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Report to Congressional Requesters: 

United States Government Accountability Office: 
GAO: 

January 2009: 

Nuclear Detection: 

Domestic Nuclear Detection Office Should Improve Planning to Better 
Address Gaps and Vulnerabilities: 

GAO-09-257: 

GAO Highlights: 

Highlights of GAO-09-257, a report to congressional requesters. 

Why GAO Did This Study: 

In April 2005, the Domestic Nuclear Detection Office (DNDO) was 
established within the Department of Homeland Security (DHS) to enhance 
and coordinate federal, state, and local efforts to combat nuclear 
smuggling domestically and overseas. DNDO was directed to develop, in 
coordination with the departments of Defense (DOD), Energy (DOE), and 
State (State), a global strategy for nuclear detection—a system of 
radiation detection equipment and interdiction activities domestically 
and abroad. GAO was asked to examine (1) DNDO’s progress in developing 
programs to address critical gaps in preventing nuclear smuggling 
domestically, (2) DNDO’s role in supporting other agencies’ efforts to 
combat nuclear smuggling overseas, and (3) the amount budgeted by DHS, 
DOD, DOE, and State for programs that constitute the global nuclear 
detection strategy. To do so, GAO analyzed agency documents; 
interviewed agency, state, and local officials; and visited select 
pilot program locations. 

What GAO Found: 

DNDO has made some progress in strengthening radiation detection 
capabilities to address critical gaps and vulnerabilities in combating 
nuclear smuggling, which include the land border area between ports of 
entry into the United States, aviation, and small maritime vessels. 
However, DNDO is still in the early stages of program development, and 
has not clearly developed long term plans, with costs and time frames, 
for achieving its goal of closing these gaps by expanding radiological 
and nuclear detection capabilities. For example, DNDO and Customs and 
Border Protection have been collaborating on radiological and nuclear 
detection options to better secure the land borders between ports of 
entry. However, DNDO-sponsored field evaluations to test radiation 
detection equipment are still not complete and DNDO and CBP may not 
have all radiation detection equipment in place until 2012. In 
addition, DNDO is in the first year of a 3-year maritime pilot program, 
working with the Coast Guard and local law enforcement agencies in the 
Puget Sound, Washington, area to field test equipment and to develop 
radiological and nuclear screening procedures. However, DNDO has made 
little progress in (1) developing criteria for assessing the success of 
the pilot to help determine whether it should be expanded to other 
locations, and (2) resolving some of the challenges it faces in the 
pilot program, such as technological limitations of the detection 
equipment and sustaining current detection efforts. 

Although DNDO has no authority over other federal agencies’ programs to 
combat radiological and nuclear smuggling overseas, it has worked with 
DOD, DOE, and State to provide subject matter expertise and exchange 
lessons learned on radiological and nuclear detection. However, most of 
DNDO’s efforts are modest in scope, reflecting the fact that these 
agencies have well-established programs to combat nuclear smuggling. 
For example, DNDO has been working with State’s Global Initiative to 
Combat Nuclear Terrorism to develop model guidelines that other nations 
can use to establish their own nuclear detection programs. 

According to DNDO, approximately $2.8 billion was budgeted by DHS, DOD, 
DOE, and State in fiscal year 2007 for programs included in the global 
strategy for nuclear detection. Of this amount, approximately $1.1 
billion was budgeted for programs to combat nuclear smuggling overseas, 
$1.1 billion was budgeted for nuclear detection programs at the U.S. 
border and within the United States, and approximately $577 million was 
budgeted to fund cross-cutting activities, such as providing technical 
support to users of the radiation detection equipment. DNDO collected 
budget data and published them in the Joint Annual Interagency Review, 
an annual report required by Congress. DOD, DOE, and State officials 
told GAO that this information is used primarily as a status report of 
individual programs to combat nuclear smuggling. It is not used as a 
tool to help plan for or inform the future direction of the strategy or 
to help establish current or future priorities. 

What GAO Recommends: 

GAO recommends that DHS (1) develop a plan for the domestic part of the 
global strategy, and (2) in coordination with DOD, DOE, and State, use 
the Joint Annual Interagency Review to guide future strategic efforts 
to combat nuclear smuggling. GAO also has two recommendations related 
to maritime planning. DHS did not directly comment on the 
recommendations, but said they aligned with DNDO’s efforts. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/products/GAO-09-257]. For more 
information, contact David Maurer at (202) 512-3841 or maurerd@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

DNDO Is in the Early Stages of Enhancing Domestic Initiatives for 
Nuclear Detection: 

DNDO Has Limited Role in Influencing U.S. Efforts to Combat 
Radiological and Nuclear Smuggling Overseas: 

A Total of $2.8 Billion Was Budgeted in Fiscal Year 2007 for Programs 
Associated with Detecting Radiological and Nuclear Materials: 

DNDO Has Not Yet Implemented Recommendation from July 2008 Testimony: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Comments from the Department of Homeland Security: 

GAO Comments: 

Appendix II: Comments from the Department of Defense: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Table: 

Table 1: Distribution of Fiscal Year 2007 Budget for Detecting 
Radiological and Nuclear Weapons or Materials: 

Figures: 

Figure 1: Elements of the Global Nuclear Detection Strategy: 

Figure 2: Cargo Vehicle Passing through Radiological Detection 
Equipment at Dulles International Airport: 

Figure 3: A Coast Guard Officer Wearing Standard Boarding Team 
Equipment: 

Figure 4: Budgets by Program Focus and Agency: 

Abbreviations: 

ASP: advanced spectroscopic portal (monitor): 

CBP: Customs and Border Protection: 

DHS: Department of Homeland Security: 

DNDO: Domestic Nuclear Detection Office: 

DOD: Department of Defense: 

DOE: Department of Energy: 

IAEA: International Atomic Energy Agency: 

NYPD: New York Police Department: 

RIID: radioactive isotope identification device: 

SAFE Port Act: Security and Accountability for Every Port Act of 2006: 

State: Department of State: 

TSA: Transportation Security Administration: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

January 29, 2009: 

Congressional Requesters: 

Preventing terrorists from using radiological or nuclear material to 
carry out an attack in the United States is a top national priority. If 
terrorists were to carry out such an attack, the consequences could be 
devastating to national security. Since the events of September 11, 
2001, there is heightened concern that terrorists may try to smuggle 
radiological and nuclear materials or a nuclear weapon into the United 
States or obtain such materials within the United States. In 2002, 
Congress established the Department of Homeland Security (DHS) and gave 
it authority to, among other things, develop and deploy technologies to 
detect, prevent, and interdict nuclear materials or devices from being 
transported into and used within the United States. 

In April 2005, the President issued a directive establishing the 
Domestic Nuclear Detection Office (DNDO), within DHS, to enhance and 
coordinate federal, state, and local efforts to prevent radiological 
and nuclear attacks. Congress subsequently passed the Security and 
Accountability for Every Port Act of 2006 (SAFE Port Act), which 
established DNDO in statute.[Footnote 1] Among other things, DNDO is 
required to develop, in coordination with the Department of Defense 
(DOD), the Department of Energy (DOE), the Department of Justice, and 
the Department of State (State), an enhanced global nuclear detection 
architecture--essentially a strategy involving radiation detection 
equipment and interdiction activities to combat nuclear smuggling in 
foreign countries, at the U.S. border, and inside the United 
States.[Footnote 2] DNDO is responsible for coordinating the 
implementation of the domestic portion (at the U.S. border and within 
the United States) of the global strategy, including the efforts of 
federal, state, and local governments. It is also responsible for 
developing and acquiring radiation detection equipment to support the 
domestic efforts of DHS and other federal agencies. The directive and 
the SAFE Port Act reaffirmed that DOD, DOE, and State, among other 
agencies, are responsible for programs to combat radiological and 
nuclear smuggling outside the United States. 

In its initial approach, DNDO categorized existing nuclear detection 
programs into three main geographic regions--overseas, U.S. border, and 
U.S. interior--which it further divided into nine more specific 
geographic segments. In addition, agencies identified other programs 
that support more than one segment; DNDO categorizes these as cross- 
cutting. While DNDO is responsible for developing the global strategy 
for nuclear detection, each federal agency that has a role in combating 
nuclear smuggling is responsible for implementing its own programs. 
DNDO identified 73 federal programs, which are primarily funded by DOD, 
DOE, and DHS, that engage in radiological and nuclear detection 
activities. 

Since its inception about 4 years ago, DNDO has been examining nuclear 
detection strategies along potential pathways--such as air, land, or 
sea--for smuggling radiological or nuclear material and identified 
opportunities to improve the likelihood of detection and interdiction. 
Through these studies, DNDO concluded that potential smuggling pathways 
outside of traditional ports of entry--where U.S. government efforts 
have been focused--represented critical gaps in the existing nuclear 
detection strategy. Specifically, DNDO identified several gap areas, 
among others, with respect to detecting potential nuclear smuggling and 
prioritized its efforts on three primary pathways: (1) land border 
areas between ports of entry into the United States, (2) aviation, and 
(3) small maritime craft.[Footnote 3] 

These pathways are important because of their size, volume of traffic, 
and limited deployment of radiological and nuclear detection 
capabilities. Specifically, the United States has more than 6,000 miles 
of land border with many locations where people and vehicles can easily 
enter the United States. Nuclear weapons and material also can be small 
and portable enough to be carried on most aircraft. On average, nearly 
2,000 international commercial flights and over 400 international 
general aviation flights land in the United States each day.[Footnote 
4] In the maritime environment, a Coast Guard risk assessment revealed 
that small boats pose a greater threat for nuclear smuggling than 
container ships. There are at least 13 million registered domestic 
pleasure craft in the United States and 110,000 commercial fishing 
vessels. These small boats have traditionally been used to smuggle 
drugs and people, but, as occurred in the attack on the U.S.S. Cole, 
can be used to deliver a weapon. 

GAO was asked to examine (1) DNDO's progress in developing programs to 
address critical gaps in preventing nuclear smuggling domestically, (2) 
DNDO's role in supporting other agencies' efforts to combat nuclear 
smuggling overseas, and (3) the amount budgeted by DHS, DOD, DOE, and 
State for programs that constitute the global nuclear detection 
strategy and the extent to which the budget information is used for 
planning purposes. In addition, we are providing an update on DNDO's 
efforts to implement the recommendation made in our July 2008 
testimony, which presented preliminary observations on the global 
strategy for nuclear detection.[Footnote 5] 

To evaluate the status of DNDO's progress in developing programs to 
address critical gaps and its role in supporting other agencies' 
efforts to combat nuclear smuggling overseas, we reviewed and analyzed 
documents DNDO used to help create the baseline, or initial strategy, 
as well as DNDO-sponsored studies on gaps identified in the strategy. 
We also reviewed our previous reports on nuclear and radiological 
detection.[Footnote 6] We interviewed officials from DNDO about steps 
taken to develop and improve upon the existing strategy for nuclear 
detection and interviewed agency officials from DOD, DOE, and State who 
manage programs that are part of the global strategy to obtain their 
perspectives on how these programs fit into the global strategy and to 
learn about any new initiatives to address gaps and vulnerabilities. In 
addition, we interviewed officials from a variety of federal, state, 
and local agencies--including Customs and Border Protection (CBP), the 
Coast Guard, the New York City Police Department, and local law 
enforcement participating in the Puget Sound maritime pilot--to obtain 
their views on DNDO's initiatives to combat nuclear smuggling. We chose 
the New York City Police Department because of its efforts to enhance 
nuclear detection capabilities through the Securing the Cities 
initiative and Puget Sound because that was the first location chosen 
for the maritime radiological and nuclear detection pilot program. We 
also interviewed subject matter experts from the academic and nonprofit 
sectors, as well as representatives from the International Atomic 
Energy Agency (IAEA), to gain their perspective on efforts to develop 
and implement the strategy. To examine the amount budgeted for the 
programs that constitute the global strategy for nuclear detection, we 
analyzed budget data submitted by DHS, DOD, DOE, and State to DNDO as 
part of DNDO's Joint Annual Interagency Review and spoke with officials 
from these agencies to discern how this information was used. We 
assessed the reliability of these data and determined it was sufficient 
for the purposes of this analysis. We conducted this performance audit 
from November 2007 through January 2009 in accordance with generally 
accepted government auditing standards. Those standards require that we 
plan and perform the audit to obtain sufficient, appropriate evidence 
to provide a reasonable basis for our findings and conclusions based on 
our audit objectives. We believe that the evidence obtained provides a 
reasonable basis for our findings and conclusions based on our audit 
objectives. 

Results in Brief: 

DNDO has made some progress in strengthening radiation detection 
capabilities to address critical gaps and vulnerabilities in combating 
nuclear smuggling, which include the land border areas between ports of 
entry into the United States, aviation, and small maritime vessels. 
However, DNDO is still in the early stages of program development, and 
has not clearly developed long-term plans, with costs and time frames, 
for achieving its goal of closing these gaps by expanding radiological 
and nuclear detection capabilities. Specifically, we found: 

* Land border areas between ports of entry. DNDO and CBP, both agencies 
within DHS, have been collaborating on radiological and nuclear 
detection options to better secure the border areas between ports of 
entry. CBP is responsible for developing and implementing screening 
procedures; DNDO provides the equipment for these operations. DNDO and 
CBP plan to have radiation detection equipment in place at all 20 CBP 
sectors by fiscal year 2012. However, DNDO-sponsored laboratory and 
field evaluations to identify and test radiation detection equipment 
are still not complete, DNDO has fallen behind on its original test 
schedule, critical testing has been postponed owing to problems with 
the detection technology being tested, and DNDO has not estimated the 
total cost of this effort. In addition, DNDO has not provided CBP with 
the equipment needed in a timely manner to improve radiation detection 
capabilities either at ports of entry or land border areas between 
ports of entry. 

* Aviation. DNDO is still in the early stages of developing programs to 
achieve its goal of screening all incoming international planes, cargo, 
and passengers for nuclear weapons and material. Although some 
initiatives in the aviation arena are under way, it is unclear how long 
this effort will take or how much it will cost. Since December 2007, 
CBP has been screening 100 percent of passengers and baggage on 
arriving international general aviation flights (approximately 400 
flights per day), as well as the aircraft, for radiological or nuclear 
materials. However, CBP efforts to screen international cargo have not 
proceeded as smoothly. Jurisdictional and operational issues between 
the Transportation Security Administration (TSA), CBP, and the local 
airport authority delayed efforts to screen international cargo at the 
initial airport selected for screening until September 2008. Planned 
expansion of this screening to a total of 30 U.S. airports, which 
represent 99 percent of incoming international cargo, is not projected 
to be fully achieved until 2014. 

* Small maritime vessels. DNDO has developed and tested equipment for 
detecting nuclear material on small maritime vessels. However, efforts 
to use this equipment in a port area have been limited to pilot 
programs for demonstrating the feasibility of screening small vessels. 
Whereas initiatives to combat smuggling at land border areas between 
formal ports of entry and through aviation routes are being integrated 
into already existing CBP screening operations, initiatives in the 
maritime environment require developing and testing new equipment and 
new procedures with the Coast Guard and local law enforcement agencies. 
DNDO is currently in the first year of a 3-year pilot program in Puget 
Sound and San Diego to design, field test, and evaluate equipment and 
is working with CBP and Coast Guard as they develop procedures for 
screening. This review is scheduled to end in 2010, when DNDO will 
decide whether screening of small vessels for radiological and nuclear 
material is feasible. However, DNDO has not established criteria for 
assessing the success of this pilot effort to help determine whether it 
should be expanded to other locations. In addition, should DNDO decide 
to continue this program, it does not currently have a plan detailing 
which locations it would target for maritime radiological and nuclear 
detection programs, nor has it estimated the total cost of this 
initiative. Although DNDO is providing state, tribal, and local 
agencies with initial equipment, support, and training during the 
pilot, DNDO expects them to seek funding from federal grant programs to 
sustain these initiatives. For many state and local agency officials we 
spoke with, the uncertainty of federal resources jeopardizes their 
ability to continue radiological and nuclear detection activities. 

Although DNDO has no authority over other federal agencies' programs to 
combat radiological and nuclear smuggling, it has worked with DOD, DOE, 
and State to support these agencies' efforts to combat nuclear 
smuggling overseas by, for example, providing subject matter expertise 
and exchanging lessons learned on radiological and nuclear detection. 
However, most of DNDO's efforts are modest in scope, reflecting the 
fact that DOD, DOE, and State have well-established programs to combat 
nuclear smuggling. Some of the areas in which DNDO has been able to 
contribute to other agencies' overseas programs include (1) working 
with State's Global Initiative to Combat Nuclear Terrorism to develop 
model guidelines that other nations can use to establish their own 
nuclear detection programs and sponsoring a related workshop, and (2) 
exchanging lessons learned with DOE from its efforts to develop 
operations to screen for radiological and nuclear materials in the 
aviation arena. In addition, DNDO has been collecting information and 
developing an inventory of radiation detection equipment deployed 
overseas. DNDO subsequently has shared this information with relevant 
agencies, and agencies have used this information to guide equipment 
placement decisions. 

According to DNDO, approximately $2.8 billion was budgeted by DHS, DOD, 
DOE, and State in fiscal year 2007 for programs included in the global 
strategy for nuclear detection; however, agencies are not analyzing 
this budget information to ensure that resources are clearly aligned 
with overarching priorities. Of this $2.8 billion, approximately $1.1 
billion was budgeted for programs designed to combat nuclear smuggling 
and secure materials overseas. Approximately $220 million was budgeted 
for programs to support the detection of radiological and nuclear 
material at the U.S. border; an additional $918 million funded security 
and detection activities within the United States. Finally, 
approximately $577 million was budgeted for a number of cross-cutting 
activities that support many different layers of the strategy, such as 
those focused on research and development or technical support to users 
of the detection equipment. When analyzed by agency, the majority of 
the $2.8 billion--$1.8 billion, or 62 percent--was budgeted for DOE 
programs, primarily those related to securing nuclear weapons and 
weapons material at its source and deploying radiological and nuclear 
detection systems at international border crossings, airports, and 
seaports. DNDO collected these program-level budget data in response to 
a statutory requirement that select agencies, including DHS, DOD, DOE, 
and State, annually assess their capacity to implement their portion of 
the global nuclear detection strategy. DNDO's June 2008 report 
discusses, among other things, programs and budgets in support of the 
global nuclear detection effort. The report provides an overview of the 
global nuclear detection strategy and discusses programs and budgets 
for combating nuclear smuggling domestically and overseas. Agency 
officials from DOD, DOE, and State said that this information is used 
primarily to provide agencies and Congress with a picture of the 
already established roles and responsibilities within the layered 
structure of the strategy. The information is not being used, however, 
as a tool to look more broadly across the global strategy, to help 
assess the overall strategic direction of global detection efforts, or 
help establish current or future global priorities, according to these 
officials. 

In July 2008, we testified that DNDO had not developed an overarching 
strategic plan to guide its development of a more comprehensive global 
strategy for nuclear detection.[Footnote 7] We recommended that DHS, in 
coordination with DOD, DOE, and State, develop a strategic plan to 
guide the development of a more comprehensive global nuclear strategy 
including (1) clearly defining objectives, (2) identifying the roles 
and responsibilities for meeting each objective, (3) identifying 
funding necessary to achieve those objectives, and (4) employing 
monitoring mechanisms to determine programmatic progress and identify 
needed improvements. DNDO agreed with the need for an overarching 
strategic plan and believes that many elements of such a plan exist in 
DHS and other agency documents, but that there are gaps and 
vulnerabilities for which solutions are still under development. As of 
December 2008, DNDO had not yet established detailed plans to address 
those gaps and vulnerabilities, nor had it integrated all the plan 
elements into an overarching strategic plan as recommended. 

To complement our July 2008 recommendation, we are recommending that 
the Secretary of Homeland Security develop a strategic plan for the 
domestic part of the global nuclear detection strategy to help ensure 
the future success of initiatives aimed at closing gaps and 
vulnerabilities. This plan should focus on, among other things, 
establishing time frames and costs for the three areas of recent focus-
-land border areas between ports of entry, aviation, and small maritime 
vessels. In addition, to enhance DNDO's future efforts to combat 
nuclear smuggling via small maritime vessels, we are recommending that 
the Secretary of Homeland Security develop criteria to assess the 
effectiveness, cost, and feasibility of its maritime radiological and 
nuclear pilot program. Furthermore, should the Secretary decide to 
expand the program beyond the pilot, we recommend that DHS undertake 
additional planning to identify next steps, including how and where a 
broader strategy would be implemented, what technology would be needed, 
what organizations should be involved, and how such efforts would be 
sustained. 

We provided a draft of this report to DHS, DOD, DOE, and State for 
comment. DHS and DOD provided written comments, which are presented in 
appendixes I and II, respectively. DOE and State provided technical 
comments, which we incorporated as appropriate. DOD concurred with the 
recommendation that the Secretary of Homeland Security, in coordination 
with the Secretary of Defense, Secretary of Energy, and Secretary of 
State, use the Joint Annual Interagency Review to guide future 
strategic efforts to combat nuclear smuggling. DOD stated that greater 
use could be made of the review associated with the development of this 
annual report to guide U.S. efforts to combat nuclear smuggling. DHS 
did not directly comment on our recommendations but noted that the 
recommendations aligned with DNDO's past, present, and future actions. 
DHS pointed out what, in its view, were a number of shortcomings in the 
draft report. Specifically, the department believes that we did not 
give enough credit to DNDO's strategic planning efforts. Furthermore, 
the department believes that we did not clearly and adequately explain 
the background and context of DNDO's efforts to develop a global 
strategy, what has been accomplished so far, what remains to be done, 
and what challenges it faces. Finally, DHS asserted that the draft 
contained a number of inaccuracies and omissions that make it less 
reliable and useful than it could be. DHS also provided a number of 
more detailed comments on specific issues presented in the draft 
report. We have addressed those comments in our detailed responses in 
appendix I and incorporated changes, where appropriate. 

We believe that our report fairly and accurately presents DNDO efforts 
to develop and implement a global strategy to enhance nuclear detection 
efforts. We have reported DNDO's key initiatives to improve radiation 
detection capabilities in the areas of land borders between the ports 
of entry, aviation, and maritime. For example, the report acknowledges 
how DNDO has helped highlight the need to address these critical gaps 
and has also made some progress in developing and supporting 
initiatives to close these gaps. In our view, DNDO needs better 
planning to improve the chances that the strategy will be successfully 
implemented and sustained in the future. In its comments, DNDO agreed 
that the overarching strategic plan we had previously recommended in 
our July 2008 testimony based on our preliminary findings on this very 
issue was valuable and that work on such a plan has begun. 

Background: 

According to IAEA, between 1993 and 2006, there were 1,080 confirmed 
incidents of illicit trafficking and unauthorized activities involving 
nuclear and radiological materials worldwide. Eighteen of these cases 
involved weapons-usable material--plutonium and highly enriched 
uranium--that could be used to produce a nuclear weapon. IAEA also 
reported that 124 cases involved materials that could be used to 
produce a device that uses conventional explosives with radioactive 
material (known as a "dirty bomb"). Past confirmed incidents of illicit 
trafficking in highly enriched uranium and plutonium involved seizures 
of kilogram quantities of weapons-usable nuclear material but most have 
involved very small quantities. In some of these cases, it is possible 
that the seized material was a sample of larger quantities available 
for illegal purchase. IAEA concluded that these materials pose a 
continuous potential security threat to the international community, 
including the United States. 

Nuclear material could be smuggled into the United States in a variety 
of ways: hidden in a car, train or ship; sent through the mail; carried 
in a private aircraft or small boat; carried in personal luggage 
through an airport; or walked across the border. In response to these 
threats, U.S. agencies--including DHS, DOD, DOE, and State--fund, 
manage, and implement programs to combat nuclear smuggling in foreign 
countries and the United States. DOD, DOE, and State are responsible 
specifically for the overseas programs. Many of these programs started 
operations prior to DNDO's creation and collectively cover all of the 
geographic regions of the global strategy. (See figure 1.) 

Figure 1: Elements of the Global Nuclear Detection Strategy: 

[Refer to PDF for image: illustrated map] 

This figure is a world map depicting the following elements of the 
global nuclear detection strategy: 

Overseas: 

1. Foreign origin: Locations in foreign countries where nuclear weapons 
or material, or radiological material are stored, used, or created. 

2. Foreign transit: Any transport of radiological or nuclear material 
within or between foreign countries from its site of origin to its 
point of departure to the U.S. 

3. Foreign departure: Points of departure to the U.S. including 
seaports and airports. 

U.S. Border: 

4. Transit to United States: Actual ship passage or airplane flight 
from the point of departure to the port of entry. 

5. U.S. Border: Radiation detection at all land borders with Canada and 
Mexico, the coastal and inland waterway borders, and international 
airports. 

U.S. Interior: 

6. U.S. origin: Places within the U.S. where nuclear weapons, nuclear 
material or radiological material are stored, used, or processed. 

7. U.S. Regional: Capabilities that detect or identify radiation 
sources between the entry into the United States (or the U.S. point of 
origin) and the ultimate target. 

8. Target Vicinity: Detectors located “near” targets but with 
sufficient standoff to protect the targets, or at least mitigate 
damage, if a device is detonated. 

9. Target: Detect devices delivered to the target but not yet 
detonated. 

9Sources: GAO analysis of DNDO data and Map Resources (map). 

[End of figure] 

For example, DOE's Materials Protection, Control, and Accounting 
program, initiated in 1995, provides support to the Russian Federation 
and other former Soviet Union countries to secure nuclear weapons and 
weapons material that may be at risk of theft or diversion.[Footnote 8] 
In addition, during the 1990s, the United States began deploying 
radiation detection equipment at borders in countries of the former 
Soviet Union. DOD's Cooperative Threat Reduction program was 
established in the early 1990s to help address proliferation concerns 
in the former Soviet Union, including helping secure sites where 
nuclear weapons are located.[Footnote 9] Two other DOD programs have 
provided radiation portal monitors, hand-held equipment, and radiation 
detection training to countries in the former Soviet Union and in 
Eastern Europe. Similarly, DOE's Second Line of Defense program, 
initiated in 1998, supplies radiation detection equipment, training, 
and communication systems to Russia and other countries.[Footnote 10] 
DOE's Megaports Initiative, also part of the Second Line of Defense 
program, began in 2003 and is focused on providing radiation detection 
systems at major international seaports. Once the equipment is 
installed, it is then operated by foreign government officials and port 
personnel working at these ports.[Footnote 11] State also has programs 
that provide radiation detection equipment and training to numerous 
countries. 

Domestically, DHS, in conjunction with other federal, state, and local 
agencies, is responsible for combating nuclear smuggling in the United 
States and has provided radiation detection equipment, including portal 
monitors, personal radiation detectors (known as pagers), and 
radioactive isotope identifiers at U.S. ports of entry, as well as in 
other settings. For example, DHS has equipped Coast Guard boarding and 
inspection teams with portable detection systems and has provided 
equipment, training, and assistance in other maritime, air, and land 
venues. In addition, DOE has programs to secure nuclear and radioactive 
sources domestically. For example, the U.S. Radiological Threat 
Reduction program recovers and manages excess and unwanted radioactive 
sources that belong to U.S. licensees. In addition, the Nuclear 
Regulatory Commission, as well as 35 states that have signed an 
agreement with the Nuclear Regulatory Commission, are responsible for 
regulating the security of radioactive and nuclear materials within the 
United States through its Radiological Materials and Reactor Security 
Programs. 

Several types of radiation detection equipment are used by CBP, the 
Coast Guard, and other agencies involved in radiological and nuclear 
detection activities: radiation portal monitors, radioactive isotope 
identification devices (RIID), and personal radiation detectors, among 
others. Portal monitors are stationary or mobile pieces of equipment 
that can detect radioactive materials carried by vehicles or 
transported in cargo containers. RIIDs are a type of handheld radiation 
detection equipment that can detect radiation as well as identify the 
specific isotope of the radioactive source. Personal radiation 
detectors are worn by CBP officials, Coast Guard boarding teams, and 
other law enforcement agents. Unlike portal monitors and RIIDs, 
personal radiation pagers function primarily as personal safety devices 
to alert the individual wearer when he or she is exposed to an 
increased level of radiation. Under certain circumstances these devices 
also could be used to detect smuggled nuclear material. However, they 
can only indicate variations in the general level of radiation and 
their sensitivity is limited because of the small size of the detector. 
Therefore, they should not be relied upon for that purpose. 

All radiation detection devices have limitations in their ability to 
detect and identify nuclear material. Detecting attempted nuclear 
smuggling is difficult because many sources of radiation are legal and 
not harmful when used as intended. These materials can trigger alarms-
-known as nuisance or innocent alarms--that may be difficult to 
distinguish in some cases from alarms that could sound in the event of 
a true case of nuclear smuggling without a thorough secondary 
inspection. Nuisance or innocent alarms can be caused by patients who 
have recently had cancer treatments, a wide range of cargo with 
naturally occurring radiation (e.g., fertilizer, ceramics, and food 
products), and legitimate shipments of radiological sources for use in 
medicine and industry. Additionally, detecting actual cases of illicit 
trafficking in weapons-useable nuclear material is complicated: one of 
the materials of greatest concern in terms of proliferation--highly 
enriched uranium--is among the most difficult materials to detect 
because of its relatively low level of radioactivity. 

DNDO is currently testing the next generation of radiation portal 
monitors--the advanced spectroscopic portal monitor, or ASP. We have 
repeatedly raised concerns about DNDO's efforts to develop and test 
ASPs. Specifically, we found that testing of ASPs at DOE's Nevada Test 
Site did not represent an objective or rigorous assessment because DNDO 
used biased test methods that enhanced the apparent performance of the 
ASPs and did not test the limitations of the ASPs' detection 
capabilities.[Footnote 12] In 2008, we also found that DNDO's cost 
estimate to equip U.S. ports of entry with radiation detection 
equipment is unreliable because it omits major project costs and relies 
on a flawed methodology. Furthermore, the agency is no longer following 
the original project execution plan, the scope of the agency's current 
ASP deployment strategy has changed, and DNDO now plans a much more 
limited deployment of the ASP than initially proposed.[Footnote 13] The 
current ASP testing is expected to continue into 2009. 

DNDO Is in the Early Stages of Enhancing Domestic Initiatives for 
Nuclear Detection: 

DNDO's ultimate goal is to expand radiological and nuclear detection 
capabilities to areas identified as vulnerable to nuclear smuggling. To 
that end, in 2005, DNDO identified critical gaps in domestic efforts to 
prevent and detect radiological and nuclear smuggling, including, but 
not limited to: (1) land border areas between ports of entry into the 
United States, (2) aviation, and (3) small maritime craft. However, 
DNDO is still in the early stages of developing initiatives to address 
these vulnerabilities, and it has not clearly articulated a long-term 
plan for how to achieve its goal of closing these gaps by expanding 
radiological and nuclear detection capabilities in the time frames 
identified. 

Land border areas between ports of entry. The United States has more 
than 6,000 miles of land border susceptible to illegal crossings by 
people and vehicles. DNDO began addressing this gap in 2005 and 
currently is jointly working with CBP to equip Border Patrol agents-- 
who are responsible for patrolling the U.S. borders with Canada and 
Mexico--with portable radiological and nuclear detection equipment by 
2012. Portability is critical to strengthening radiation detection 
efforts because it expands the opportunity to detect a potential 
radiological threat should a Border Patrol agent encounter one. To 
date, as part of a phased approach, DNDO and CBP have tested and 
evaluated radiation detection equipment and CBP developed operating 
procedures for using the equipment and resolving radiation alarms along 
the southern U.S. border. However, similar tests along the northern 
U.S. border have been postponed.[Footnote 14] Specifically, DNDO and 
CBP originally scheduled equipment testing along the southern border 
for January 2008 and along the northern border for March 2008. However, 
they did not actually begin testing along the southern border until May 
2008. According to a CBP official, DNDO explained that this schedule 
slip was caused by a delay in selecting the equipment for the test. 
DNDO told us that it chose to conduct an additional review of 
commercially available detection equipment before field testing, which 
caused these tests to be delayed. As a result of preliminary findings 
from the field tests, DNDO and CBP decided in November 2008 to 
indefinitely postpone the previously scheduled tests along the northern 
border. According to these agencies, the preliminary test results 
indicated that further technological improvements will be necessary 
before the portable radiation detection equipment can be distributed 
more widely for use in this environment. Full distribution of equipment 
along the land border areas between ports of entry is contingent on 
completing these field evaluations and entails providing detection 
equipment and operating procedures to all 20 Border Patrol sectors 
across the United States. Assuming no further schedule and 
technological delays, the radiation detection equipment to help secure 
the U.S. land border areas between ports of entry may not be fully in 
place until fiscal year 2012. According to DNDO, the agency requested a 
total of $33.6 million in fiscal years 2008 and 2009 for such 
initiatives, but it has not estimated the total cost for this effort 
beyond those years. 

One of DNDO's roles in supporting the effort to close gaps in the land 
border area between ports of entry is to procure and supply detection 
equipment to CBP. However, according to CBP officials, in fiscal year 
2008, DNDO did not procure needed radiation detection equipment in a 
timely manner. Specifically, CBP's Office of Field Operations-- 
responsible for official ports of entry--and its Office of Border 
Patrol requested approximately 240 additional RIIDs. However, according 
to CBP officials, DNDO did not fill its procurement needs. As of 
November 2008, only 64 of the 240 devices requested had been delivered 
to CBP. This situation is particularly problematic for the Border 
Patrol because its agents do not have enough RIIDs to meet their 
current patrol needs, according to a Border Patrol official. 

Aviation. Because nuclear weapons and material can be small and 
portable enough to be carried on most aircraft, CBP, with the support 
of DNDO, has been working on initiatives to screen all incoming 
international planes, cargo, and passengers. Although progress has been 
made on screening international general aviation, many of the other 
initiatives are either in their initial phases or still on the drawing 
board and it is unclear how long it will take or how much it will cost 
to complete these initiatives. In fiscal years 2008 and 2009, DNDO has 
requested a total of $35 million for aviation-related activities; 
[Footnote 15] however, it has not estimated the costs of these 
initiatives beyond the near term. 

Since December 2007, CBP has been screening 100 percent of arriving 
international general aviation aircraft (approximately 400 flights per 
day) for radiological and nuclear material. According to DNDO 
officials, such efforts are being included in the strategy for the 
first time. To assist with the international general aviation 
initiative, DNDO managed the testing and evaluation of radiation 
detection devices in close coordination with CBP officials to ensure 
that the technology and operating procedures would be consistent with 
CBP's responsibilities to screen all aircraft arriving from outside the 
United States.[Footnote 16] Specifically, in 2008, DNDO, in partnership 
with CBP, tested portable radiation detection equipment for use in 
scanning small, medium, and large international general aviation 
aircraft and assessed whether CBP screening procedures needed to be 
modified. 

While CBP has made progress in ensuring that appropriate operating 
procedures for using the equipment and resolving radiation alarms are 
established and all international general aviation is screened, its 
other aviation initiatives have not proceeded as smoothly or have not 
yet begun. CBP is working with DNDO on an initiative to screen 
international air cargo for radiological and nuclear material and has 
chosen Dulles International Airport as the first location for this 
screening. According to DNDO, this airport was chosen first because it 
has one gate through which all cargo travels. However, because both 
international and domestic cargo pass through this gate, the start of 
operations was delayed until September 2008 due to jurisdictional 
issues between CBP and TSA--CBP is responsible for screening 
international cargo for radiological and nuclear material and TSA for 
scanning domestic cargo for explosives. The two agencies had to reach 
an agreement allowing CBP to screen all cargo for radiological and 
nuclear material, regardless of origin. (Figure 2 shows cargo moving 
through a stationary radiation portal monitor at Dulles International 
Airport.) 

Figure 2: Cargo Vehicle Passing through Radiological Detection 
Equipment at Dulles International Airport: 

[Refer to PDF for image: photograph] 

Source: GAO. 

[End of figure] 

In October 2008, we visited Dulles to observe this operation, including 
a demonstration of radiation detection capabilities. CBP sent a vehicle 
containing a small sample of Cesium-137--a radiological material that 
is considered a highly attractive source for the purpose of a 
radiological dispersal device, or dirty bomb--through the detection 
equipment. Cesium-137, which is generally in the form of a powder 
similar to talc, is highly dispersible. CBP uses this sample to 
routinely test equipment. However, the detection equipment failed to 
sound an alarm until the material had passed through it for a third 
time. CBP officials told us that this source material triggered an 
alarm during a test earlier that week, and attributed the problems with 
this demonstration to either the shielding of the source material by 
the vehicle or to a weak signal given off by the material because it 
may be nearing the end of its usable life. 

CBP plans to have cargo screening at the 30 U.S. airports that account 
for 99 percent of incoming international cargo by 2014. However, 
because cargo processing at Dulles is simpler than at other airports, 
due to the configuration of its cargo area, CBP officials acknowledged 
that their plan is very ambitious. According to CBP officials, 
expanding the cargo screening initiative to larger, more complicated 
airports will require CBP to devise different operational procedures 
and possibly develop new detection technology. DNDO and CBP also plan 
to cooperate with other federal agencies on an initiative to screen 
passengers and baggage from international commercial flights. However, 
according to DNDO, it is still working on the basic approach for this 
initiative, such as where to locate passenger and baggage scanning 
equipment in an airport. To date, DNDO and CBP have initiated a pilot 
program for screening international passengers and their baggage at 
airports. In fiscal year 2008, they completed site surveys at five 
airports in order to develop requirements for testing planned for 
fiscal year 2009. 

Current aviation initiatives focus on radiation detection both prior to 
departure from a foreign location and after the aircraft lands in the 
United States. Ultimately, DNDO and CBP would like the detection of 
radiological and nuclear materials to occur as far outside of U.S. 
borders as possible--at the point of departure instead of the point of 
entry. For example, rather than screening international general 
aviation once the plane arrives in the United States, it would be 
preferrable to screen the plane at the country from which it departs. 
However, such a strategy would rely on negotiating agreements with 
foreign governments, which could prove challenging given concerns about 
sovereignty and rights of access. Furthermore, DNDO officials were 
uncertain when and if agreements could be reached with enough foreign 
governments to establish a more effective aviation strategy. As of 
December 2008, DHS has concluded agreements with Ireland and Aruba to 
include radiological and nuclear screening of international general 
aviation aircraft in these countries. 

Small maritime vessels. A Coast Guard analysis revealed that small 
boats pose a greater threat for nuclear smuggling than transporting 
illicit material in shipping containers, according to a senior Coast 
Guard official.[Footnote 17] These small boats, which include maritime 
craft less than 300 gross tons, number in the millions. DNDO efforts 
related to radiological and nuclear detection on small maritime vessels 
are part of a larger DHS effort--the Small Vessel Security Strategy. 
This strategy recognizes a number of risks that small vessels pose, 
including serving as a vehicle to smuggle weapons or terrorists into 
the United States, and using the boat itself as an improvised explosive 
device. DHS is working to develop a Small Vessel Security Strategy 
implementation plan, which will, among other things, identify needed 
research, development, and testing, and recommend actions for future 
efforts and put the strategy into action. To address one of the 
vulnerabilities, DNDO has been working since 2005 with multiple federal 
agencies, including the Coast Guard and CBP, as well as state and local 
agencies, to develop and expand capabilities to detect radiological and 
nuclear materials that could be smuggled on small maritime craft. Coast 
Guard and CBP are responsible for developing the screening procedures 
and making decisions about what vessels are to be screened; DNDO 
provides the radiological and nuclear detection equipment. Coast Guard 
and DNDO have entered into a Joint Acquisition Strategy to update the 
current Coast Guard detection technology inventory, as well as to 
acquire new equipment if necessary. 

There are a number of challenges associated with radiological detection 
capabilities in the maritime environment that have limited DNDO's 
ability to roll this initiative out widely. Specifically, these 
agencies have a pilot project underway in Puget Sound, Washington, to 
field-test equipment and develop standard operating procedures for 
detecting and interdicting radiological and nuclear materials on small 
vessels. DNDO chose Puget Sound because of its proximity to Vancouver, 
Canada, the host of the 2010 Winter Olympics; its military and economic 
significance; and the large number of commercial and recreational 
vessels. DNDO is also expanding this pilot to San Diego, California, 
where it has conducted an initial assessment of the area and briefed 
officials about the program. DNDO selected San Diego as a pilot 
location because of its proximity to Mexico, geographic configuration, 
and many military facilities. DNDO is currently in the first year of a 
3-year pilot program; the Puget Sound and San Diego operations are 
scheduled to be completed in December 2010. According to DNDO's data 
for fiscal years 2008 and 2009, the agency requested $14.7 million for 
the pilot project and a total of $54.2 million for these and other 
maritime initiatives. 

One significant challenge in developing maritime radiological and 
nuclear detection efforts is sustaining them beyond the original pilot 
projects; DNDO has not yet developed plans for doing so. In addition to 
the Coast Guard and CBP, state and local governments play a key role in 
maritime law enforcement activities. For example, in Puget Sound, the 
majority of the law enforcement personnel and equipment available for 
radiological and nuclear detection belong to the 15 state, tribal, and 
local agencies participating in the pilot.[Footnote 18] However, these 
agencies generally have limited resources, making it difficult to 
expand their mission to include radiological and nuclear detection. 
Furthermore, these agencies have competing demands and could choose to 
fund other priorities. Although DNDO is providing these agencies with 
the initial equipment, support, training, and maintenance during the 
Puget Sound and San Diego pilots, it is expecting them to seek funding 
from federal grant programs to sustain these initiatives. For many 
state and local agency officials we spoke with, the uncertainty of 
federal resources jeopardizes their ability to continue radiological 
and nuclear detection activities. According to one local sheriff from 
Washington state, if funding to maintain and support radiation 
detection equipment provided during the pilot disappears, his 
department will not continue radiological and nuclear detection 
activities. 

Other state and local agencies participating in the Puget Sound pilot 
also emphasized the difficulty in keeping personnel trained on 
detection equipment without additional federal support beyond the 
current pilot project. Because maritime law enforcement personnel may 
not frequently need to use the equipment, future training is necessary 
to ensure that that they maintain their skills. However, without the 
additional resources currently provided by DNDO, state and local 
agencies would have difficulty covering the costs associated with 
ongoing training, including overtime salaries for personnel who have to 
take on the regular duties of those being trained. 

Given these state and local concerns, DNDO's strategy for sustaining 
such programs appears problematic. According to DNDO officials, 
sustaining the existing pilot programs will be the responsibility of 
the local jurisdictions through a well-established federal grants 
process. Specifically, DNDO anticipates that funding for these programs 
will come from Homeland Security grants, Urban Areas Security 
Initiative grants, and the DHS Port Security Grant Program. However, 
DNDO currently does not have a plan detailing which locations it would 
target next for the maritime program, nor has it estimated the total 
cost of this initiative. 

According to DNDO officials, the office has focused first on just two 
locations in order to determine whether maritime screening of small 
vessels for radiological and nuclear material is feasible and to gather 
lessons learned that can be used to minimize challenges and develop 
operating procedures for using the radiation detection equipment and 
resolving radiation alarms in other areas. However, DNDO has not 
established criteria for assessing the success of this pilot effort to 
help determine whether it should be expanded to other locations. Should 
its concept for detecting and interdicting radiological and nuclear 
material smuggled on small maritime vessels prove feasible, DNDO plans 
to develop guidance so that state and local law enforcement agencies 
can implement their own maritime radiological and nuclear detection 
programs. 

In addition, unlike radiation detection technology for land or 
aviation, technology in the maritime environment is relatively 
undeveloped and poses unique challenges. For example, the level of 
background radiation in water differs from the level of background 
radiation on land, which affects the capability of equipment to detect 
and identify certain types of radioactive material. Furthermore, the 
equipment needs to be water resistant and designed so that it can be 
used by agents who need their hands free to board and climb around 
ships. To date, DNDO has, among other things, tested boat-mounted 
radiation detectors, detection equipment that can be carried in a 
backpack, and handheld radiological detection and identification 
devices that can withstand exposure to water. Nevertheless, the 
effectiveness of radiation detection equipment in the maritime 
environment remains limited. For example: 

* The boat-mounted radiation equipment is unable to indicate the 
direction of the radioactive material causing the alarm, making it 
difficult to identify the potential threat in an open sea with many 
small vessels, according to a local law enforcement officer we spoke 
with. CBP Air and Marine officers also expressed uncertainty about how 
boat-mounted detection equipment, which has been tested only in a 
fairly controlled lake environment, will work in a more turbulent open 
sea environment, where it is more difficult to detect and determine 
radioactive material. DNDO officials told us that a fiscal year 2009 
initiative will assess boat-mounted detection systems in real-world 
environments. 

* The backpack radiation equipment works best when physically worn by 
someone, according to a DNDO official. However, Coast Guard officers 
already have a difficult time maneuvering through the small passageways 
on boats with the current equipment they must wear. (Figure 3 shows a 
Coast Guard officer wearing standard boarding team equipment, without a 
backpack.) The backpacks have the potential to further decrease 
officers' maneuverability and their ability to inspect boats. 

* If a hand-held radiological detection and identification device is 
accidentally dropped overboard, it does not float and can withstand 
being submerged under only 30 feet of water. These handheld devices 
cost $15,000 per unit, making them expensive to replace. 

Figure 3: A Coast Guard Officer Wearing Standard Boarding Team 
Equipment: 

[Refer to PDF for image: photographs, front and side views] 

Source: Coast Guard. 

[End of figure] 

DNDO has also delayed in rolling out radiation detection equipment to 
the agencies engaged in its maritime initiatives. Although federal, 
state, and local agencies in the Puget Sound pilot determined their 
equipment needs in April 2008 and submitted this request to DNDO, they 
have received little equipment. According to a DNDO official, DNDO was 
slow to process the order and once it was placed, the manufacturer was 
unable to fill the order in a timely manner and did not immediately 
notify DNDO of this delay. According to DNDO, once it was notified of 
the delay from the vender, it borrowed units from the Coast Guard so 
that the pilot could proceed. Of the 362 personal radiation detectors 
ordered, 95 had been delivered as of October 2008. However, the order 
may not be completely filled until early 2009. 

DNDO, in coordination with the Coast Guard, the New York City Police 
Department (NYPD), and other state and local agencies, is also engaged 
in maritime nuclear detection activities in the New York City area as 
part of the Securing the Cities initiative. This initiative is intended 
to enhance protection and response capabilities in and around high-risk 
urban areas by designing a system to detect and interdict illicit 
radioactive materials that may be used as a weapon. As with the Puget 
Sound pilot, the agencies involved in the initiative's maritime 
activities do not presently have enough equipment to meet their needs, 
according to officials participating in the Securing the Cities 
initiative. For example, the Coast Guard has one boat, with radiation 
detection equipment provided by DOE, and the NYPD has two boats with 
radiation detection equipment. However, NYPD officials told us that the 
NYPD has another 28 boats that need to be equipped with radiation 
detection technology and these equipment purchases depend on the 
availability of future federal grant funding. 

DNDO Has Limited Role in Influencing U.S. Efforts to Combat 
Radiological and Nuclear Smuggling Overseas: 

Although DNDO has no authority over other federal agencies' programs to 
combat radiological and nuclear smuggling overseas, it has exchanged 
lessons learned with DOD, DOE, and State and provided technical 
expertise on radiological and nuclear detection equipment. However, 
most of DNDO's efforts are modest in scope and reflect the fact that 
DOD, DOE, and State have well-established programs to combat nuclear 
smuggling overseas. DNDO officials told us that their efforts to 
develop a more comprehensive approach to global nuclear detection are 
very complex because each agency has a distinct area of authority. 
Areas in which DNDO has been able to contribute to other agencies' 
overseas programs include the following: 

* DOD. DNDO has been working with DOD, among other agencies, to develop 
radiation detection equipment and to minimize duplication of research 
efforts. For example, DNDO and DOD are collaborating through the 
National Institute for Standards and Technology to develop interagency 
standards and common practices for testing and evaluating radiation 
detection systems. These standards will be threat based and will state 
the minimum detection capability that certain radiation detection 
systems should have to perform their purpose. 

* DOE. DNDO has been collaborating with DOE to develop strategies for 
addressing gaps in DOE's overseas radiation detection programs that are 
similar to those DNDO has been working on domestically. For example, 
DOE's Second Line of Defense program had focused more on placing fixed 
detectors at particular sites. However, as a result of DOE's review of 
its existing nuclear detection programs and its discussion with other 
agencies, including DNDO, DOE officials told us the agency has begun to 
work with law enforcement officials in other countries to improve 
detection capabilities for the land between ports of entry. DOE 
officials said they also are considering assisting other countries with 
the implementation of mobile detection technologies, similar to those 
used domestically by CBP. DNDO and DOE also are exchanging lessons 
learned from both agencies' efforts to screen aviation, specifically 
the development of standard operating procedures for using hand-held 
radiation detection equipment. 

* State. DNDO is working with State on the Global Initiative to Combat 
Nuclear Terrorism--which provides 75 countries with an opportunity to 
integrate resources and share information and expertise on nuclear 
smuggling prevention, detection, and response--to develop model 
guidelines that other countries can use to establish their own nuclear 
detection strategies. DNDO sponsored a Global Initiative workshop in 
March 2008 to help 25 countries develop a draft of the model guidelines 
document. This document, among other things, is intended to raise 
awareness about the elements of an effective nuclear detection strategy 
and build consensus for its implementation. In addition, DNDO personnel 
have traveled with officials from State to countries involved in the 
department's Nuclear Smuggling Outreach Initiative, a program to assess 
and improve the capabilities of countries to combat smuggling of 
nuclear and radiological materials, in order to provide advice to these 
countries on how to build their own capabilities to counter nuclear 
smuggling. DNDO also helped State develop questions that these 
countries could use to assess their own vulnerabilities. 

In addition to providing the U.S. government agencies engaged in 
international nuclear detection programs with knowledge gained from 
domestic nuclear detection initiatives, DNDO has been directed by these 
agencies to develop an inventory of radiation detection equipment 
deployed overseas. In a March 2006 report, we recommended that State, 
working with DOD and DOE, create, maintain, and share a comprehensive 
list of all U.S.-funded radiation detection equipment provided to 
foreign governments.[Footnote 19] In December 2006, State, in 
coordination with DOD, DOE, and DHS, issued a strategic plan giving 
DNDO responsibility for gathering data on the deployment of radiation 
detection equipment overseas, including portal monitors and handheld 
devices.[Footnote 20] As part of DNDO's efforts to develop the global 
strategy for nuclear detection, it is charged with maintaining this 
database, share information from it at interagency meetings, and 
provide other relevant government agencies with access to the database. 
According to DNDO, it collected information on radiation detection 
equipment from DOD, DOE, and State most recently in 2007 and is 
updating some of the information in 2008 and 2009. A DNDO official also 
said that the agency analyzed these data to determine the proximity of 
radiation detection equipment to areas with nuclear facilities. 

A Total of $2.8 Billion Was Budgeted in Fiscal Year 2007 for Programs 
Associated with Detecting Radiological and Nuclear Materials: 

DHS, DOD, DOE, and State budgeted a total of $2.8 billion in fiscal 
year 2007 for the programs included in the global strategy for 
radiological and nuclear detection, according to DNDO. Nearly the same 
amount of funds--$1.1 billion--were budgeted for programs and 
activities to (1) combat nuclear smuggling overseas and (2) detect 
nuclear materials primarily at U.S. borders and ports of entry; a 
smaller portion was budgeted for cross-cutting programs. By agency, the 
majority of 2007 budgeted funds for the global strategy for 
radiological and nuclear detection went to DOE--62 percent. Although 
DNDO has detailed information on the budgets for various security and 
detection programs, it is not using this information to coordinate with 
other agencies on the overall strategic direction of these detection 
efforts. 

Amounts Budgeted for Programs to Combat Nuclear Smuggling Overseas and 
to Detect Nuclear Materials Primarily at U.S. Borders and Ports of 
Entry Were Nearly the Same: 

According to our analysis of DNDO's data, of the approximately $2.8 
billion agencies budgeted in fiscal year 2007, about 39 percent went to 
combat nuclear smuggling overseas, while 41 percent went to programs to 
detect and secure radiological and nuclear materials at and within U.S. 
borders; another 20 percent went to programs that cut across foreign 
and domestic activities. Figure 4 shows budgets by program focus and by 
agency. 

Figure 4: Budgets by Program Focus and Agency: 

[See PDF for image: pie-charts] 

FY 2007 Budget by Program Focus: 
Unites States: 41%; 
Overseas: 39%; 
Cross-cutting: 20%. 

FY 2007 Budget by Agency: 
DOE: 62%; 
DHS: 24%; 
DOD: 11%; 
State: 3%. 

Source: GAO analysis of DNDO data. 

[End of figure] 

Table 1 shows the allocation of these funds by programs to combat 
nuclear smuggling overseas and within the United States. 

Table 1: Distribution of Fiscal Year 2007 Budget for Detecting 
Radiological and Nuclear Weapons or Materials (Dollars in Millions): 

Geographic focus: Overseas; 
Fiscal year 2007 budget: DHS: $139.77; 
Fiscal year 2007 budget: DOD: $161.90; 
Fiscal year 2007 budget: DOE: $736.74; 
Fiscal year 2007 budget: State[A]: $81.13; 
Fiscal year 2007 budget: Total: $1,119.54. 

Geographic focus: United States[B]; 
Fiscal year 2007 budget: DHS: $274.65; 
Fiscal year 2007 budget: DOD: $1.60; 
Fiscal year 2007 budget: DOE: $871.49; 
Fiscal year 2007 budget: State[A]: 0.00; 
Fiscal year 2007 budget: Total: $1,147.74. 

Geographic focus: Cross-cutting; 
Fiscal year 2007 budget: DHS: $271.18; 
Fiscal year 2007 budget: DOD: $137.07; 
Fiscal year 2007 budget: DOE: $168.86; 
Fiscal year 2007 budget: State[A]: 0.00; 
Fiscal year 2007 budget: Total: $577.12. 

Dollars in millions: Geographic focus: Total; 
Fiscal year 2007 budget: DHS: $685.60; 
Fiscal year 2007 budget: DOD: $300.57; 
Fiscal year 2007 budget: DOE: $1,777.09; 
Fiscal year 2007 budget: State[A]: $81.13; 
Fiscal year 2007 budget: Total: $2,844.39. 

Source: GAO analysis of DNDO data. 

[A] State does not sponsor domestic programs to combat nuclear 
smuggling and did not provide budget amounts for its cross-cutting 
programs because these programs do not provide direct financial 
assistance and generally leverage resources from other federal agencies 
and international partners. 

[B] United States includes efforts at the border as well as within the 
interior of the country. 

[End of table] 

Programs to combat nuclear smuggling overseas. DOE received the 
majority of the budget for programs to combat international nuclear 
smuggling--$737 million (or approximately 67 percent) of the $1.1 
billion total in fiscal year 2007. For all the agencies, the 
international programs are largely intended to secure nuclear and 
radiological materials at their source or detect them in transit. By 
agency, key programs include the following: 

* DHS budgeted $139 million for its Container Security Initiative, 
which provides multidisciplinary teams--agents, intelligence analysts, 
and CBP officers--to selected foreign seaports in order to protect the 
United States from potential terrorist attacks using maritime cargo 
shipments and to help secure the primary system of containerized 
shipping for international trade.[Footnote 21] Another DHS program, the 
Secure Freight Initiative,[Footnote 22] is important to the global 
strategy for nuclear detection because it provides foreign countries 
with radiation scanning systems for containers at ports of departure 
and communications infrastructure to transmit radiological and nuclear 
material data to the United States. This program is designed to test 
the feasibility of 100 percent scanning of U.S.-bound container cargo 
at seven overseas seaports and involves the deployment of integrated 
scanning systems, consisting of radiation portal monitors and RIIDs. 

* At DOD, 98 percent of its budget for combating nuclear smuggling 
overseas went to three programs that are part of the Cooperative Threat 
Reduction Program--a program that protects national security by 
reducing the present threat and preventing the proliferation of weapons 
of mass destruction.[Footnote 23] The Nuclear Weapons Safety and 
Security Program had a budget of $92.8 million to enhance Russia's 
security systems at nuclear weapons storage sites and capability to 
account for and track nuclear weapons scheduled for dismantlement. The 
Proliferation Prevention Initiative had a budget of $32.4 million to 
help countries of the former Soviet Union prevent the smuggling of 
weapons of mass destruction or related materials across their borders; 
this initiative provides equipment, logistics support, and training. 
Finally, the Nuclear Weapons Transportation Security Program had a 
budget of $32.7 million to enhance safe and secure transport of nuclear 
weapons from operational sites and storage areas to enhanced security 
storage sites and dismantlement sites throughout Russia. 

* At DOE, two programs account for about 81 percent of the department's 
budget to combat nuclear smuggling overseas. First, the Materials 
Protection, Control, and Accounting Program had a budget of $414 
million.[Footnote 24] This program provides support to the Russian 
Federation and other countries of the former of Soviet Union to secure 
nuclear weapons and weapons material that may be at risk of theft or 
diversion from their current location. Second, DOE's Second Line of 
Defense--a cooperative assistance program for deploying radiological 
and nuclear detection systems and associated training at international 
border crossings, airports, and seaports--had a budget of $183 million. 
[Footnote 25] 

* State budgeted approximately $42 million for its Export Control and 
Related Border Security program to help stem the proliferation of 
weapons of mass destruction, their delivery systems, and conventional 
weapons by assisting recipient countries in detecting, deterring, 
preventing, and interdicting illicit trafficking in weapons and weapons-
related items.[Footnote 26] The program is also designed to provide a 
wide range of assistance and support, such as offering licensing and 
legal and regulatory technical workshops, and providing detection 
equipment and training for border control and enforcement agencies. 

Programs to combat radiological and nuclear smuggling at and within 
U.S. borders. As with programs to combat nuclear smuggling overseas, 
DOE received most of the budget for programs to combat radiological and 
nuclear smuggling domestically--$871 million (or 76 percent) of the 
$1.1 billion budgeted in fiscal year 2007. By agency, key programs 
include the following: 

* At DHS, the Advanced Spectroscopic Portals/Radiological Portal 
Monitors program had a budget of $209 million to provide systems 
development, acquisition, and deployment of these technologies to ports 
of entry. The Securing the Cities initiative, with a fiscal year 2007 
budget of $8.47 million, is intended to enhance protection and response 
capabilities in and around the nation's highest risk urban areas. 
Starting with New York City, the department will work with state and 
local officials to develop urban and regional deployment and operations 
strategies, identify appropriate detection equipment, establish the 
necessary support infrastructure, and develop incident management and 
response protocols. In addition, DHS budgeted $1.1 million for the West 
Coast Maritime Radiation Detection Program, which is evaluating general 
radiation detection capabilities to be deployed aboard Coast Guard or 
other law enforcement vessels that participate in vessel-boarding 
activities. 

* DOD budgeted $1.6 million for domestic radiation detection programs, 
with $1.1 million directed to its Radiation Protection Program. This 
program uses the best available detection technologies to prevent or 
mitigate the effects of radiation exposure on Pentagon personnel and 
structures. The remaining funds were budgeted for the department's 
Unconventional Nuclear Warfare Defense, which installed radiological 
and nuclear sensors at Camp Lejeune. 

* At DOE, $846 million (or 97 percent) of the $871 million budgeted to 
combat nuclear smuggling went to the Nuclear and Radiological Materials 
Security Program, which is intended to protect DOE's critical assets-- 
nuclear weapons, nuclear weapons components, special nuclear materials, 
classified information, and DOE facilities from such threats as 
terrorist activity, theft, diversion, loss, or unauthorized access. 

Cross-cutting activities that simultaneously support multiple programs. 
DHS had nearly half of the $577 million budgeted for cross-cutting 
activities--about $271 million. By agency, key programs include the 
following: 

* At DHS, the Human Portable Radiation Detection System had a budget of 
$18.1 million to support the development of detection systems and the 
acquisition of advanced, hand-held radiation detectors. In addition, 
DHS budgeted about $11 million for the Technical Reachback Program, 
which provides technical assistance to help personnel operating 
radiation detection equipment identify the source that triggered the 
alarm. Finally, the Joint Analysis Center had a budget of $1.75 million 
to collect and notify appropriate federal, state, and local agencies as 
early as possible of: 

radiological and nuclear threats and coordinate technical support to 
federal, state, and local authorities. 

* DOD budgeted $94.5 million of the $137 million of its funds budgeted 
for cross-cutting programs to support its Weapons of Mass Destruction 
Civil Support Teams. These 55 teams are deployed nationwide to support 
civil authorities during domestic chemical, biological, radiological, 
nuclear, and high-yield explosives incidents.[Footnote 27] In addition, 
the Nuclear Detection Technologies Division of DOD's Defense Threat 
Reduction Agency was budgeted $28 million in fiscal year 2007 to 
develop technologies to detect, locate, and identify radiological and 
nuclear weapons and materials to support search and interdiction 
missions. 

* At DOE, nearly all of the $168 million DOE budgeted for cross-cutting 
programs went to one program--the Proliferation Detection Program. This 
program, budgeted at $148 million, provides technical expertise and 
leadership toward the development of next generation nuclear detection 
technologies and methods to detect foreign nuclear materials and 
weapons production. This program develops the tools, technologies, and 
techniques for detecting, locating, and analyzing the global 
proliferation of weapons of mass destruction, with a special emphasis 
on nuclear weapons technology and the diversion of special nuclear 
materials. 

* Because many of State's efforts to combat nuclear smuggling leverage 
resources from other federal agencies and international partners, or 
these efforts do not provide direct financial assistance, State does 
not have a budget for all of its efforts. However, it still oversees a 
number of crosscutting programs. For example, the Nuclear Trafficking 
Response Group is responsible for coordinating responses to 
international nuclear and radiological alarms; its mission is to 
protect the United States by resolving incidents of nuclear smuggling 
and by interdicting materials in transit. The National Combating 
Terrorism Research Program works to develop prototypes for technology 
with specific applications to detect and characterize nuclear 
materials. This program is not a financial assistance program, and 
therefore has no formal budget. 

DNDO's Joint Annual Interagency Report Is Not Used for Analysis or to 
Focus Nuclear Detection Priorities: 

In July 2007, Congress passed the "Implementing Recommendations of the 
9/11 Commission Act of 2007," which required DHS, DOD, DOE, the 
Department of Justice, and the Director of National Intelligence to 
coordinate the preparation of a Joint Annual Interagency Review of the 
Global Nuclear Detection Architecture. DNDO collected these program- 
level budget data in response to a statutory requirement that select 
agencies, including DHS, DOD, DOE, and State, annually assess their 
capacity to implement their portion of the global nuclear detection 
strategy. DNDO issued this report in June 2008 after gathering data 
from relevant agencies on programs and budgets in support of each layer 
of the global nuclear detection effort. The report provides an overview 
of the global nuclear detection strategy and discusses programs and 
budgets for combating nuclear smuggling domestically and overseas. 

DNDO has collected these data since 2006. It used these data to 
identify areas in which new domestic initiatives may be needed. For 
example, in the most recent review, DNDO said that programs focused on 
the land border areas between ports of entry, aviation, and maritime 
pathways will need to grow substantially in the years ahead. However, 
the Joint Annual Interagency Review does not serve as a tool to analyze 
nuclear detection budgets across agencies in order to ensure that the 
level and nature of resources devoted to combating nuclear smuggling 
are going toward the highest priority gaps and are aligned with the 
overall strategic direction of global detection efforts. 

Agency officials said that their program decisions and budget requests 
are primarily guided by their agencies' mission-related needs, rather 
than by the overarching goals and priorities of a broader, more 
comprehensive global detection strategy. In addition, DOD, DOE, and 
State officials told us that the information in the review is primarily 
used to provide agencies and Congress with an overview of already 
established programmatic roles and responsibilities across the range of 
programs to combat nuclear smuggling. Finally, agency officials told us 
that they do not use the specific budget data included in the Joint 
Annual Interagency Review to help determine whether funding levels are 
reasonable in terms of individual agency or governmentwide needs. 

DNDO Has Not Yet Implemented Recommendation from July 2008 Testimony: 

In July 2008, we testified on the preliminary findings of our work. 
[Footnote 28] Specifically, we found that while DNDO's initiatives are 
a step in the right direction for improving the current efforts to 
combat nuclear smuggling, they are not being undertaken within the 
larger context of an overarching strategic plan. Although each agency 
with a role in combating nuclear smuggling has its own planning 
documents, an overarching strategic plan is needed to guide these 
efforts to address the gaps and move to a more comprehensive global 
nuclear detection strategy. Our past work has discussed the importance 
of strategic planning.[Footnote 29] We have reported that strategic 
plans should clearly define objectives to be accomplished, identify the 
roles and responsibilities for meeting each objective, ensure that the 
funding necessary to achieve the objectives is available, and employ 
monitoring mechanisms to determine progress and identify needed 
improvements. For example, such a plan would define how DNDO would 
monitor the goal of detecting the movement of radiological and nuclear 
materials through potential smuggling routes, such as small maritime 
craft or land border areas in between ports of entry. Moreover, this 
plan would include agreed-upon processes and procedures to guide the 
improvement of the efforts to combat nuclear smuggling and coordinate 
the activities of the participating agencies. 

DNDO agreed with the need for an overarching strategic plan and 
believes that many elements of such a plan exist in DHS and other 
agency documents, but noted that solutions for addressing gaps and 
vulnerabilities are still under development. As of December 2008, DNDO 
had not yet established detailed plans to address those gaps and 
vulnerabilities, nor had it integrated all the plan elements into an 
overarching strategic plan, as we recommended. 

Conclusions: 

Preventing terrorists from obtaining and smuggling radiological or 
nuclear material into the United States is a national security 
imperative. DNDO has an important and complex task in this regard-- 
develop a global nuclear detection strategy to combat nuclear smuggling 
and to keep radiological and nuclear material and weapons from entering 
the United States. However, DNDO has not yet taken steps to work with 
DOE, DOD, and State to develop an overarching strategic plan, as we 
recommended in July 2008. Given the national security implications and 
urgency attached to combating nuclear smuggling globally, we continue 
to believe that such a plan needs to be established as soon as 
possible. Without an overarching plan that ties together the various 
domestic and international efforts to combat nuclear smuggling and 
clearly describes goals, responsibilities, priorities, resource needs, 
and performance metrics, it is unclear how the strategy will evolve or 
whether it is evolving in the right direction. 

While DNDO has gathered useful program and budget information in its 
Joint Annual Interagency Review, we believe it has missed an 
opportunity to use this information as a basis for working with other 
agencies--most notably DOD, DOE and State--to identify future 
priorities, and analyze and help determine future resource allocations. 
We are not suggesting that any of the agencies participating in U.S. 
efforts to combat nuclear smuggling cede authority to manage its own 
programs. However, this information could be used as a tool to better 
ensure that limited resources are leveraged to promote program 
effectiveness and avoid potential duplicative efforts. By doing so, we 
believe the federal government will be better positioned to take a 
holistic view of global nuclear detection and develop a plan that helps 
safeguard investments to date, more closely links future goals with the 
resources necessary to achieve those goals, and enhances the agencies' 
ability to operate in a more cohesive and integrated fashion. 

DNDO, for its part, has helped highlight the need to address critical 
gaps in efforts to combat nuclear smuggling domestically. It also has 
made some progress in developing and supporting initiatives to close 
these gaps. However, remaining challenges are great, funding is 
uncertain, time frames are unclear, and the technology may not be 
available any time soon to bridge some of these vulnerabilities. 
Without a plan to guide development of initiatives to address domestic 
gaps, it is unclear how DNDO plans to achieve its objectives of closing 
these critical gaps, particularly in three key areas--land border areas 
between ports of entry, aviation, and small maritime vessels. 

Maritime detection efforts pose unique technological and operational 
challenges. DNDO's maritime pilot is a sensible first step to 
addressing this vulnerability. However, DNDO should establish criteria 
for assessing the effectiveness of this effort and use the result of 
this evaluation to determine the feasibility of expanding this program 
beyond the pilot stage. Should the pilot prove worthy of replicating, 
we believe that DNDO will need to engage in additional planning to 
identify next steps to help ensure that it will be able to roll the 
program out to other locations in a timely manner. 

Recommendations for Executive Action: 

To help ensure that U.S. governmentwide efforts to secure the homeland 
are well coordinated, well conceived, and properly implemented, we 
reiterate the recommendation we made in our July 2008 testimony to 
develop an overarching strategic plan. We also recommend that the 
Secretary of Homeland Security take the following four actions: 

* In coordination with the Secretary of Defense, the Secretary of 
Energy, and the Secretary of State, use the Joint Annual Interagency 
Review to guide future strategic efforts to combat nuclear smuggling. 
This effort should include analyzing overall budget allocations to 
determine whether governmentwide resources clearly align with 
identified priorities to maximize results and whether there is 
duplication of effort across agencies. 

* Develop a strategic plan for the domestic part of the global nuclear 
detection strategy to help ensure the future success of initiatives 
aimed at closing gaps and vulnerabilities. This plan should focus on, 
among other things, establishing time frames and costs for the three 
areas of recent focus--land border areas between ports of entry, 
aviation, and small maritime vessels. 

* Develop criteria to assess the effectiveness, cost, and feasibility 
of the maritime radiological and nuclear pilot program. 

* Should the decision be made to expand the maritime radiological and 
nuclear program beyond the pilot, undertake additional planning to 
identify next steps, including how and where a broader strategy would 
be implemented, what technology would be needed, what organizations 
should be involved, and how such efforts would be sustained. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to DHS, DOD, DOE, and State for 
comment. DHS and DOD provided written comments, which are presented in 
appendixes I and II, respectively. DOE and State provided technical 
comments which we incorporated as appropriate. DOD concurred with the 
recommendation that the Secretary of Homeland Security, in coordination 
with the Secretary of Defense, Secretary of Energy, and Secretary of 
State, use the Joint Annual Interagency Review to guide future 
strategic efforts to combat nuclear smuggling. DOD stated that greater 
use could be made of the review associated with the development of this 
annual report to guide U.S. efforts to combat nuclear smuggling. 

DHS did not directly comment on our recommendations but noted that the 
recommendations aligned with DNDO's past, present, and future actions. 
The department agreed, however, that planning can always be improved 
and that the office will seek to continue to do so. DHS also reiterated 
that it agreed with a recommendation that we made in our 2008 testimony 
on the need for an overarching strategic plan to guide future efforts 
to combat nuclear smuggling and move toward a more comprehensive global 
nuclear detection strategy. In its comments, DHS noted that work had 
already begun on an overarching plan. 

DHS also pointed to what, in its view, were a number of shortcomings in 
the draft report. Specifically, the department believes that we did not 
give enough credit to DNDO's strategic planning efforts. The department 
asserted that we did not clearly and adequately explain the background 
and context of DNDO's efforts to develop a global strategy, what has 
been accomplished so far, what challenges it faces, and what remains to 
be done. Finally, DHS asserted that the draft contained a number of 
inaccuracies and omissions that make it less reliable and useful than 
it could be. DHS also provided a number of more detailed comments on 
specific issues presented in the draft report. We have addressed those 
comments in our detailed responses and incorporated changes where 
appropriate. 

First, we found no evidence that DNDO engaged in long-term strategic 
planning to carry out its initiatives to address gaps in domestic 
nuclear detection. During the course of our review, we specifically 
asked DNDO for strategic planning documents used to develop and 
implement a global radiation detection strategy. In response, DNDO 
officials referred to the more than 4,000 pages of documents provided 
and stated in their comments on the report that this material was the 
basis for their plan. Although this information documented the efforts 
put forth by DNDO in developing its initial strategy and identifying 
gaps and vulnerabilities, it did not constitute a plan with clear 
goals, time frames, and costs. More specifically, DNDO commented that 
we did not mention the DNDO-Coast Guard Joint Acquisition Strategy as a 
cornerstone of its small maritime strategy, that we only mention DHS 
Small Vessel Security Strategy in passing in the back of the report, 
and that we do not mention the DHS Small Vessel Security Strategy 
implementation plan. We revised the report to include references to the 
Joint Acquisition Strategy and the implementation plan. However, we 
disagree with DNDO's characterization that we failed to give the Small 
Vessel Security Strategy adequate attention. In fact, the report 
describes the strategy and how it relates to efforts to combat nuclear 
smuggling. We would also point out, however, that these planning 
documents cited by DNDO only apply to one specific critical gap area 
identified--the small maritime vessel threat. 

Second, we disagree with the department's comment that we did not 
clearly and adequately explain the background and context of DNDO's 
efforts to develop a global strategy, what has been accomplished so 
far, what remains to be done, and what challenges it faces. 
Specifically, our report contains an overview of DNDO's initial 
approach in developing a global strategy, including providing 
information on steps DNDO has taken to identify potential pathways for 
radiological and nuclear material. In addition, the report identified 
some of DNDO's accomplishments in specific areas, such as working with 
the other agencies to develop new radiation detection technologies. 
Furthermore, we recognize that DNDO has helped highlight the need to 
address critical gaps in efforts to combat nuclear smuggling, and we 
have reported DNDO's key initiatives to improve radiation detection 
capabilities in areas that had previously received insufficient 
attention--land borders between the ports of entry, aviation, and 
maritime. The report also recognizes the many challenges that DNDO 
faces as it attempts to enhance nuclear detection capabilities, 
including technological limitations of detection equipment and 
sustaining initiatives beyond their pilot phase. We also believe that 
DNDO needs to undertake additional planning so that it can be in a 
better position to determine the work that remains. That is why our 
recommendation to develop a strategic plan for the domestic part of the 
global nuclear detection strategy is so crucial. 

Finally, where appropriate, we have incorporated a variety of technical 
comments provided by DHS to better characterize DNDO's role and 
accomplishments, and the challenges it faces in developing a global 
nuclear detection strategy to combat nuclear smuggling. We do not 
believe that any of the comments that we incorporated represented a 
serious flaw in the content or quality of the draft report and in fact 
improve the technical accuracy of the report. In the few areas where 
DHS commented that we were factually incorrect, we have made minor 
changes to the report to clarify our point, to correct technical 
inaccuracies, or to avoid confusion. Where appropriate, we have 
provided additional information to further support our point, in some 
cases using information contained in DHS's letter. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to interested 
congressional committees and Members of Congress, the Secretary of 
Homeland Security, the Secretary of Defense, the Secretary of Energy, 
and the Secretary of State. The report will also be available at no 
charge on the GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staffs have questions about this report, please contact 
me at (202) 512-3841 or maurerd@gao.gov. Contact points for our Offices 
of Congressional Relations and Public Affairs may be found on the last 
page of this report. GAO staff who made key contributions to this 
report are listed in appendix III. 

Signed by: 

David Maurer: 
Acting Director, Natural Resources and Environment: 

List of Requesters: 

The Honorable Joseph I. Lieberman:
Chairman:
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Bennie G. Thompson:
Chairman:
The Honorable Peter T. King:
Ranking Member:
Committee on Homeland Security: 
House of Representatives: 

The Honorable Bart Gordon Chairman:
Committee on Science and Technology:
House of Representatives: 

The Honorable Edolphus Towns:
Chairman:
Committee on Oversight and Government Reform:
House of Representatives: 

The Honorable Charles E. Schumer: 
United States Senate: 

The Honorable James R. Langevin: 
House of Representatives: 

The Honorable Michael T. McCaul:
House of Representatives: 

[End of section] 

Appendix I: Comments from the Department of Homeland Security: 

Note: GAO comments supplementing those in the report text appear at the 
end of this appendix. 

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

January 14, 2009: 

Mr. David Maurer: 
Acting Director, Natural Resources and Environment: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Maurer: 

RE: Draft Report GAO-09-257, Nuclear Detection: Domestic Nuclear 
Detection Office Should Improve Planning to Better Address Gaps and 
Vulnerabilities (360896) 

The Department of Homeland Security (DHS or Department) appreciates the 
opportunity to review and comment on the draft report referenced above. 
While the U.S. Government Accountability Office's (GAO's) 
recommendations align with the Domestic Nuclear Detection Office's 
(DNDO's) past, present, and future actions, DNDO does not believe that 
GAO gave due credit to DNDO's strategic planning efforts and 
significant accomplishments, as detailed below. DNDO agrees that 
planning, like all endeavors, can always be improved and that office 
will continue to do so. However, considering GAO's report as a whole, 
GAO does not clearly and accurately explain (I) the background and 
context of DNDO's efforts to develop an enhanced global nuclear 
detection architecture, (2) what has been accomplished thus far, (3) 
what still remains to be done, and (4) what challenges DNDO faces in 
addressing this portion of its mission. In addition, the report 
contains a number of inaccuracies and omissions that make it less 
reliable and useful than it could be. 

Because DNDO's comments are lengthy, the response is divided into two 
parts. The first part consists of general comments. The second part, 
contained in the ten-page attachment, consists of a page-by-page 
listing, with details on specific issues and concerns relative to the 
draft report. The Department believes that these comments are more than 
technical in nature. The comments provide balance, context, 
explanation, and address omissions and both parts should be considered 
as the Department's formal response. 

General Comments: 

DNDO has developed and in conjunction with its partners is implementing 
a sound strategy for enhancing the global nuclear detection 
architecture, one of its core missions. While more remains to be done, 
DNDO has already made substantial progress toward implementing this 
strategy. 

Beginning in 2005, DNDO and its interagency partners analyzed the then-
existing or baseline detection architecture and identified serious gaps 
and vulnerabilities that were not being adequately addressed by then-
existing detection programs in any agency. To address the gaps, a 
series of significant new initiatives has been launched and adjustments 
to existing programs have been introduced. Particularly noteworthy are 
four major sets of gaps that previously had received insufficient 
attention: general aviation, small maritime craft, the land borders 
between designated ports of entry, and gaps within the domestic 
interior layer of the architecture (i.e., areas of the U.S. not on the 
borders). New initiatives have been launched in all of these areas and 
substantial progress has been made. 

Putting these gaps on the agenda, in many cases for the first time, and 
launching new programs to address them, has in itself been a major 
achievement. DNDO and its partners have begun to shift the emphasis 
from a nuclear detection strategy that previously had focused almost 
exclusively on ports of entry, to a more balanced and comprehensive 
architecture that addresses a much broader spectrum of credible 
pathways by which adversaries could attack the United States. 

None of these gaps has a "quick fix." In many cases, new technology and 
new concepts of operations will be needed to fully address the 
vulnerabilities. These new approaches will need to be adapted and 
refined based on lessons learned in the field to withstand the 
practical demands of deploying detection systems in challenging new 
settings. In some cases, a sustained effort over many years will be 
necessary. 

As is often the case with challenging, long-term problems, not every 
detail can be spelled out at the beginning, and not every solution is 
in hand at the outset. Although much remains to be done, DNDO and its 
partners have identified the important vulnerabilities, are pursuing 
sound strategies for reducing them, and are making significant progress 
toward their solutions. 

GAO's explanation of the status of these efforts does not present a 
complete and balanced picture of what has been accomplished and what is 
being done to address remaining vulnerabilities. For example, one of 
the cornerstones of the small maritime strategy is the DNDO-Coast Guard 
Joint Acquisition Strategy, a joint plan to procure and sustain the 
radiological and nuclear detection equipment needed for hundreds of 
Coast Guard boarding teams. This plan has already achieved its initial 
goals, providing full operational capability to the Coast Guard by the 
end of fiscal year 2007, and the sustainment phase is proceeding 
smoothly. GAO does not mention the Joint Acquisition Strategy in their 
report. A second example, also concerning the small maritime vessel 
threat, concerns the DHS Small Vessel Security Strategy and the 
accompanying DHS Small Vessel Security Implementation Plan. GAO 
mentions the Strategy in passing far back in the report, but not in the 
introductory or summary sections. The Implementation Plan is not 
mentioned at all. 

DNDO agrees with GAO on the need for better documentation. It should be 
noted that there is no lack of documentation. DNDO provided GAO with 
more than 4000 pages of documents, numerous briefings with charts and 
handouts, and extensive written answers to questions contained in GAO 
questionnaires. However, better summary documents, including the 
overarching strategic plan recommended by GAO, will be valuable. Work 
has already begun on the overarching plan and additional supporting 
documents. 

Sincerely, 

Signed by: 

Michael E. McPoland, for: 

Jerald E. Levine: 
Director, Departmental GAO/OIG Liaison Office: 

Detailed Comments: 

On the highlights page, GAO states: "However, DNDO-sponsored field 
evaluations to test radiation detection equipment are still not 
complete and DNDO may not have all radiation detection equipment in 
place until 2012." [See comment 1] GAO does not clearly state why the 
field evaluations are not complete. The reason is that the first round 
of evaluations has shown that the existing commercial-off-the-shelf 
technology would not be effective in the intended application. Going 
ahead and continuing the evaluations, or proceeding to deploy 
ineffective equipment, just to meet the original field evaluation 
schedule, would have been inappropriate. Although not mentioned in the 
draft report, the Border Patrol has told GAO that lessons learned from 
the field evaluations have helped avert the expenditure of large 
amounts of taxpayer funds for equipment that would not have been 
effective. GAO states that DNDO may not have all radiation detection 
equipment in place until 2012. This statement does not make clear that 
this project is a joint effort with Customs and Border Protection 
(CBP). DNDO does not unilaterally put equipment in place. Furthermore, 
neither CBP nor DNDO will agree to put in place equipment that is not 
effective. [See comment 2] 

At the end of that same paragraph, in connection with the Puget Sound 
small maritime pilot, GAO states that: "However, DNDO has made little 
progress in ... resolving some of the challenges it faces in the pilot 
program, such as technological limitations of the detection equipment 
and sustaining current detection efforts." GAO does not explain the 
reasons behind these observations, thereby leaving a misleading 
impression that little is being accomplished. Not every challenge has a 
quick fix. [See comment 3] An important part of DNDO's charter is to 
develop mid-term and long-term solutions when quick fixes are not 
available or effective. DNDO believes this work is vitally important 
and complementary to work focused on near-term solutions. In 
characterizing as a lack of progress those mid-term and long-term 
technology development efforts that have not yet "resolved the 
challenges," GAO understates the value, importance, and challenge of 
technology development efforts needed to arrive at effective solutions. 
With regard to GAO's statement that little progress is being made on 
"sustaining current detection efforts," the assertion is incorrect. 
Further related comments are mentioned later. [See comment 4] 

On page 5, in the section on "Land border between ports of entry," GAO 
does not clearly acknowledge that DNDO and CBP developed a joint 
"Phased Deployment Implementation Plan," which was approved by senior 
management in both DNDO and CBP. [See comment 5] Furthermore, GAO does 
not acknowledge that that plan specifically called for a phased 
approach, as its title indicates, whereby (1) each step was intended to 
be contingent on the results of previous steps, and (2) it was clearly 
understood at the outset that schedule adjustments would be made if the 
results of field evaluations so indicated. Similarly, the original plan 
had preliminary cost estimates, based on a set of working assumptions 
that were intended to be updated periodically based on the results of 
the field evaluations. GAO's report does not recognize that this type 
of phased approach is in fact appropriate for problems where simple, 
off-the-shelf solutions are not available, including for example the 
particularly challenging environment for radiation detection on the 
land border between ports of entry. Not every problem has a quick fix. 
As the Border Patrol has stated to GAO, this careful, step-by-step 
approach has averted the expenditure of large amounts of taxpayer funds 
on ineffective or inappropriate solutions. DNDO and CBP are working 
diligently to develop solutions that are effective and suitable for 
their intended applications. 

On page 5, in the section on "Aviation," GAO does not acknowledge that 
DNDO has put some of these issues on the agenda for the first time. If 
not for DNDO's work on aviation gaps and vulnerabilities, some of these 
issues (e.g., the issue of radiological and nuclear detection for 
international general aviation) would have received little or no 
attention. [See comment 6] 

Second, GAO does not clearly explain the roles and responsibilities of 
DNDO, CBP and other government agencies in this section. The first two 
sentences refer to DNDO and to "DNDO initiatives." The next part of the 
paragraph then refers to CBP and states that CBP's "efforts to screen 
international cargo have not proceeded as smoothly" because of 
jurisdictional and operational issues between CBP and the 
Transportation Security Administration (TSA) and the local airport 
authority. The paragraph then states that these jurisdictional issues 
have "delayed DNDO's efforts...." GAO's account creates confusion about 
who is responsible for what. In fact, DNDO has no substantive 
involvement in jurisdictional issues between CBP and TSA, and the 
efforts to screen international cargo (which GAO refers to as "DNDO's 
efforts") are in fact a complex joint effort, involving multiple 
agencies. The paragraph should be rewritten to clarify roles and 
responsibilities. [See comment 7] 

On page 5, in the section entitled "Small maritime vessels," GAO 
mischaracterizes the differences between detection in the small 
maritime setting and detection in the aviation and land border 
settings, saying that "...initiatives in the maritime environment 
require developing and testing new equipment and new procedures...," in 
contrast to the land border and aviation where the initiatives "are 
being integrated into already existing CBP screening operations." This 
supposed distinction is inaccurate. Many of the detection activities 
for the land border and for aviation do in fact require new procedures 
and new equipment (although existing equipment can be used in some 
instances). In the small maritime vessels setting, the Coast Guard has 
been doing maritime radiological and nuclear detection for years, and 
so existing equipment and procedures are being used there. In all 
settings, it is usually desirable to overlay radiological and nuclear 
detection operations onto existing law enforcement activities. This is 
being done for aviation, small maritime vessels and land applications. 
[See comment 8] 

Later in that same paragraph, GAO does not provide essential context 
and perspective, and reaches conclusions that are not correct. GAO 
states: "DNDO has not established criteria for assessing the success of 
this pilot effort to help determine whether it should be expanded to 
other locations. In addition, should DNDO decide to continue this 
program, it does not currently have a plan detailing which locations it 
would target for maritime radiological and nuclear detection programs, 
nor has it estimated the total cost of this initiative." GAO also 
inaccurately implies that nothing is being or has been done about 
sustaining detection programs: "DNDO expects them [state, tribal, and 
local agencies] to seek funding from federal grant programs to sustain 
these initiatives. For many state and local agency officials we spoke 
with, the uncertainty of federal resources jeopardizes their ability to 
continue radiological and nuclear detection activities." [See comment 
9] 

GAO may have misunderstood what is intended here, perhaps because of 
the complexity of the grant process, although they acknowledge that 
Department of Homeland Security grant programs are the prescribed 
mechanism for extending these detection programs beyond the pilots. 
Congress has established the grant programs for precisely these kinds 
of activities. Congress does not provide funding to DNDO to pass 
through to State and local governments, except for certain pilot 
programs. If that Congressional policy is taken as the starting point 
(GAO has not recommended otherwise), then the operative question is how 
to adapt the grant process to address the small maritime vessel 
detection challenge. That is precisely what DNDO is working on. [See 
comment 10] 

GAO does not acknowledge that DNDO has already worked closely with the 
Coast Guard and the Federal Emergency Management Agency (FEMA) to craft 
language in the DHS Fiscal Year 2009 Port Security Grant Guidance and 
Homeland Security Grant Program Guidance that clearly makes funding for 
preventive radiological/nuclear detection systems a priority and 
encourages State and local agencies to consider this mission when 
submitting grant applications. Planning, equipment, training and 
exercise expenses are allowable under the grants, as well as specified 
overtime expenses. DNDO has also recommended that FEMA expand allowable 
maintenance costs and will continue to work with FEMA officials on 
these issues. 

In terms of criteria, the port security grant process relies on a well-
established risk scoring tool known as MSRAM (Maritime Security Risk 
Assessment Model) to score grant applications and, in conjunction with 
other factors, to determine whether they should be funded. Thus the 
criteria are risk-based. DNDO is working with the Coast Guard to adapt 
the MSRAM tool to accommodate more explicitly the radiological and 
nuclear detection challenge so that grant applications can be properly 
evaluated, through an annual competitive process that has been in 
routine use for several years. 

Nominally, there are some 361 ports in the United States. In principle, 
they might all be candidates for some form of radiological/nuclear 
detection capabilities to guard against small maritime vessel threats. 
As stated earlier, however, the basic criteria are risk-based and not 
all ports will score equally. Basic data to estimate risk scores for 
ports are already included in the MSRAM model, and thus will be 
factored into the scoring; as noted above, the model is also being 
refined to better address radiological and nuclear scenarios. 

In practice, the mechanism DNDO and the Coast Guard have adopted for 
outreach to the ports is via the Area Maritime Security Committees, of 
which there are some 46, generally covering multiple ports. (This 
fundamental element of DNDO's small maritime strategy is not mentioned 
anywhere in GAO's report.) It is DNDO's expectation that grant 
applications will ultimately come from participants in some fraction of 
these 46 AMSCs; the AMSCs are the organizing framework, and already 
have a well-established role. At present, we cannot estimate how many 
will apply, what specific assistance and funding they will seek, nor 
how their grant applications will score in comparison to others. Thus, 
it is not possible at present to estimate the total cost of the 
initiative. One of the principal purposes of the pilot projects is to 
establish a solid technical and analytic foundation so that those kinds 
of estimates can eventually be prepared. By not explaining this 
context, and calling for details that cannot possibly exist at this 
stage, GAO is presenting an incomplete picture of the situation. 

Also on page 6, in the paragraph on international activities, GAO does 
not recognize DNDO's recommendations for stronger international efforts 
on "Megaports for Air," small maritime vessel threats, general 
aviation, land borders between designated border crossings, and 
interior law enforcement in foreign countries. These represent 
significant gaps that DNDO has highlighted in the existing 
international programs and thus deserve explicit mention. [See comment 
11] 

On page 7, in a paragraph about budgets, GAO states that the budget 
crosscut information is not used to examine whether programs are 
aligned with priorities or to help establish current or future 
priorities. [See comment 12] However, GAO says the opposite later in 
the report (on page 32), where it notes that "[DNDO] used these data to 
identify areas in which new initiatives may be needed. For example, in 
the most recent review, DNDO said that programs focused on the land 
border between ports of entry, aviation, and maritime pathways will 
need to grow substantially in the years ahead." Other examples could 
also be cited. In addition, GAO does not provide context and 
explanation for the comment, and does not mention here an essential 
point, clearly recognized by Senators in the July 16 hearing before the 
Senate Homeland Security and Government Affairs Committee: DNDO has no 
authority over the budgets of other agencies. There is no requirement 
for other agencies to accept or act on recommendations or advice 
emerging from the budget crosscut. 

On page 8, GAO states that "DNDO has not yet established detailed plans 
to address those gaps and vulnerabilities...." GAO's statement is 
misleading, since it suggests DNDO has no plans or strategy to address 
the gaps and vulnerabilities. That is not correct. DNDO has identified 
gaps and vulnerabilities that previously were not being addressed, and 
we are systematically working to identify and develop workable 
solutions. The supposed lack of "detailed" plans, as GAO characterizes 
them, reflects the fact that solutions are not yet in hand for some of 
the key gaps and vulnerabilities. That does not mean there are no plans 
or strategy. We have already commented on this point in connection with 
the small maritime discussion on page 6, and we will return to it 
several times in the remainder of these comments. [See comment 13] 

On page 11, GAO states: "In addition, DOE has programs to secure 
nuclear and radiological sources domestically. For example, the U.S. 
Radiological Threat Reduction program recovers and manages excess and 
unwanted radioactive sources that belong to U.S. licensees." GAO does 
not recognize the important role of many other agencies in domestic 
security. For radioactive materials, for example, the Nuclear 
Regulatory Commission and the Agreement States play a far more 
fundamental role than the DOE program mentioned by GAO, although that 
program is a valuable part of the overall picture. [See comment 14] 

On page 12, GAO states: "Portal monitors are stationary or mobile 
pieces of equipment that can detect radioactive materials carried by 
vehicles." This statement is incomplete, overlooking other important 
uses of portal monitors to monitor pedestrians or packages, for example.
At the end of that same paragraph, GAO states: "Under certain 
circumstances, these devices [personal radiation detectors, or 
"pagers"] could also be used to detect smuggled nuclear material. 
However, they can only indicate variations in the general level of 
radiation and their sensitivity is limited because of the small size of 
the detector. Therefore, they should not be used for that purpose." 
This statement requires qualification and correction, because there are 
accepted applications in which pagers are used as a `"tripwire," as 
part of a more complex inspection process. Although the limitations of 
pagers are significant and must be kept in mind, GAO overstates the 
case in saying "they should not be relied upon." Pagers have a 
legitimate role in some circumstances. [See comment 15] 

Also on page 12, in a paragraph about the limitations of radiation 
detection devices, GAO states that "highly enriched uranium ... is 
among the most difficult materials to detect because of its relatively 
low level of radioactivity." Although this is true for passive 
radiation detection, it is not true for all types of radiation 
detection devices, for example, active interrogation techniques or x-
ray and gamma-ray imaging. Since this purports to be a generic 
discussion of radiation detection, GAO should take the extra effort to 
make its account technically precise by adding one word, "passive," 
before radiation detection. DNDO and other agencies are devoting 
significant R&D resources to active interrogation methods. Nonintrusive 
imaging techniques (e.g., x-ray and gamma ray) are also a significant 
focus of programs such as the Secure Freight Initiative. There is an 
important reason these techniques are receiving such emphasis-to solve 
the very problem that GAO raises but does not accurately describe: 
limitations of passive radiation detection. To suggest, as GAO's 
language does, that the problem is intractable (i.e., that HEU cannot 
be detected at all) is incorrect. [See comment 16] 

On the bottom of page 12, GAO has inserted a paragraph on Advanced 
Spectroscopic Portals (ASP). This subject is outside the agreed scope 
of this audit and the paragraph should be removed. GAO officials agreed 
that ASP would not be a part of this audit. At the entrance conference 
on October 18, 2007, Mr. F. James Shafer, Jr, accompanied by Messrs. 
Daren K. Sweeney and Eugene W. Wisnoski, explicitly stated that they 
would be pursuing "two separate jobs," namely this audit and an audit 
on the life cycle cost estimate for ASP. In response to DNDO questions 
about the scope of the two audits, Mr. Shafer further emphasized that 
for the audit of the global nuclear detection architecture (i.e., this 
audit) "I don't want to focus on ASP." In the earlier March 1, 2007 
entrance conference, Mr. Shafer was equally clear about the scope-it 
would be a separate audit. In 2007 and 2008, Congressional staff who 
requested the audit told us the same thing: they wanted to have a 
separate audit on the global nuclear detection architecture. [See 
comment 17] 

We had the opportunity to review GAO's draft testimony prior to the 
July 16 hearing before the Senate Homeland Security and Government 
Affairs Committee. We questioned the inclusion of ASP matters in that 
testimony, for the same reasons we have stated here. Indeed, during the 
course of this audit, including extensive written questions and answers 
and numerous briefings, GAO did not ask us a single question about ASP, 
and, as such, ASP should not be included within the scope of this 
report. 

On page 13, GAO states: DNDO is still in the early stages of developing 
initiatives to address these vulnerabilities, and it has not clearly 
articulated a long term plan for how to achieve its goal of closing 
these gaps by expanding radiological and nuclear detection capabilities 
in the time frames identified." This is similar to the comment on page 
8. Again GAO's statement is misleading, since it suggests DNDO has no 
plans or strategy to address the gaps and vulnerabilities. That is not 
accurate. DNDO has identified gaps and vulnerabilities that previously 
were not being addressed, and we are systematically working to identify 
and develop workable solutions. The supposed lack of "long term plans" 
as GAO states here reflects the fact that solutions are not yet in hand 
for some of the key gaps and vulnerabilities. Not every problem has a 
quick fix. That does not mean there are no plans or strategy. In the 
very next paragraph, GAO even talks about the joint plan with the 
Border Patrol extending to 2012 (as mentioned earlier, this plan is 
known as the Phased Deployment Implementation Plan). We have already 
commented on this point several times, and we will return to it again 
several times in the remainder of these comments. [See comment 18] 

Beginning at the bottom of page 14, GAO's account of the work on the 
land border between ports of entry paints an incomplete picture, and 
does not clearly explain the real issues that DNDO and CBP are 
attempting to address. The key challenge is not simply to buy 
equipment. DNDO and CBP, including the Border Patrol, are engaged in a 
deliberate, systematic program to identify effective and workable 
solutions, and at the same time avoid wasteful expenditures on systems 
that would not work or that would not be suited for the intended 
application. GAO's heavy focus on alleged schedule delays, without 
clearly explaining the context and the challenges, is an 
oversimplification of a complex and important problem. For example, GAO 
does not mention the challenges posed by 4th Amendment legal issues, 
which have an important impact on some of the technical and operational 
options. GAO does not mention the four-layer, defense-in-depth concept 
for the land border between ports of entry, and the technical needs 
that each layer entails. GAO briefly mentions portability as a 
consideration in selecting equipment, but does not clearly explain the 
severe demands this places on hardware choices, and the consequent 
implications for wide scale deployment of equipment in the near term. 
[See comment 19] 

At the bottom of page 14, GAO reports incomplete information about the 
procurement of radioactive isotope identification devices (RIIDs), and 
confuses several distinct issues and programs. [See comment 20] 

With regard to the purchase of radioactive isotope identification 
devices (RIIDs) for the Border Patrol, the joint DNDO-CBP Phased 
Deployment Implementation Plan originally did not call for the purchase 
of any RIIDs for the Border Patrol in FY08. Therefore, GAO's statement 
(attributed to "CBP officials") that "in fiscal year 2008, DNDO did not 
procure needed detection equipment in a timely manner" requires 
explanation. 

The FY08 procurements for the Border Patrol were initiated by DNDO and 
the Border Patrol in an effort to accelerate the milestones in the 
original Phased Deployment Implementation Plan, in order to meet the 
Border Patrol's urgent needs. Of course, by definition, in meeting 
urgent needs, faster is always better, but GAO's implication that there 
were inordinate delays and a lack of responsiveness on the part of DNDO 
is not an accurate account of what actually happened. 

Although not in the original plan agreed to by DNDO and CBP, DNDO (in 
response to discussions with Border Patrol counterparts) became aware 
and recognized the importance of the acute shortage of detectors at the 
Office of Border Patrol (OBP). Since this procurement was not in the 
original plan or budget, DNDO took steps during the summer of 2008 to 
identify a source of funds at DNDO to accelerate purchase of RIIDs from 
FY09 to FY08. Because it was not part of the original approved plan, 
the DNDO Phased Deployment Implementation Plan (PDIP) representative 
asked for and received a written request from the OBP representative 
for 64 RIIDs to be procured at the earliest possible time. This request 
was approved by DNDO management, and a procurement request was 
processed. The detectors are scheduled to arrive early in fiscal year 
2009. If they had not been ordered until FY09, as originally planned, 
they would have been delivered later, probably sometime in the second 
or third quarter in CY09. Thus, instead of delaying the procurements, 
DNDO expedited them. 

DNDO similarly accelerated FY09 purchases for the Border Patrol, again 
responding to urgent Border Patrol requirements and going beyond the 
quantities specified in the PDIP. On December 16, we initiated a 
purchase order for an additional 169 RIIDs. Delivery of the first ten 
units is scheduled on January 23. After that, 10 systems a week will be 
shipped from January 30 through May 8, 2009, with the last delivery 
being 8 systems. 

GAO reports statements by CBP officials about procurement delays, but 
does not mention the background or reasons. In FY 08, DNDO placed an 
order for 240 RIIDs, as GAO stated. It should be noted that this was a 
combined procurement for the Office of Field Operations (OFO) as well 
as for the Border Patrol. The status of RIIDs at ports of entry raises 
a different set of issues than the Border Patrol application, which GAO 
does not clearly explain. The Border Patrol aspect of the issue was 
discussed in the previous comments above, and as explained there, DNDO 
actually accelerated the procurement ahead of the original schedule. In 
any case, 240 RIIDs were ordered and the first 2 shipments were found 
during receiving inspection to have many failed units. Corrective 
actions were therefore necessary. In direct consultation with CBP, it 
was determined that a back-up RIID (a different make and model) should 
be explored so that if the original vendor could not fix its production 
problems, DNDO and CBP could then switch to a new device and thereby 
meet OFO and OBP needs. A field evaluation was planned for the new 
device. Fifty new units were to be procured and tested at 2 CBP ports 
of entry. Steps were also taken in parallel to have the original vendor 
upgrade quality control procedures. All of these actions were taken 
with complete CBP involvement and cooperation. In summary, the root 
cause of these procurement issues was reliability problems with the 
equipment, a point not mentioned by GAO. 

On page 15, in the section on aviation, GAO has not clearly delineated 
the roles and responsibilities of the agencies involved in these 
programs. First, GAO states: "CBP, with the support of DNDO, has been 
working since 2005, on initiatives to screen all incoming international 
planes, cargo, and passengers." Then GAO states: "While DNDO has made 
progress in ensuring that appropriate operating procedures ... are 
established, its other aviation initiatives have not proceeded as 
smoothly or have not yet begun." Later in the same section, GAO 
discusses the efforts to screen air cargo, saying "DNDO is working with 
CBP...," and also referring to jurisdictional disputes between CBP and 
TSA. The air cargo project was originally a CBP initiative that 
predated DNDO. It was part of CBP's Radiation Portal Monitoring 
Program. It is true that progress has been slow, for a variety of 
reasons. However, to attribute the delays to DNDO ("its other aviation 
initiatives have not proceeded as smoothly") is not correct. The 
reported jurisdictional disputes between CBP and TSA, for example, are 
not the responsibility of DNDO. This section should be rewritten to 
clarify roles and responsibilities. [See comment 21] 

At the bottom of page 16, GAO describes a "demonstration of radiation 
detection capabilities" at Dulles airport. This anecdote, as presented, 
does not have a sound technical foundation, since the activity of the 
137Cs' radiation source may not have been suitable for this type of 
dynamic test. First, GAO does not explain that the Cesium-137 check 
source used in the demonstration is tiny compared to the amounts that 
would constitute a serious concern. In the IAEA Code of Conduct, a 
category 3 quantity of Cesium-137 is 3 curies (or 0.1 TeraBecquerel), 
orders of magnitude larger than the check source in question. Most 
check sources are exempt-quantity amounts characterized by very low 
activity levels. These levels are far below the portal's design 
threshold when carried by a moving vehicle. [See comment 22] 

Furthermore, GAO's statement that "CBP uses this sample to routinely 
test equipment" is misleading. It is a check source, not a test source. 
The procedures for the use of a check source versus a test source are 
different. A check source is used to validate detector response to a 
source of radiation or possibly a calibration point, and is typically 
placed on the surface of the detector. This is the reason that check 
sources contain very little radioactive material. A test source is used 
to verify the operation of a detector by using it in the configuration 
that mimics the material in normal commerce. (e.g., in a car, in 
luggage) Thus a test source would contain a larger amount of 
radioactive material and more closely approximate the category 1 or 2 
quantity that would be of concern. The demonstration, as described, has 
no technical basis. 

In the last paragraph on page 17, GAO states: "DNDO and CBP would like 
the detection of radiological and nuclear materials to occur as far 
outside U.S. borders as possible...." There is in fact a compelling 
security imperative here, which GAO minimizes by describing it as a 
mere preference by DNDO and CBP ("DNDO and CBP would like"). This is 
one of the largest and most important vulnerabilities in the existing 
detection architecture. [See comment 23] 

On page 18, in the discussion of small maritime vessels, GAO's 
statement of the reasons that Puget Sound was chosen is incomplete. One 
of the major drivers behind the selection of Puget Sound is the volume 
of traffic from Asia, an important potential source of radiological and 
nuclear threats that pass through and near the Pacific Northwest. [See 
comment 24] 

On page 18, the last sentence states: "According to DNDO's data for 
fiscal years 2008 and 2009, the agency requested $54.2 million for 
these and other maritime initiatives." This comment is misleading since 
it is at the bottom of a paragraph highlighting details of the West 
Coast Maritime Pilot project, leading the reader to infer the majority 
of this funding went to pilot project. For fiscal years 2008 and 2009 
funding allocated for the pilot project is $14.7M. [See comment 25] 

On page 19, GAO states that "DNDO has not yet developed plans for 
[sustaining maritime radiological and nuclear detection efforts]." This 
statement is inaccurate. As discussed earlier, DNDO plans to leverage 
the grant process and has already taken steps to make this happen, 
including working with the Coast Guard and FEMA to craft suitable grant 
guidance, and working with the Coast Guard to refine the MSRAM risk 
scoring tool to better represent radiological and nuclear detection 
scenarios. Furthermore, GAO does not recognize the role and clear 
direction of Congress in establishing grant programs as the mechanism 
for supporting State and local efforts. GAO's repeated statements that 
DNDO does not have a plan are incorrect. For example, the ongoing 
effort to update the MSRAM tool would not be happening in the absence 
of a plan to leverage the grant process. [See comment 26] 

In the middle paragraph on page 20, GAO states: `"Should its concept 
for detecting and interdicting radiological and nuclear material 
smuggled on small maritime vessels prove feasible, DNDO plans to 
develop guidance so that state and local law enforcement agencies can 
implement their own maritime radiological and nuclear detection 
programs." This has already been done. The "maritime module" of the 
Preventive Radiological and Nuclear Detection Handbook has been 
developed with the input of more than thirty state and local entities. 
The draft is currently under review and will be completed early in 
calendar year 2009. [See comment 27] 

On page 21, GAO makes a number of incomplete statements about detection 
technologies in the maritime environment. First, GAO states that: "The 
boat-mounted radiation detection equipment is unable to indicate the 
direction of the radioactive material causing the alarm, making it 
difficult to identify the potential threat in an open sea with many 
small vessels, according to a local law enforcement officer we spoke 
with." The same problem occurs in the land and aviation vectors, and is 
addressed by applying appropriate concepts of operations (CONOPS). This 
is not a limitation that is unique to the maritime environment, nor is 
it intractable. Second, GAO implies serious problems with backpack 
detectors, because of the difficulties Coast Guard officers supposedly 
have maneuvering with these detectors. Difficulties notwithstanding, 
the Coast Guard has adopted, and routinely uses, backpack detectors. 
They determined several years ago that backpacks provide, on balance, a 
reasonable tool for meeting certain needs in the Coast Guard boarding 
team environment. Third, GAO implies that a serious problem exists 
because handheld detectors do not float if dropped overboard. The same 
can be said of many other tools used in the maritime environment, e.g., 
firearms, radios and other communication equipment, cameras and video 
equipment, etc. Simple solutions such as tethering the equipment are 
readily available and in some cases, have already been applied in the 
maritime environment to minimize loss or damage. [See comment 28] 

On page 22, GAO asserts that "According to a DNDO official, DNDO was 
slow to process the order." Equipment delivery delays for the West 
Coast Pilot involved a number of challenges. For example when a pager, 
was ordered, the vendor did not have sufficient units in stock (the 
vendor actually had none) and did not notify DNDO. Upon discovery, DNDO 
took immediate action. Delivery of this equipment has begun, and with 
the exception of the backpacks, will be completed over the next several 
months with no adverse impact on the overall pilot timeline expected. 
[See comment 29] 

On page 23, GAO states "However, NYPD officials told us that NYPD has 
another 28 boats that need to be equipped with radiation detection 
technology and these equipment purchases depend on the availability of 
future federal grant funding." NYPD was a major participant in 
developing the Securing the Cities initiative maritime concept of 
operations (CONOPS), which for the nine identified maritime 
chokepoints, called for "...2 boat-mounted detectors per chokepoint at 
a minimum with a minimum of 1 RIID at each chokepoint to obtain 
spectrum..." Sufficient funding exists within the STC initiative to 
achieve this CONOPS if NYPD so desires. [See comment 30] 

On page 23, GAO states: "DNDO officials told us that their efforts are 
very complex because each agency has a distinct area of authority." 
This quote is incomplete. There are many other reasons contributing to 
the complexity, besides the one GAO mentions, and we have raised those 
issues with GAO. [See comment 31] 

On page 27, GAO states: "According to DNDO, it collected information on 
radiation detection equipment from DOD, DOE and State most recently in 
2007." DNDO collected such information beginning in 2005 and is 
updating some of the information in 2008 and 2009. [See comment 32] 

At the bottom of page 25, GAO states: "Although DNDO has detailed 
information on the budgets for various security and detection programs, 
it is not using this information to ensure that agencies efforts are 
directed toward the highest priorities." GAO does not note that DNDO 
has no authority to "ensure that agencies efforts are directed toward 
the highest priorities." This issue was a major point of discussion at 
the July 16 hearing before the Senate Homeland Security and Government 
Affairs Committee; GAO does not address it. [See comment 33] 

On page 34, GAO states that "DNDO has not yet taken steps to work with 
DOE, DOD, and State to develop an overarching strategic plan, as we 
recommended in July 2008." GAO's statement is incorrect. For example, 
we included a call for strategic planning information as part of the 
data call issued for the next edition of the Joint Annual Interagency 
Review of the Global Nuclear Detection Architecture. [See comment 34] 

The following are GAO's comments on the Department of Homeland 
Security's letter dated January 14, 2009. 

GAO Comments: 

1. We agree with DHS that deploying or purchasing ineffective equipment 
would be inappropriate. We also agree with DHS that, as we reported, 
field evaluations are not complete and that the necessary equipment may 
not be deployed until 2012. We discuss the reasons for these delays on 
page 14 of the report. In addition, we disagree with DHS's assertion 
that Border Patrol told us that lessons learned from field evaluations 
"would help avert large amounts of taxpayer funds for equipment that 
would not have been effective." We do not dispute the importance of 
spending taxpayer dollars wisely; however, it was not expressed to us 
as such until this letter. 

2. We added language on the highlights page to clarify that CBP is also 
responsible for putting radiation detection equipment in place. 

3. We discuss in more depth the technological limitations of detection 
equipment and sustaining detection efforts on pages 19 through 21 of 
the report. 

4. DHS commented that we have understated the value, importance, and 
challenge of technology development efforts needed to arrive at 
effective solutions. We disagree. We acknowledge these challenges in 
the body of the report and discuss some of the measures DNDO has taken 
to develop needed equipment. Furthermore, we disagree with DNDO's 
statement about our findings regarding the status of sustainability 
planning. We describe at more length on pages 19 and 20 of the report 
our concerns with DNDO's efforts to sustain maritime initiatives into 
the future. 

5. While we do not mention the Phased Deployment Implementation Plan by 
name, on page 14 we state that DNDO and CBP are jointly working on 
measures to better secure the border areas between ports of entry and 
that these efforts are part of a phased approach. We have added 
clarifying language to the paragraph on page 4 to more clearly 
delineate the different roles CBP and DNDO play in this regard. 
Furthermore, while we do not disagree with taking a phased approach, 
DNDO has not kept to its original schedule and if such delays continue, 
it is uncertain whether DNDO and CBP will meet their original goal of 
full deployment of equipment by 2012. 

6. We have modified the text on page 16 to include a reference that 
efforts to screen aviation for radiological and nuclear materials are 
being included in the strategy for the first time. 

7. We have modified the language on page 5 to clarify the roles and 
responsibilities of DNDO and CBP. 

8. DHS may have misunderstood the point we were making concerning 
maritime screening as compared with land and aviation screening. We 
agree that non-port of entry screening will require modifications to 
existing screening operations and new equipment. However, we were told 
that maritime screening posed unique challenges, which we have 
documented on pages 18-21 of this report. 

9. We disagree with DHS that the conclusions we reach regarding the 
maritime program are incorrect. Although DHS comments that our 
conclusions are incorrect, DHS does not dispute the facts we present. 
Namely, DNDO has not established criteria for assessing the success of 
pilot efforts and it has no plan detailing which locations it would 
target next. Furthermore, during the course of our work we heard 
repeated concerns about the sustainability of the maritime radiological 
and nuclear screening from state and local law enforcement. 
Specifically, we asked the maritime mission area manager if a 
sustainability plan existed and we were told no. After our visit to 
Puget Sound, we received an e-mail from the manager stating DNDO would 
begin to develop a sustainability plan should the decision be made to 
continue the initiative. 

10. We understand the role of grants in funding these types of 
activities and agree with DHS that, according to DNDO, grants are the 
primary mechanism it plans to rely on for sustaining radiological and 
nuclear detection activities in the maritime environment. We agree with 
DNDO efforts to work with the Coast Guard to adapt the Maritime 
Security Risk Assessment Model to accommodate more explicitly 
radiological and nuclear detection challenges. However, we maintain our 
concern that DNDO does not have any detailed plans, including how and 
where a broader strategy would be implemented, what technology would be 
needed, what organizations should be involved, and how such efforts 
would be sustained for this important national security issue. 

11. DNDO incorrectly asserted that we did not recognize its 
contributions to international efforts. On page 23 of the report we 
acknowledged DNDO's efforts to look for opportunities to work with 
other agencies to help strengthen their radiological and nuclear 
detection efforts, despite the fact that these programs to combat 
nuclear smuggling are well established and are under the purview of 
another agency. 

12. DNDO has misunderstood the reference to its annual assessment of 
the global nuclear detection strategy and we believe the text that now 
appears on page 6 is consistent with our discussion later in the 
report. Our discussion on page 6 focuses on the global strategy, 
encompassing radiological and nuclear detection activities across all 
relevant government agencies. The reference DNDO makes to text later in 
the report focuses specifically on actions taken by DNDO to enhance 
domestic detection capabilities. However, we have modified the language 
to be clearer about what is being discussed in each place. We 
acknowledge that DNDO does not have authority over the budgets of other 
agencies and we would not advocate for such authority to be provided to 
it. However, DNDO is responsible for enhancing and coordinating 
federal, state, and local efforts to combat nuclear smuggling 
domestically and overseas. We believe that the analysis we are 
recommending--that DNDO undertake using data collected as part of the 
Joint Annual Interagency Review--is consistent with this requirement. 

13. We recommended that DNDO develop a strategic plan to guide the 
development of a more comprehensive global nuclear strategy and 
delineated what such a plan should contain, including clearly defined 
objectives, roles, and responsibilities for meeting the objectives; 
necessary funding; and monitoring mechanisms to determine progress in 
meeting goals. However, DNDO has not yet produced such a strategic 
plan. We acknowledge that combating nuclear smuggling on a global scale 
is a large and complex undertaking. We repeatedly asked DNDO for 
detailed plans, containing the elements described above, but did not 
receive any. 

14. We have modified the text on page 12 to recognize the role of the 
Nuclear Regulatory Commission. 

15. DNDO commented that portal monitors can also be used to monitor 
pedestrians, but according to CBP, it does not currently use portal 
monitors for this purpose. However, we have modified the text to 
reflect that portal monitors are used for screening cargo containers. 
With regard to the use of pagers to detect smuggled nuclear material, 
we have reported in the past on the limitations of using these devices 
and that pagers should not be relied upon to detect smuggled nuclear 
material. 

16. None of the radiation detection devices discussed in this report 
use the active interrogation techniques cited by DHS. 

17. DHS commented that including a paragraph on ASPs (now on page 13) 
was beyond the scope of this audit and should be removed from this 
report. The scope of our review is presented on pages 3 and 4 of the 
report. As such, we agree with DHS that our review did not include an 
assessment of DNDO's efforts to test and procure ASP technology. 
However, several prior GAO reports have found significant problems with 
DNDO's work in this area. Reporting the results of our prior work in 
the background of this report is appropriate and germane because portal 
monitors are a key component of the global nuclear detection strategy. 

18. DHS commented that our findings on DNDO's lack of long-term plans 
are misleading and suggest DNDO has no plans or strategies. We agree 
that DNDO has identified gaps and vulnerabilities and has taken some 
steps to address these, including jointly working with CBP as mentioned 
on page 14 of our report. However, DHS does not dispute our finding 
that it has not developed a detailed plan, which clearly conveys the 
goals, responsibilities, resource needs, and performance metrics needed 
to further its detection efforts. Identifying gaps and initiating 
programs are positive steps toward enhancing detection capabilities, 
but these efforts alone do not constitute a long-term plan. Without a 
detailed, documented plan, DNDO will be unable to determine whether 
these new programs are actually succeeding and addressing the 
identified gaps. 

19. We believe DHS had misconstrued our description of efforts to 
implement radiological and nuclear screening at the border areas in 
between official ports of entry. We acknowledge that there are a number 
of challenges associated with implementing portable detection equipment 
for use in the field and appreciate DNDO and CBPs efforts to develop 
this capability. However, the fact remains that DNDO has not kept to 
its original schedule, and if such delays continue, it is uncertain 
whether DNDO and CBP will meet their original goal of full deployment 
of such equipment by 2012. 

20. Our description of the procurement challenges faced by DNDO and CBP 
is an accurate summary of the information we were provided. One of 
DNDO's primary roles is to test and procure needed radiological and 
nuclear detection equipment for use by CBP and other agencies. We were 
informed by CBP that it did not receive the equipment it had originally 
ordered in the agreed upon time frames. Regardless of whether the 
equipment was for use at an official border crossing or for use by 
Border Patrol officers in the field, the needed equipment was not 
procured as requested. In CBP's technical comments on a draft of this 
report, it stressed that its radiological and nuclear detection 
equipment procurement funding was handed over to DNDO in 2006. CBP 
further stated that it believes that the most effective way to procure 
commercial off-the-shelf equipment is for CBP to have its own radiation 
and nuclear equipment budget. 

21. We have modified the text on pages 15 through 17 to more clearly 
delineate roles and responsibilities. 

22. We have accurately described what we observed during our visit to 
Dulles International Airport. We were told by CBP officials that the 
source used in the demonstration was what they use to routinely check 
the responsiveness of the portal monitor and successfully did just that 
earlier in the week. 

23. We believe DHS has misconstrued our statement about detecting 
radiological and nuclear material outside the U.S. borders. We are not 
minimizing the importance of such a goal. In fact, since DNDO believes 
that it is one of the largest and most important vulnerabilities in the 
existing detection architecture, it will be even more important that 
DNDO develop detailed plans for securing such arrangements with as many 
nations as possible. 

24. We have listed on page 18 of the report a number of other factors 
we were told by DHS officials influenced the decision to pilot the 
maritime program in the Puget Sound area. In response to the draft 
report, DHS provided an additional reason for the selection of Puget 
Sound. 

25. We modified the text on page 19 to include the actual funding 
amount for the pilot project. 

26. See comments 9 and 10. 

27. DHS provided new information that the Preventative Radiological and 
Nuclear Detection handbook is under development and that DNDO reached 
out to state and local entities in its development. This is another 
positive step. However, as DNDO stated, this handbook is currently in 
draft, undergoing review, and not yet finalized or in use by any 
locale. 

28. We believe DNDO has incorrectly characterized our finding regarding 
detection technologies in the maritime environment. On pages 20 and 21, 
our report delineates some of the technological limitations, as they 
were presented to us by the users of the equipment. We do not assert 
that these limitations are insurmountable; only that they exist and 
should be taken into consideration when crafting a plan for 
radiological and nuclear detection in the maritime environment. 

29. The information contained in the report on page 22 is factually 
accurate. 

30. The information contained on pages 22 and 23 of the report was 
obtained through interviews with NYPD officials in the presence of a 
DNDO representative. The primary purpose of the statement was to point 
out the number of boats with boat-mounted radiation detection equipment 
in use at the time of our review. 

31. While there are other complexities with developing a global nuclear 
detection strategy, DNDO officials repeatedly told us during the course 
of our review that a primary complicating factor is the office's 
limited ability to influence other agencies' programs to combat nuclear 
smuggling. 

32. We modified the text on page 25 to reflect DNDO's efforts to update 
some of the information. 

33. We modified the text on page 25 to reflect the fact that DNDO 
should coordinate with other agencies on the overall strategic 
direction of detection efforts. 

34. In response to our July 2008 recommendation that DNDO develop an 
overarching strategic plan, DNDO commented that it has included a 
request for strategic planning information as part of its efforts to 
develop the next edition of the Joint Annual Interagency Review. 
However, DHS did not comment on how this will inform or contribute to 
an overarching strategic plan to guide future enhancement to global 
nuclear detection. 

[End of section] 

Appendix II: Comments from the Department of Defense: 

Assistant To The Secretary Of Defense
Nuclear And Chemical And Biological Defense Programs
3050 Defense Pentagon: 
Washington, DC 20301-3050: 

January 13, 2009: 

Mr. David Maurer: 
Acting Director, Natural Resources and Environment: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Maurer: 

The following submission is the Department of Defense (DoD) response to 
the GAO draft report GAO-09-257, "Nuclear Detection: Domestic Nuclear 
Detection Office Should Improve Planning to Better Address Gaps and 
Vulnerabilities. Detailed comments on the report recommendations are 
enclosed. 

DoD appreciates the opportunity to review and comment on this draft 
report. After reviewing the report, DoD concurs with the 
recommendation. 

Sincerely, 

Signed by: 

Illegible, for: 
Fred S. Celec: 

Enclosure: As stated: 

GAO Draft Report Dated December 18, 2008: 
GAO-09-257 (GAO Code 360896): 

"Nuclear Detection: Domestic Nuclear Detection Office Should Improve 
Planning To Better Address Gaps And Vulnerabilities" 

Department Of Defense Comments To The GAO Recommendations: 

Recommendation: The GAO recommends that the Secretary of Homeland 
Security, in coordination with the Secretary of Defense, the Secretary 
of Energy, and the Secretary of State, use the Joint Annual Interagency 
Review to guide future strategic efforts to combat nuclear smuggling. 

DOD Response: DoD concurs with this recommendation. Greater use could 
be made of the review associated with the development of this annual 
report to guide U.S. efforts to combat nuclear smuggling. 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

David Maurer, 202-512-3841 or maurerd@gao.gov: 

Staff Acknowledgments: 

In addition to the contact person named above, Glen Levis (Assistant 
Director), Elizabeth Erdmann, Rachel Girshick, Sandra Kerr, Omari 
Norman, Kim Raheb, Rebecca Shea, Carol Herrnstadt Shulman, and Tommy 
Williams made key contributions to this report. 

[End of section] 

Related GAO Products: 

Securing Nuclear and Radiological Material Overseas: 

Nuclear Nonproliferation: Focusing on the Highest Priority Radiological 
Sources Could Improve DOE's Efforts to Secure Sources in Foreign 
Countries. [hyperlink, http://www.gao.gov/products/GAO-07-580T]. 
Washington, D.C.: March 13, 2007. 

Nuclear Nonproliferation: Progress Made in Improving Security at 
Russian Nuclear Sites, but the Long-term Sustainability of U.S.-Funded 
Security Upgrades Is Uncertain. [hyperlink, 
http://www.gao.gov/products/GAO-07-404]. Washington, D.C.: February 28, 
2007. 

Nuclear Nonproliferation: DOE's International Radiological Threat 
Reduction Program Needs to Focus Future Efforts on Securing the Highest 
Priority Radiological Sources. [hyperlink, 
http://www.gao.gov/products/GAO-07-282]. Washington, D.C.: January 31, 
2007. 

Nuclear Nonproliferation: IAEA Has Strengthened Its Safeguards and 
Nuclear Security Programs, but Weaknesses Need to Be Addressed. 
[hyperlink, http://www.gao.gov/products/GAO-06-93]. Washington, D.C.: 
October 7, 2005. 

Radiological Sources in Iraq: DOD Should Evaluate Its Source Recovery 
Efforts and Apply Lessons Learned to Future Recovery Missions. 
[hyperlink, http://www.gao.gov/products/GAO-05-672]. Washington, D.C.: 
September 7, 2005. 

Nuclear Nonproliferation: U.S. and International Assistance Efforts to 
Control Sealed Radioactive Sources Need Strengthening. [hyperlink, 
http://www.gao.gov/products/GAO-03-638]. Washington, D.C.: May 16, 
2003. 

Weapons of Mass Destruction: Additional Russian Cooperation Needed to 
Facilitate U.S. Efforts to Improve Security at Russian Sites. 
[hyperlink, http://www.gao.gov/products/GAO-03-482]. Washington, D.C.: 
March 24, 2003. 

Securing Nuclear and Radiological Material in the United States: 

Nuclear Security: DOE and NRC Have Different Security Requirements for 
Protecting Weapons-Grade Material from Terrorist Attacks. [hyperlink, 
http://www.gao.gov/products/GAO-07-1197R]. Washington, D.C.: September 
11, 2007. 

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

National Nuclear Security Administration: Security and Management 
Improvements Can Enhance Implementation of the NNSA Act. [hyperlink, 
http://www.gao.gov/products/GAO-07-428T]. Washington, D.C.: January 31, 
2007. 

Securing U.S. Nuclear Materials: Poor Planning Has Complicated DOE's 
Plutonium Consolidation Efforts. [hyperlink, 
http://www.gao.gov/products/GAO-06-164T]. Washington, D.C.: October 7, 
2005. 

Nuclear Security: DOE Needs Better Information to Guide Its Expanded 
Recovery of Sealed Radiological Sources. [hyperlink, 
http://www.gao.gov/products/GAO-05-967]. Washington, D.C.: September 
22, 2005. 

Nuclear Security: Actions Needed by DOE to Improve Security of Weapons- 
Grade Nuclear Material at Its Energy, Science and Environment Sites. 
[hyperlink, http://www.gao.gov/products/GAO-05-934T]. Washington, D.C.: 
July 26, 2005. 

Securing U.S. Nuclear Materials: DOE Needs to Take Action to Safely 
Consolidate Plutonium. [hyperlink, 
http://www.gao.gov/products/GAO-05-665]. Washington, D.C.: July 20, 
2005. 

Nuclear Security: DOE's Office of the Under Secretary for Energy, 
Science, and Environment Needs to Take Prompt, Coordinated Action to 
Meet the New Design Basis Threat. [hyperlink, 
http://www.gao.gov/products/GAO-05-611]. Washington, D.C.: July 15, 
2005. 

Nuclear Security: Federal and State Action Needed to Improve Security 
of Sealed Radioactive Sources. [hyperlink, 
http://www.gao.gov/products/GAO-03-804]. Washington, D.C.: August 6, 
2003. 

Radiation Detection Programs Overseas: 

Combating Nuclear Smuggling: Challenges Facing U.S. Efforts to Deploy 
Radiation Detection Equipment in Other Countries and in the United 
States. [hyperlink, http://www.gao.gov/products/GAO-06-558T]. 
Washington, D.C.: March 28, 2006. 

Combating Nuclear Smuggling: Corruption, Maintenance, and Coordination 
Problems Challenge U.S. Efforts to Provide Radiation Detection 
Equipment to Other Countries. [hyperlink, 
http://www.gao.gov/products/GAO-06-311]. Washington, D.C.: March 14, 
2006. 

Preventing Nuclear Smuggling: DOE Has Made Limited Progress in 
Installing Radiation Detection Equipment at Highest Priority Foreign 
Seaports. [hyperlink, http://www.gao.gov/products/GAO-05-375]. 
Washington, D.C.: March 31, 2005. 

Nuclear Nonproliferation: U.S. Efforts to Help Other Countries Combat 
Nuclear Smuggling Need Strengthened Coordination and Planning. 
[hyperlink, http://www.gao.gov/products/GAO-02-426]. Washington, D.C.: 
May 16, 2002. 

Container Security: 

Maritime Security: The SAFE Port Act: Status and Implementation One 
Year Later. [hyperlink, http://www.gao.gov/products/GAO-08-126T]. 
Washington, D.C.: October 30, 2007. 

Maritime Security: Observations on Selected Aspects of the SAFE Port 
Act. [hyperlink, http://www.gao.gov/products/GAO-07-754T]. Washington, 
D.C.: April 26, 2007. 

Homeland Security: Key Cargo Security Programs Can Be Improved. 
[hyperlink, http://www.gao.gov/products/GAO-05-466T]. Washington, D.C.: 
May 26, 2005. 

Maritime Security: Enhancements Made, But Implementation and 
Sustainability Remain Key Challenges. [hyperlink, 
http://www.gao.gov/products/GAO-05-448T]. Washington, D.C.: May 17, 
2005. 

Container Security: A Flexible Staffing Model and Minimum Equipment 
Requirements Would Improve Overseas Targeting and Inspection Efforts. 
[hyperlink, http://www.gao.gov/products/GAO-05-557]. Washington, D.C.: 
April 26, 2005. 

Radiation Detection Technology: 

Combating Nuclear Smuggling: DHS's Phase 3 Test Report on Advanced 
Portal Monitors Does Not Fully Disclose the Limitations of the Test 
Results. [hyperlink, http://www.gao.gov/products/GAO-08-979]. 
Washington, D.C.: September 30, 2008. 

Combating Nuclear Smuggling: DHS's Program to Procure and Deploy 
Advanced Radiation Detection Portal Monitors Is Likely to Exceed the 
Department's Previous Cost Estimates. [hyperlink, 
http://www.gao.gov/products/GAO-08-1108R]. Washington, D.C.: September 
22, 2008. 

Combating Nuclear Smuggling: Additional Actions Needed to Ensure 
Adequate Testing of Next Generation Radiation Detection Equipment. 
[hyperlink, http://www.gao.gov/products/GAO-07-1247T]. Washington, 
D.C.: September 18, 2007. 

Combating Nuclear Smuggling: DHS's Decision to Procure and Deploy the 
Next Generation of Radiation Detection Equipment Is Not Supported by 
Its Cost-Benefit Analysis. [hyperlink, 
http://www.gao.gov/products/GAO-07-581T]. Washington, D.C.: March 14, 
2007. 

Combating Nuclear Smuggling: DNDO Has Not Yet Collected Most of the 
National Laboratories' Test Results on Radiation Portal Monitors in 
Support of DNDO's Testing and Development Program. [hyperlink, 
http://www.gao.gov/products/GAO-07-347R]. Washington, D.C.: March 9, 
2007. 

Combating Nuclear Smuggling: DHS's Cost-Benefit Analysis to Support the 
Purchase of New Radiation Detection Portal Monitors Was Not Based on 
Available Performance Data and Did Not Fully Evaluate All the Monitors' 
Costs and Benefits. [hyperlink, 
http://www.gao.gov/products/GAO-07-133R]. Washington, D.C.: October 17, 
2006. 

Combating Nuclear Terrorism: Federal Efforts to Respond to Nuclear and 
Radiological Threats and to Protect Emergency Response Capabilities 
Could Be Strengthened. [hyperlink, 
http://www.gao.gov/products/GAO-06-1015]. Washington, D.C.: September 
21, 2006. 

Border Security: Investigators Transported Radioactive Sources Across 
Our Nation's Borders at Two Locations. [hyperlink, 
http://www.gao.gov/products/GAO-06-940T]. Washington, D.C.: July 7, 
2006. 

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/products/GAO-06-389]. Washington, D.C.: 
March 22, 2006. 

Technology Assessment: Securing the Transport of Cargo Containers. 
[hyperlink, http://www.gao.gov/products/GAO-06-68SU]. Washington, D.C.: 
January 25, 2006. 

Homeland Security: Limited Progress in Deploying Radiation Detection 
Equipment at U.S. Ports of Entry. [hyperlink, 
http://www.gao.gov/products/GAO-03-963]. Washington, D.C.: September 4, 
2003. 

Nuclear Nonproliferation and Security: 

Nuclear Safety: Construction of the Protective Shelter for the 
Chernobyl Nuclear Reactor Faces Schedule Delays, Potential Cost 
Increases, and Technical Uncertainties. [hyperlink, 
http://www.gao.gov/products/GAO-07-923]. Washington, D.C.: July 19, 
2007. 

Nuclear Nonproliferation: Better Management Controls Needed for Some 
DOE Projects in Russia and Other Countries. [hyperlink, 
http://www.gao.gov/products/GAO-05-828]. Washington, D.C.: August 29, 
2005. 

Cooperative Threat Reduction: DOD Has Improved Its Management and 
Internal Controls, but Challenges Remain. [hyperlink, 
http://www.gao.gov/products/GAO-05-329]. Washington, D.C.: June 30, 
2005. 

Weapons of Mass Destruction: Nonproliferation Programs Need Better 
Integration. [hyperlink, http://www.gao.gov/products/GAO-05-157]. 
Washington, D.C.: January 28, 2005. 

Nuclear Nonproliferation: DOE's Effort to Close Russia's Plutonium 
Production Reactors Faces Challenges, and Final Shutdown Is Uncertain. 
[hyperlink, http://www.gao.gov/products/GAO-04-662]. Washington, D.C.: 
June 4, 2004. 

[End of section] 

Footnotes: 

[1] Pub. L. No. 109-347, section 501, 120 Stat. 1884, 1932 (2006). 

[2] Neither the presidential directive nor the SAFE Port Act, which 
established DNDO and directed the agency to develop a global nuclear 
detection architecture, defined the term "architecture." DNDO has 
interpreted "architecture" as a time-phased, geographic approach to 
reducing the risk of a radiological or nuclear attack. For the purposes 
of this report, we refer to the architecture as a strategy. 

[3] Small maritime craft are vessels less than 300 gross tons and can 
include recreational boats, commercial fishing vessels, and tug boats. 
These vessels are subject to few security regulations. For example, 
they do not have to provide a 96-hour advance notice of arrival. 

[4] International general aviation applies to noncommercial, 
nonmilitary aircraft traveling to the United States from an 
international location. International general aviation aircraft can 
range in size from small planes (such as a Cessna 182) to planes as 
large as a DC-9 or even an Airbus A380. 

[5] GAO, Nuclear Detection: Preliminary Observations on the Domestic 
Nuclear Detection Office's Efforts to Develop a Global Nuclear 
Detection Architecture, [hyperlink, 
http://www.gao.gov/products/GAO-08-999T] (Washington, D.C.: July 16, 
2008). 

[6] See the list of related GAO products at the end of this report. 

[7] [hyperlink, http://www.gao.gov/products/GAO-08-999T]. 

[8] GAO, Nuclear Nonproliferation: Progress Made in Improving Security 
at Russian Nuclear Sites, but the Long-term Sustainability of U.S.- 
Funded Security Upgrades Is Uncertain, [hyperlink, 
http://www.gao.gov/products/GAO-07-404] (Washington, D.C.: Feb. 28, 
2007). 

[9] GAO, Cooperative Threat Reduction: DOD Has Improved Its Management 
and Internal Controls, but Challenges Remain, [hyperlink, 
http://www.gao.gov/products/GAO-05-329] (Washington, D.C.: June 30, 
2005). 

[10] GAO, Combating Nuclear Smuggling: Corruption, Maintenance, and 
Coordination Problems Challenge U.S. Efforts to Provide Radiation 
Detection Equipment to Other Countries, [hyperlink, 
http://www.gao.gov/products/GAO-06-311] (Washington, D.C.: Mar. 14, 
2006). Since its initial deployment of equipment in 1998, the Second 
Line of Defense program has grown to include cooperation with countries 
throughout the Former Soviet Union, Eastern Europe, and the Caucasus, 
providing radiation detection equipment at land border crossings, 
international airports, and feeder seaports. 

[11] GAO, Preventing Nuclear Smuggling: DOE Has Made Limited Progress 
in Installing Radiation Detection Equipment at Highest Priority Foreign 
Seaports, [hyperlink, http://www.gao.gov/products/GAO-05-375] 
(Washington, D.C.: Mar. 31, 2005). 

[12] GAO, Combating Nuclear Smuggling: Additional Actions Needed to 
Ensure Adequate Testing of Next Generation Radiation Detection 
Equipment, [hyperlink, http://www.gao.gov/products/GAO-07-1247T] 
(Washington, D.C.: Sept. 18, 2007). 

[13] GAO, Combating Nuclear Smuggling: DHS's Program to Procure and 
Deploy Advanced Radiation Detection Portal Monitors Is Likely to Exceed 
the Department's Previous Cost Estimates, [hyperlink, 
http://www.gao.gov/products/GAO-08-1108R] (Washington, D.C.: Sept. 22, 
2008). 

[14] The southern U.S. border tests occurred in the Border Patrol's El 
Paso, Texas, and Tucson, Arizona, sectors. The northern U.S. border 
test was planned for the Border Patrol's Swanton, Vermont, sector. 

[15] This number includes the fiscal year 2007 Supplemental 
Appropriation which provided $22 million for aviation initiatives into 
fiscal year 2009. 

[16] 6 U.S.C. section 202. 

[17] From testimony delivered by Vice Admiral Thad Allen on the role of 
Coast Guard in border and maritime security, Committee on 
Appropriations, Subcommittee on Homeland Security, U.S. Senate, Apr. 6, 
2006. 

[18] The state and local agencies are Washington Department of Fish and 
Wildlife, Washington State Patrol, Washington Department of Health, 
Whatcom County Sheriff, Pierce County Sheriff, Seattle Fire Department, 
Seattle Police Department, Port of Seattle Police, Everett Police 
Department, Bainbridge Island Police Department, Port Orchard Police 
Department, Tacoma Police Department, Suquamish Tribal Police, Port of 
Everett, and Skagit County Sheriff. 

[19] [hyperlink, http://www.gao.gov/products/GAO-06-311]. 

[20] U.S. Department of State, Strategic Plan For Interagency 
Coordination of U.S. Government Nuclear Detection Assistance Overseas 
(Washington, D.C., Dec. 1, 2006). 

[21] GAO, Supply Chain Security: Examinations of High-Risk Cargo at 
Foreign Seaports Have Increased, but Improved Data Collection and 
Performance Measures Are Needed, [hyperlink, 
http://www.gao.gov/products/GAO-08-187] (Washington, D.C.: Jan. 25, 
2008). 

[22] GAO, Supply Chain Security: Challenges to Scanning 100 Percent of 
U.S.-Bound Cargo Containers, [hyperlink, 
http://www.gao.gov/products/GAO-08-533T] (Washington, D.C.: June 12, 
2008). 

[23] GAO, Weapons of Mass Destruction: Nonproliferation Programs Need 
Better Integration, [hyperlink, http://www.gao.gov/products/GAO-05-157] 
(Washington, D.C.: Jan. 28, 2005). 

[24] GAO, Nuclear Nonproliferation: Progress Made in Improving Security 
at Russian Nuclear Sites, but the Long-term Sustainability of U.S. 
Funded Security Upgrades Is Uncertain, [hyperlink, 
http://www.gao.gov/products/GAO-07-404] (Washington, D.C.: Feb. 28, 
2007). 

[25] GAO, Combating Nuclear Smuggling: Corruption, Maintenance, and 
Coordination Problems Challenge U.S. Efforts to Provide Radiation 
Detection Equipment to Other Countries, [hyperlink, 
http://www.gao.gov/products/GAO-06-311] (Washington, D.C.: Mar. 14, 
2006). 

[26] GAO, Nonproliferation: U.S. Efforts to Combat Nuclear Networks 
Need Better Data on Proliferation Risks and Program Results, 
[hyperlink, http://www.gao.gov/products/GAO-08-21] (Washington, D.C.: 
Oct. 31, 2007). 

[27] Each state, as well as the District of Columbia, Puerto Rico, the 
Virgin Islands, and Guam, has their own Civil Support Teams and 
California has two. Civil Support Teams are National Guard assets and 
are under the direction of the governor of that state. 

[28] [hyperlink, http://www.gao.gov/products/GAO-08-999T]. 

[29] GAO, Managing for Results: Enhancing Agency Use of Performance 
Information for Management Decision Making, [hyperlink, 
http://www.gao.gov/products/GAO-05-927] (Washington, D.C.: Sept. 9, 
2005); Results-Oriented Government: Practices That Can Help Enhance and 
Sustain Collaboration among Federal Agencies, [hyperlink, 
http://www.gao.gov/products/GAO-06-15] (Washington, D.C.: Oct. 21, 
2005); Combating Terrorism: Observations on National Strategies Related 
to Terrorism, [hyperlink, http://www.gao.gov/products/GAO-03-519T] 
(Washington, D.C.: Mar. 3, 2003); and Executive Guide: Effectively 
Implementing the Government Performance and Results Act, [hyperlink, 
http://www.gao.gov/products/GAO/GGD-96-118] (Washington, D.C.: June 
1996). 

[End of section] 

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