In addition,
NRC assures that it intends to place the highest priority on the
completion and deployment of the NSTS and Web-based licensing system.
However, we are concerned that NRC has once again postponed its
estimated completion dates for these systems--by at least 9 months in
the case of expanding NSTS to include the smaller but still potentially
dangerous radioactive sources and estimates a similar delay in the
deployment of the Web-based licensing system. Finally, in its technical
comments, NRC informed us that it is developing a new, third system
which will draw information from both the NSTS and the Web-based
licensing system to provide an improved capability for vendors and
regulators to verify licensing information. While we hope this new,
third system provides the intended additional capabilities, we are
concerned that after so many delays with NSTS and the Web-based
licensing system, adding a third system may further delay the ultimate
security benefits that these systems are expected to provide. NRC also
provided additional technical comments, which we incorporated into the
report as appropriate.
The other federal agencies that were offered the opportunity to comment
on our report either agreed with our recommendations and outlined the
steps to be taken to implement them, or chose not comment on the final
draft. Specifically, according to DHS's written comments, CBP concurred
with our recommendations and specified the steps it will take to
effectively communicate current Customs and Border Protection guidance
to officers at ports of entry regarding when they are required to
contact the National Targeting Center to verify that radioactive
materials are legitimately licensed, and the measures it will take to
ensure this guidance is being followed. In fact, CBP has already
updated its current guidance to CBP officers at the border by issuing a
memorandum to the field directors restating and clarifying when
officers must contact the National Targeting Center to verify that
radioactive materials are legitimately licensed and requiring them to
incorporate this guidance into ports of entry standard operating
procedures. Finally, DOE and EPA reviewed and provided comments on
earlier versions of our draft report and, after reviewing our final
draft, had no further comments.
The Organization of Agreement States neither agreed nor disagreed with
our findings and recommendations, but offered two comments which we
incorporated into the report. Specifically, state officials thought it
was important to recognize the quality of agreement state regulatory
programs by highlighting the fact that while GAO investigators
succeeded in obtaining an NRC radioactive materials license using
fictitious documents, GAO withdrew its application to obtain a
materials license from the agreement state when that state informed GAO
investigators that it would take steps that would have revealed the
application not to be authentic. State officials also wanted to stress
what they view as the high level of collaboration they enjoy with NRC,
as evidenced by the number of state officials involved in security-
related working groups with NRC officials and the financial support
that NRC provides to states to enable this level of state
participation.
As agreed with your offices, unless you publicly announce the contents
of this report, we plan no further distribution until 24 days from the
report date. At that time, we will send copies of this report to the
Chairman of the Nuclear Regulatory Commission, the Secretary of
Homeland Security, the Secretary of Energy, the Administrator of the
Environmental Protection Agency, the Chair of the Organization of
Agreement States, and interested congressional committees. We will also
make copies available to others upon request. In addition, this report
will be available at no charge on the GAO Web site at [hyperlink,
http://www.gao.gov].
If you or your staffs have any questions about this report, please
contact me at (202) 512-3841 or 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 that made major contributions
to this report are listed in appendix V.
Signed by:
Gene Aloise:
Director, Natural Resources and Environment:
[End of section]
Appendix I: Potential Effects of a Radiological Dispersal Device with
Category 1, 2, and 3 Quantities of Radioactive Material:
A radiological dispersal device (RDD) is any type of device that is
intended to disperse radioactive materials, through conventional
explosives or other means. Among the federal agencies, the
Environmental Protection Agency (EPA) has lead responsibility for
providing radiological emergency planning guidance, known as Protective
Action Guides (PAG), to protect the public from exposure to radiation.
In addition, the Department of Homeland Security (DHS) issued PAGs for
responses to RDD and improvised nuclear devices (IND) for interim use
and comment. Both EPA's and DHS's PAGs can be used by other federal
agencies or state governments to develop their own guidance or
regulations to protect public health. According to EPA officials, the
general public's fear of radiation, coupled with most law enforcement
officers' relative inexperience dealing with radioactive material,
would likely cause any emergency incident that triggers first
responders' radiation detectors to be treated as an RDD. Until the type
and specific quantity of radioactive material could be determined, the
situation would initiate a federal response, whether or not specific,
federal thresholds for safety have been reached. Even very small
amounts of radioactive material are sufficient to set off the radiation
detectors of first responders.
For purposes of illustration (see table 3), we calculated how large an
area might be sufficiently contaminated using International Atomic
Energy Agency (IAEA) category 1, 2, and 3 quantities of cesium-137--
assuming the material could be evenly distributed--to (1) trigger the
EPA PAG recommending relocation of the public until the site is cleaned
up and (2) reach the threshold at which potential direct health
effects, such as radiation sickness, might occur. We used category 2
and 3 amounts of cesium-137 (one of the 16 radionuclides of concern)
because, according to the International Atomic Energy Agency
categorization scheme, the threshold category 3 quantity is the amount
at which a radionuclide becomes potentially dangerous to human health
if not handled appropriately. A category 2 quantity of a radioactive
material is at least 10 times more dangerous than the category 3
threshold quantity and is also the level at which NRC requires
licensees to take additional security measures to protect the material
from unauthorized access or use. We calculated how large an area might
be contaminated with a category 1 quantity of cesium-137 because such
quantities can be found in medical devices and irradiators throughout
the United States.
Table 3: Potential Contamination from an RDD:
Thresholds for concern (based on 1 year of exposure):
Amount of radioactive material (cesium-137):
* Category 3 threshold (2.7 curies);
* Category 2 threshold (27 curies);
* Category 1 threshold (2,700 curies).
EPA recommends relocation (2 rem)[A]:
Amount of radioactive material (cesium-137):
* Category 1: 15.1 acres;
* Category 2: 150.7 acres;
* Category 3: 15,012 acres.
Potential observable health effects (100 rem);
Amount of radioactive material (cesium-137):
* Category 1: 0.3 acre;
* Category 2: 3 acres;
* Category 3: 300 acres.
Source: GAO.
Notes: Calculations based on the Department of Energy's Federal
Regulatory Monitoring and Assessment Center dose assessment
methodology. The potential area contamination figures assume uniform
ground deposition of radioactive material, which is difficult to
accomplish and may not be realistic.
[A] A rem is a term scientists use to describe how much radiation the
body absorbs, multiplied by a quality factor for the various types of
radiation (e.g., alpha, beta, gamma, or neutron). For example,
scientists estimate that the average person receives 360 millirem (0.36
rem) every year from natural (such as radon gas) and manufactured
radiation sources (such as exposure to radioactive isotopes used in
some medical procedures).
[End of table]
Specifically, when the potential additional exposure to radiation for a
person remaining in a given area for 1 year reaches 2 rem, EPA
considers the area sufficiently dangerous to recommend that people be
relocated until the site can be decontaminated. When the potential
exposure to radiation over the course of 1 year reaches 100 rem, the
International Commission on Radiological Protection--an organization of
radiation scientists from around the world who provide recommendations
regarding radiation exposure--concludes that readily observable health
effects, such as radiation sickness, are possible with extended
exposure. Only a category 1 quantity would be likely to produce health
effects due to acute radiation doses. This level, however, is still
substantially below the level at which prompt fatalities could occur.
(Prompt fatalities from untreated radiation exposure may only result
from acute radiation doses--that is, doses delivered in their entirety
in a matter of hours or days--of at least hundreds of rem from a
predominately beta-gamma emitting radionuclide like cesium-137.)
EPA guidance is based on protecting human health and calculating the
odds that radiation exposure will lead to cancer, the most common of
radiation's long term side effects. In the event of an RDD, federal RDD
PAGs, such as those issued by DHS in 2006, would be used to manage the
response to the incident. PAGs are operative during the emergency, and
their chief goal is to protect the public by providing standards to
guide the response in the early and intermediate phases of an incident.
However, any PAG guidance is only a series of recommendations and is
not legally enforceable or binding.
Furthermore, a PAG does not establish cleanup levels. In fact, guidance
for specific cleanup levels after an RDD has been deliberately left ad
hoc, and is to be established after an evaluation occurs using an
"optimization" process for long-term site cleanup and restoration. The
level to which a contaminated site would be cleaned up for the long
term would be agreed upon after the emergency has passed and would
depend on the uses of the site. A cleanup standard would factor in the
lifetime exposure that the contamination creates for the people using
the site--generally, the long-term increased risk of developing cancer.
For example, a site that is used for business purposes, where the
typical person would spend only working hours, would not have to be
cleaned up to the same level as a site where people live, where some
people could reasonably be exposed to the post-cleanup radiation levels
24 hours a day. Public involvement in the decision would play a
significant role in determining what risk levels are acceptable. While
EPA provides guidelines, state and local authorities make the ultimate
decisions under most scenarios.
[End of section]
Appendix II: Comments from the Nuclear Regulatory Commission:
United States Nuclear Regulatory Commission:
Washington, DC 20565-0001:
May 28, 2008:
Mr. Gene Aloise, Director:
Natural Resources and Environment:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, D.C. 20548:
Dear Mr. Aloise:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am
responding to your e-mail dated April 21, 2008, requesting NRC review
and comment on your draft report, "Nuclear Security: NRC and DHS Need
to Take Additional Steps to Better Track and Detect Radioactive
Materials" (GAO-08-598). I appreciate you providing the NRC the
opportunity to review this draft report and the time and effort that
you and your staff have invested in reviewing this important topic.
NRC's leadership role in applying a risk-based approach has enhanced
security of radioactive materials and has reduced the potential threat
from a radiological dispersal device (RDD) or radiological exposure
device. As a result, these materials are significantly more secure than
before the events of September 11, 2001. NRC is working closely with
its domestic and international partners to continuously assess,
integrate, and improve its security programs to make risk-significant
radiation sources more secure and less vulnerable to terrorists.
Specifically, the U.S. Government Accountability Office (GAO) noted
that the NRC has made limited progress toward implementing 3 of the 6
recommendations in the 2003 report on security of radioactive sources.
The GAO recommended that the NRC: (1) modify its process for issuing
licenses to ensure that radioactive materials cannot be purchased by
individuals with no legitimate need for them; (2) determine how to
effectively mitigate the potential psychological effects of malicious
use of such materials; and (3) examine whether certain radioactive
sources should be subject to more stringent regulations. With regard to
these recommendations, the NRC and its Federal and Agreement State
partners have made and are making significant progress towards
achieving these goals.
Beginning in January 2008, the NRC has modified its licensing process
and now conducts pre-licensing site visits for all unknown applicants
before issuing new licenses. The new procedure was tested in a pilot
project with the Agreement States. The procedure will be revised based
on comments received from licensing reviewers in the NRC Regions and
the Agreement States as a result of the pilot project. These actions
are aiding in the prevention of illegitimate purchases of radioactive
materials.
The NRC is working with its Federal and Agreement State partners to
address the issue of mitigation of potential psychological effects of
an RDD through the Radiation Source Protection and Security Task
Force's (Task Force) subgroup on public education, which is chaired by
the Department of Homeland Security. As noted in their December 2007
Draft Public Education Action Plan, proactively educating the public
about radiation in general and the specific radiation risks associated
with RDDs may reduce the public's anxiety and ameliorate adverse
psychological impacts in the event of an RDD attack. This plan was
presented to the Task Force on May 15, 2008.
Additionally, the Task Force has reactivated the radiation sources
subgroup to reevaluate the list of radioactive sources that warrant
enhanced security and protection. The subgroup's proposed evaluation
will take economic, physical, psychological, and social disruption
consequences into consideration. The results will be presented to the
Task Force by November 2008. The combined work planned by these two
subgroups will address mitigation of psychological impacts of a RDD and
address whether enhanced security measures may be warranted for certain
radioactive materials.
With regard to whether generally licensed radioactive sources should be
subject to more stringent regulations, the NRC formed a rulemaking
working group which included State representatives in September 2007,
to consider which sources should be specifically licensed. The working
group has drafted a proposed rule to limit the quantity of radioactive
material allowed in a generally licensed device. The draft proposed
rule is currently being reviewed by the NRC and the Agreement States
and is expected to be issued for public comment this fall. The final
rule is projected to be issued in fall 2009.
In addition to providing a status update on the NRC's progress in
implementing the recommendations from the 2003 report, the GAO also
recommended that the Chairman of the NRC take steps, consistent with
sound systems development practices, to: (1) ensure that priority
attention is given to meeting the current January and October 2009
target dates for launching the National Source Tracking System (NSTS)
and Web-based Licensing (WBL) System, respectively, and (2) complete
the needed steps to include all potentially dangerous radioactive
sources in the NSTS as quickly as is reasonably possible.
With regard to the GAO's recommendation that the NRC take steps to
ensure that priority attention is given to meeting the current January
and October 2009 target dates for launching the NSTS and WBL systems, I
want to assure you that the Commission has placed a high priority in
the deployment of these systems. In accordance with Office of
Management and Budget guidance, the NRC has employed sound system
development practices. The NRC has: (1) assigned professionally
certified project managers to both NSTS and WBL; (2) set reasonable
performance baselines and integrated project schedules for both NSTS
and WBL; and (3) employed earned value management on the NSTS project
and wilt employ it on the WBL project once a contract is in place. The
NSTS is on schedule for deployment in January 2009. Additionally, a
proposed rule has been issued for public comment, which would expand
NSTS beyond Category 2 sources to include Category 3 and 1/10th of the
Category 3 threshold values. The final rule is projected to be issued
in early 2009. The October 2009 target date for WBL deployment was
based upon having a contract awarded and a preliminary estimate of
remaining work. The NRC has encountered delays in awarding the
contract, which are based on changing scope and requirements to meet
current programmatic needs. NRC's goal is to have the contract awarded
by late summer 2008 and to have the system deployed 24 months later.
Enclosed are additional comments related to enhancing the clarity and
accuracy of statements in the body of the report. Should you have any
questions about these comments, please contact Mr. Jesse Arildsen of my
staff at (301) 415-1785.
Sincerely,
Signed by:
R.W. Borchardt:
Executive Director for Operations
Enclosure:
NRC Comments on the GAO's Draft Report, "Nuclear Security: NRC and DHS
Need to Take Additional Steps to Better Track and Detect Radioactive
Materials" (GAO-08-598).
[End of section]
Appendix III: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
[hyperlink, http://www.dhs.gov]:
Washington, DC 20528:
June 2, 2008:
Mr. Gene Aloise:
Director, Natural Resources and Environment:
U.S. Government Accountability Office:
Washington, D.C. 20548:
Dear Mr. Aloise:
Thank you for providing us with a copy of the draft report entitled
"Nuclear Security: NRC and DHS Need to Take Additional Steps to Better
Track and Detect Radioactive Materials" (GAO-08-598) where GAO was
requested to assess: 1) the progress NRC has made in implementing 2003
recommendations; 2) other steps NRC has taken to improve its ability to
track radioactive materials; 3) Customs and Border Protection's (CBP's)
ability to detect radioactive materials at land ports of entry; and 4)
CBP's ability to verify that such materials are appropriately licensed
before they are allowed to enter the United States.
CBP concurs with GAO's recommendation that CBP effectively communicate
current CBP guidance to officers at ports of entry regarding when they
are required to call the National Targeting Center to verify the
legitimacy of radioactive materials; and take measures to ensure that
this guidance is being followed.
CBP will:
1) Issue guidance to officers at ports of entry regarding when they are
required to call the National Targeting Center to verify the legitimacy
of radioactive materials.
2) Have all field offices ensure that the port's Standard Operating
Procedures include the guidance.
Due Date: March 31, 2009.
We thank you again for the opportunity to review the draft report and
provide comments.
Sincerely,
Signed by:
Penelope G. McCormack:
Acting Director:
Departmental GAO/OIG Liaison Office:
[End of section]
Appendix IV: Comments from the Organization of Agreement States:
Organization of Agreement States:
Cindy Cardwell, Chair, Texas:
Julia Schmitt, Chair-Elect, Nebraska:
Paul Schmidt, Past Chair, Wisconsin:
Tom Conley, Treasurer, Kansas:
Isabelle Busenitz, Secretary, Kansas:
Lee Cox, Director, North Carolina:
Ann Troxler, Director, Louisiana:
May 27, 2008:
Gene Aloise:
Director, Natural Resources and Environment:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Mr. Aloise:
Please accept the comments below on behalf of the Board of the
Organization of Agreement States on the draft report on Nuclear
Security, which you provided to us during the week of April 21, 2008
and for the statement of facts provided to us in March. We've noted the
changes from the earlier document to this one.
In the section of the report beginning on page 18, which discusses
GAO's ability to obtain a license from NRC for a false company, no
mention is made of GAO's attempt to obtain a license from an Agreement
State. GAO subsequently abandoned that attempt when the licensing
process of the Agreement State was made known. The Agreement States
believe this is very significant, not only because an Agreement State's
actions caused such an attempt to be abandoned, but because this points
out the very real fact that the licensing process may indeed differ.
Agreement State programs may go to different lengths in verifications
made during the licensing process. So, the fact that GAO obtained a
license from one regulatory agency is not indicative that the same
would happen with any other regulatory agency.
Although collaboration between NRC and the Agreement States is
mentioned several times throughout the report, we do not believe this
point is emphasized enough. Currently, there are an unprecedented
number of security-related working groups involving NRC and Agreement
State staff members. The fact that the states are able to obtain
volunteers to work on all of these working groups and that NRC is
funding the travel involved with such efforts, is a testament to our
belief in the importance of ensuring security of radioactive material
in this country.
We appreciate the opportunity to review the report and provide
comments. Thank you for your patience.
Sincerely,
Signed by:
Cindy Cardwell, Chair:
Organization of Agreement States:
[End of section]
Appendix V: GAO Contact and Staff Acknowledgments:
GAO Contact:
Gene Aloise, (202) 512-3841 or aloisee@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, Ned Woodward, Nabajyoti
Barkakati, Kevin Bray, Ryan Coles, Nancy Crothers, Walker Fullerton,
Cindy Gilbert, Richard Hung, Carol Kolarik, Keith Rhodes, and Kevin
Tarmann made significant contributions to this report.
[End of section]
Footnotes:
[1] Sandia National Laboratories, located in Albuquerque, New Mexico,
and Livermore, California, are 2 of the more than 20 national
laboratories and technology centers overseen by DOE.
[2] A radionuclide is an unstable, radiation-emitting nuclide. A
nuclide is a particular atomic form of an element distinguished from
other nuclides by its number of neutrons and protons, as well as by the
amount of energy it contains. Every known element has multiple
(radio)nuclides. For example, cesium has many radionuclides, and each
is suited to different purposes--cesium-133 is used in atomic clocks,
and cesium-137 is used as an irradiator to sterilize blood and in other
medical radiation devices for treating cancer.
[3] The IAEA Safety Guide #RS-G-1.9, "Categorization of Radioactive
Sources," details the underlying methodology for the five-category
scheme.
[4] Direct, or nonprobabilistic, human health effects are readily
observable, may be acute, and are, accordingly, more severe than the
elevated risk of a future health effect, such as cancer.
[5] CBP is the unified border agency within DHS. CBP combines the
inspectional workforces and broad border authorities of the former U.S.
Customs Service, U.S. Immigration and Naturalization Service, Animal
and Plant Health Inspection Service, and the entire U.S. Border Patrol.
[6] GAO, Nuclear Security: Federal and State Action Needed to Improve
Security of Sealed Radioactive Sources, [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-03-804] (Washington, D.C.: Aug.
6, 2003).
[7] GAO, Combating Nuclear Smuggling: DHS Has Made Progress Deploying
Radiation Detection Equipment at U.S. Ports-of-Entry, but Concerns
Remain, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-389]
(Washington, D.C.: Mar. 22, 2006).
[8] GAO, Border Security: Investigators Successfully Transported
Radioactive Sources across Our Nation's Borders at Selected Locations,
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-545R] (Washington,
D.C.: Mar. 28, 2006).
[9] GAO, Nuclear Security: Actions Taken by NRC to Strengthen Its
Licensing Process for Sealed Radioactive Sources Are Not Effective,
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-1038T]
(Washington, D.C.: July 12, 2007).
[10] Results from a nonprobability sample cannot be used to make
inferences about a population because, in a nonprobability sample, some
elements of the population being studied have no chance or an unknown
chance of being selected as part of the sample.
[11] NRC implemented IMPEP in 1995 to evaluate NRC's regional materials
program and the agreement state radiation control programs using
evaluation criteria, known as performance indicators, to ensure
consistency in the nation's materials safety program. Reviews are
conducted jointly by the Office of Federal and State Materials and
Environmental Management Program staff, with agreement state and
regional representatives usually on the team. Approximately 10 to 12
reviews are scheduled each year. NRC regions are normally reviewed
every 2 years, and agreement states every 2 to 4 years--the timeline
may be adjusted depending on past performance.
[12] GAO investigators made a similar application for a radioactive
materials license to an agreement state but withdrew the application
when the agreement state official informed GAO investigators that it
would require a site visit to the applicant's place of business--a step
that would have revealed the application not to be authentic.
[13] See National Response Framework, "Emergency Support Function #10-
Oil and Hazardous Material Response," p. 14, and Nuclear/Radiological
Incident Annex, p. NUC-3 and table 1.
[14] The Health Physics Society is a scientific and professional
organization whose members specialize in occupational and environmental
radiation safety. The society supports its members in the practice of
their profession and also, among other things, promotes public
information preparation and dissemination, education and training
opportunities, and scientific information exchange through conferences
and meetings, [hyperlink, http://hps.org/aboutthesociety/] (accessed
April 17, 2008).
[15] NRC has gathered information from licensees of category 1 through
3 and the most dangerous category 4 sources. Under the IAEA
categorization scheme, any source containing category 3 or greater
quantities of radioactive materials could be dangerous to human health
if not handled properly.
[16] During the first year of the interim database, information on some
category 3 sources that were aggregated in quantities large enough to
be considered a category 2 quantity were also recorded. However, the
difficulty in defining what constituted collocated/aggregated or
separate sources made recording aggregated category 2 quantities
extremely difficult and such information was no longer collected after
the first year of implementation. For example, keeping a larger number
of category 3 sources divided among locked barriers of a certain
security level may allow some such material at the same facility not to
be reported as collocated and not subject to the aggregation rules that
would require it to be reported as a category 2 quantity.
[17] An NRC rule creating the NSTS and certain provisions for the
system are required by the Energy Policy Act of 2005. The final rule
(issued under NRC's authority to regulate radioactive materials for
public health and safety, an authority shared with the agreement
states) requiring that licensees report to the NSTS and requiring the
issuance of unique source serial numbers was published in the Federal
Register on November 8, 2006. NRC has since modified the rule and now
requires reporting to the NSTS by January 31, 2009.
[18] NRC opted to include these four additional radionuclides that NRC
deems of concern for RDD purposes in the NSTS at DOE request. Although
NRC and agreement state licensees do not possess large numbers of
sources containing these radionuclides, and none with category 2 or
higher quantities, DOE might.
[19] The activity data for a given source may be reported as of the
manufacture date or assay date. Because all radioactive materials decay
over time, an up-to-date estimation of the activity level will be
calculated, if needed, by the system.
[20] According to CBP officials, 91 percent of all personal vehicles
arriving in the United States are scanned by radiation portal monitors.
In addition, 100 percent of truck cargo arriving from Mexico and 91
percent arriving from Canada are scanned by portal monitors.
[21] NRC provides the National Targeting Center with up-to-date
information concerning the licensing, import, and export of all
regulated radioactive materials and sources in the United States. This
cooperation gives CBP indirect access to NRC and agreement state
licensing databases; NRC's list of licensees authorized to import or
export radioactive materials and sources; and advanced notification of
large, category 1 radioactive materials shipments.
[22] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-389] and
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-545R].
[End of section]
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