**Gamma Imaging Inspection Systems**

![](media/image1.jpeg){width="5.997916666666667in"
height="1.9743055555555555in"}

July 2004

**Prepared for:**

Applied Technology Division

U.S. Customs and Border Protection

Environmental Program Office

Department of Homeland Security

1300 Pennsylvania Avenue, N.W.

Washington, DC 20229

**Prepared by:**

Organizational Strategies, Inc.

1331 Pennsylvania Avenue NW, Suite 1415

Washington, D.C. 20004

[www.orgstrategies.com](http://www.orgstrategies.com/)

&

General Dynamics -- Advanced Information Systems, Inc.

10455 White Granite Road, Suite 400

Oakton, VA 22124

\(703\) 383-1883

[www.gd-ais.com](http://www.gd-ais.com/)

Executive Summary

**Background:** The United States (U.S.) Customs and Border Protection
(CBP), an agency within the Department of Homeland Security (DHS), helps
to guard the borders of the U.S. The CBP's mission is to ensure all
goods and persons entering and exiting the U.S. do so in compliance with
all U.S. laws and regulations. CBP has the responsibility to regulate
and control the borders against illegal entrants, terrorist entry, drugs
and other contraband. This mission is accomplished primarily through
physical inspection of cargo, conveyances, and persons as they enter the
country. To improve the inspection process, CBP continuously seeks
technological solutions that are cost effective and are safe for both
humans and the environment.

**Purpose and Need:** Historically, cargo entering the United States
from any foreign territory has been subject to physical examination by
the U.S. Government to verify that it complies with U.S. laws and
regulations. After September 11, 2001, a new combined organization of
the U.S. Border Patrol, the Agriculture Inspection, and the U.S. Customs
Service became Customs and Border Protection in the Department of
Homeland Security. The CBP now assumes a leading position in the defense
of Homeland Security to protect the country against terrorists and
weapons of mass destruction.[^1]

A promising new method of conducting inspections involves the use of
Non-Intrusive Inspection (NII) equipment based on technologies such as
low-energy X-ray or low-energy gamma radiation sources to "see" into
cargo containers and identify potential contraband. The Applied
Technology Division (ATD) of CBP has examined gamma-imaging technologies
for their suitability as parts of CBP's inspection program.

**Proposed Action:** This Programmatic Environmental Assessment (PEA)
documents a top-level evaluation of the potential environmental
consequences resulting from deploying, installing, and operating of
gamma imaging systems to inspect cargoes at air, sea and land ports of
entry (POEs) throughout the U.S. and Puerto Rico. The PEA satisfies the
requirements specified in the National Environmental Policy Act of 1969
(NEPA), the Council on Environmental Quality regulations implementing
NEPA, and Department of Homeland Security procedures for NEPA
compliance. NEPA requires Federal agencies to fully understand, and take
into consideration during decision-making, the environmental
consequences of proposed Federal actions.

The Vehicle and Cargo Inspection System (VACIS^®^) is a family of
gamma-imaging systems developed by SAIC, Inc., which provides a
significant NII capability to aid CBP in stemming the flow of contraband
into the U.S. CBP plans to deploy four VACIS^®^ configurations:

1)  A semi-permanent version designed for inspection of motor vehicles
    and cargo containers at CBP POEs, (VACIS^®^II);

2)  A truck-mounted version designed for high-portability inspection of
    motor vehicles and cargo containers (Mobile VACIS^®^);

3)  A fixed version designed specifically for installation along
    railroad rights of way, for the inspection of railroad cars (Rail
    VACIS^®^) and

4)  A fixed pallet (Pallet VACIS^®^) system designed for inspection of
    items stored on pallets and in boxes or crates.

Each VACIS^®^ configuration incorporates a low-energy gamma radiation
source of Cesium-137 (^137^Cs) or Cobalt-60 (^60^Co) in a shielded
enclosure. Each configuration uses a sodium iodide detector array. The
cargo is placed between the source and the detector array. A shutter
mechanism opens allowing gamma radiation to scan the cargo. The detector
array measures any gamma radiation that passes through the cargo. The
amount of gamma radiation detected indicates the thickness and/or
density of the cargo being scanned. This information is made available
at the Customs Inspector's computer display as a shaded image with the
denser material appearing darker, and the less dense material appearing
lighter. The Customs Inspector, using his/her training and experience,
visually evaluates the shaded image using the density, location, and
shape of the components of the image to identify possible contraband
such as drugs, weapons, or other illegally imported items.

**Alternatives Considered:** The PEA considers the environmental
consequences of:

-   The Proposed Action (fielding and operation of the VACIS^®^),

-   The No-Action Alternative, and

-   Other Alternatives considered but not carried forward.

A summary of the analysis and mitigation to be implemented in this PEA
regarding the potential environmental consequences resulting from the
proposed action is detailed below:

**Geology and Soils** -- Implementing the proposed action will not
impact geology. Potential impacts related to geology and soils are
primarily related to construction of structures in geologically
sensitive areas, to geohazards and potential earthquake damage to
proposed new facilities, and to possible impacts to soils, depending on
facility siting and construction requirements. Potential impacts to
soils from construction activities will be minimized through
implementing best management practices to minimize sedimentation and
provide erosion control.

**Hydrology and Water Quality** -- Construction related to the
installation of VACIS^®^ has the potential to cause increased runoff and
sedimentation during construction, and in the period between
construction and vegetation re-establishment. Erosion and sedimentation
control plans and a stormwater management plan will be prepared and
implemented to limit impacts to water quality from implementing the
proposed action. Because of the small scale associated with VACIS^®^,
increased surface runoff will be negligible. No impacts to hydrology
will occur from the proposed action.

**Floodplain** -- Floodplains are not expected to be impacted by the
proposed action.

**Wetlands** -- Wetlands are not expected to be impacted by the proposed
action.

**Coastal Zone** -- The Coastal Zone is not expected to be impacted by
the proposed action.

**Vegetation and Wildlife** -- No significant loss of habitat will occur
by implementing the proposed action. Impacts to wildlife are minimal,
limited to those temporary activities related to construction of
structures.

**Threatened and Endangered Species** -- Implementing the proposed
action will not impact Federal or state threatened or endangered
species.

**Air Quality** -- Implementing the proposed action will not have a
significant impact on air quality. Construction-related activities may
result in a temporary increase in air emissions. Minor impacts to air
quality are considered as the combination of temporary
construction-related emissions, transportation-related (vehicle idling)
emissions, and any system operation-related emissions.

**Noise** -- Minor modifications and improvements to existing
structures, and construction of new facilities, may create temporary
noise impacts. Noise associated with the operation of VACIS^®^II, Mobile
and Pallet VACIS^®^ is within limits established by the Occupational
Safety and Health Administration (OSHA). Similarly, noise from the
Mobile VACIS^®^ is not expected to exceed limits from EPA Noise Control
Act regulations in Title 40 Code of Federal Regulations (CFR) Part 205,
"Transportation Equipment Noise Emission Controls." Noise associated
with Rail VACIS^®^ operations will be the loudest of the four VACIS^®^
configurations. Although OSHA noise limits are not expected to be
measured above the regulatory "action level" (i.e., 85 dBA for an 8-hour
work shift), it is possible that transient loud noise from the movement
of railroad locomotives and cars may require operators (i.e., Customs
Inspectors) to wear acceptable hearing protection equipment during those
parts of Rail VACIS^®^ operations. None of the VACIS^®^ configurations
are anticipated to violate local Nuisance Noise ordinances.

**Land Use** -- None of the fielding sites associated with the proposed
action are located in prime farmland. Implementing the proposed action
is consistent with current and proposed land uses.

**Infrastructure/Utilities** -- Implementing the proposed action at any
of the sites is not expected to have a significant impact on
infrastructure or affect communities' requirements for public utilities.

**Traffic/Transportation** -- Implementing the proposed action will have
a negligible impact on traffic.

**Hazardous Wastes/Materials** -- The proposed action represents a small
increase in the amount of hazardous substances currently generated. Any
hazardous materials generated will be collected and disposed of in
accordance with Federal and state regulations.

**Historic and Archaeological (Cultural) Resources** -- Implementing the
proposed action is not expected to have an impact on cultural or
historic resources.

**Radiological Consequences** -- As promulgated by the Nuclear
Regulatory Commission in Title 10 CFR Part 20, the maximum permissible
level of radiation dose to the general public in unrestricted areas is
100 mrem (100,000 µrem) per year. CBP has chosen this same radiation
dose standard as the maximum permissible level for Customs Inspectors.
Based upon CBP's chosen criterion of 2000 hours per year as the time of
exposure, neither Customs Inspectors nor the general public will
experience a dose greater than 0.05 mrem (50 µrem) per hour above
natural and man-made background radiation. The radiation dose from
VACIS^®^ will be limited to no more than 0.05 mrem (50 µrem) per hour
through the establishment of radiation safety exclusion zones.

**Conclusion** -- After considering all of the aforementioned factors
and issues, this PEA concludes that VACIS^®^ will not significantly
affect the physical, cultural, or socioeconomic environments.
Site-specific analyses will be performed for each location in the U.S.
or Puerto Rico, where CBP installs VACIS^®^II, Mobile VACIS^®^, Pallet
VACIS^®^ and/or Rail VACIS^®^. Each site-specific analysis, if
necessary, will be reported in a Supplemental Environmental Document,
which will tier off of this PEA in accordance with 40 CFR Part 1508.28.

Table of Contents

[1 Introduction 10](#introduction)

[1.1 Background 10](#background)

[1.2 Why A Programmatic Environmental Assessment
12](#why-a-programmatic-environmental-assessment)

[1.3 Programmatic Process 13](#programmatic-process)

[1.3.1 Cumulative Impacts 13](#cumulative-impacts)

[2 System Description 14](#system-description)

[2.1 VACIS^®^II 16](#vacisii)

[2.1.1 Functional Characteristics 16](#functional-characteristics)

[2.1.2 Operational Procedures 21](#operational-procedures)

[2.2 MOBILE VACIS^®^ 22](#mobile-vacis)

[2.2.1 Functional Characteristics 22](#functional-characteristics-1)

[2.2.2 Operational Procedures 23](#operational-procedures-1)

[2.3 RAIL VACIS^®^ 25](#rail-vacis)

[2.3.1 Functional Characteristics 25](#functional-characteristics-2)

[2.3.2 Operational Procedures 26](#operational-procedures-2)

[2.4 PALLET VACIS^®^ 27](#pallet-vacis)

[2.4.1 Functional Characteristics 27](#functional-characteristics-3)

[2.4.2 Operational Procedures 28](#operational-procedures-3)

[3 Purpose and Need for the Action 31](#purpose-and-need-for-the-action)

[3.1 PURPOSE 31](#purpose)

[3.2 NEED 31](#need)

[4 The Proposed Action and Alternatives
33](#the-proposed-action-and-alternatives)

[4.1 FIELDING AND OPERATION OF VACIS^®^ GAMMA IMAGING SYSTEM (Proposed
Action)
33](#fielding-and-operation-of-vacis-gamma-imaging-system-proposed-action)

[4.2 ALTERNATIVES TO THE PROPOSED ACTION
34](#alternatives-to-the-proposed-action)

[4.2.1 No Action Alternative 34](#no-action-alternative)

[4.2.2 Field a Gamma Imaging System other than VACIS
34](#field-a-gamma-imaging-system-other-than-vacis)

[5 The Affected Environment 36](#the-affected-environment)

[5.1 CONSULTATIONS 36](#consultations)

[5.1.1 Coastal Zone Protection 36](#coastal-zone-protection)

[5.1.2 Protection of Wetlands, and Floodplain Management
37](#protection-of-wetlands-and-floodplain-management)

[5.1.3 Endangered Species Protection 37](#endangered-species-protection)

[5.1.4 Historic and Archaeological Resources Protection
37](#historic-and-archaeological-resources-protection)

[5.2 GEOLOGY AND SOILS 38](#geology-and-soils)

[5.3 AIR QUALITY 38](#air-quality)

[5.3.1 Air Quality Management 38](#air-quality-management)

[5.3.2 Applicable Air Quality Statutes
38](#applicable-air-quality-statutes)

[5.3.3 Air Quality for the Criteria Air Pollutants
39](#air-quality-for-the-criteria-air-pollutants)

[5.4 HYDROLOGY AND WATER QUALITY 40](#hydrology-and-water-quality)

[5.4.1 Federal Requirements 40](#federal-requirements)

[5.4.2 State Requirements 40](#state-requirements)

[5.4.3 County and City Requirements 41](#county-and-city-requirements)

[5.5 FLOODPLAINS 41](#floodplains)

[5.6 THREATENED AND ENDANGERED SPECIES
42](#threatened-and-endangered-species)

[5.7 CULTURAL RESOURCES 42](#cultural-resources)

[5.8 SOCIOECONOMICS 42](#socioeconomics)

[5.9 LAND USE AND ZONING 43](#land-use-and-zoning)

[5.10 PUBLIC SERVICES AND PUBLIC SAFETY
43](#public-services-and-public-safety)

[5.11 TRANSPORTATION 43](#transportation)

[5.12 NOISE 44](#noise)

[5.13 HAZARDOUS MATERIALS AND WASTES
45](#hazardous-materials-and-wastes)

[6 Environmental Consequences 46](#environmental-consequences)

[6.1 GEOLOGY AND SOILS 46](#geology-and-soils-1)

[6.1.1 No Action Alternative 46](#no-action-alternative-1)

[6.1.2 Fielding and Operation of VACIS^®^
46](#fielding-and-operation-of-vacis)

[6.2 AIR QUALITY 47](#air-quality-1)

[6.2.1 No Action Alternative 47](#no-action-alternative-2)

[6.2.2 Fielding and Operation of VACIS^®^
47](#fielding-and-operation-of-vacis-1)

[6.2.3 Idling Vehicle Emissions Calculations
47](#idling-vehicle-emissions-calculations)

[6.2.3.1 Particulate Matter Emissions 49](#particulate-matter-emissions)

[6.2.3.2 Potential Vehicle Idling Emissions Resulting from the Operation
of VACIS^®^
50](#potential-vehicle-idling-emissions-resulting-from-the-operation-of-vacis)

[6.2.4 Worst Case Idling Vehicle Emissions
53](#worst-case-idling-vehicle-emissions)

[6.3 HYDROLOGY AND WATER QUALITY 55](#hydrology-and-water-quality-1)

[6.3.1 No Action Alternative 55](#no-action-alternative-3)

[6.3.2 Fielding and Operation of VACIS^®^
55](#fielding-and-operation-of-vacis-2)

[6.4 FLOODPLAINS 55](#floodplains-1)

[6.4.1 No Action Alternative 55](#no-action-alternative-4)

[6.4.2 Fielding and Operation of VACIS^®^
55](#fielding-and-operation-of-vacis-3)

[6.5 BIOLOGICAL RESOURCES 56](#biological-resources)

[6.5.1 No Action Alternative 56](#no-action-alternative-5)

[6.5.2 Fielding and Operation of VACIS^®^
56](#fielding-and-operation-of-vacis-4)

[6.6 THREATENED AND ENDANGERED SPECIES
56](#threatened-and-endangered-species-1)

[6.6.1 No Action Alternative 56](#no-action-alternative-6)

[6.6.2 Fielding and Operation of VACIS^®^
56](#fielding-and-operation-of-vacis-5)

[6.7 CULTURAL RESOURCES 57](#cultural-resources-1)

[6.7.1 No Action Alternative 57](#no-action-alternative-7)

[6.7.2 Fielding and Operation of VACIS^®^
57](#fielding-and-operation-of-vacis-6)

[6.8 SOCIOECONOMICS 57](#socioeconomics-1)

[6.8.1 No Action Alternative 57](#no-action-alternative-8)

[6.8.2 Fielding and Operation of VACIS^®^
57](#fielding-and-operation-of-vacis-7)

[6.9 LAND USE AND ZONING 58](#land-use-and-zoning-1)

[6.9.1 No Action Alternative 58](#no-action-alternative-9)

[6.9.2 Fielding and Operation of VACIS^®^
58](#fielding-and-operation-of-vacis-8)

[6.10 PUBLIC SERVICES 58](#public-services)

[6.10.1 No Action Alternative 58](#no-action-alternative-10)

[6.10.2 Fielding and Operation of VACIS^®^
58](#fielding-and-operation-of-vacis-9)

[6.11 TRANSPORTATION 58](#transportation-1)

[6.11.1 No Action Alternative 58](#no-action-alternative-11)

[6.11.2 Fielding and Operation of VACIS^®^
59](#fielding-and-operation-of-vacis-10)

[6.12 NOISE 59](#noise-1)

[6.12.1 No Action Alternative 59](#no-action-alternative-12)

[6.12.2 Fielding and Operation of VACIS^®^
59](#fielding-and-operation-of-vacis-11)

[6.13 HAZARDOUS MATERIALS AND WASTES
60](#hazardous-materials-and-wastes-1)

[6.13.1 No Action Alternative 60](#no-action-alternative-13)

[6.13.2 Fielding and Operation of VACIS^®^
60](#fielding-and-operation-of-vacis-12)

[6.14 RADIOLOGICAL IMPACTS 60](#radiological-impacts)

[6.14.1 No Action Alternative 60](#no-action-alternative-14)

[6.14.2 Fielding and Operation of VACIS^®^
60](#fielding-and-operation-of-vacis-13)

[6.14.2.1 Regulations and Dose Criteria
61](#regulations-and-dose-criteria)

[6.14.2.2 Exposure Pathways 62](#exposure-pathways)

[6.14.2.3 Radiation Safety Exclusion Zones
62](#radiation-safety-exclusion-zones)

[6.14.2.3.1 VACIS^®^ II 63](#vacis-ii)

[6.14.2.3.2 Mobile VACIS^®^ 63](#mobile-vacis-1)

[6.14.2.3.3 Rail VACIS^®^ 63](#rail-vacis-1)

[6.14.2.3.4 Pallet VACIS^®^ 63](#pallet-vacis-1)

[6.14.2.4 Effects of Irradiation on Cargo
63](#effects-of-irradiation-on-cargo)

[6.14.2.5 Effects of Irradiation on Persons
64](#effects-of-irradiation-on-persons)

[6.14.2.6 Source Material Operations 69](#source-material-operations)

[6.14.2.6.1 Transportation 69](#transportation-2)

[6.14.2.6.2 Installation 70](#installation)

[6.14.2.6.3 Maintenance 70](#maintenance)

[6.14.2.6.4 Disposal 70](#disposal)

[6.14.2.7 Effects of Accidents 71](#effects-of-accidents)

[6.14.2.8 Radiation Safety 71](#radiation-safety)

[6.14.2.9 Licensing 71](#licensing)

[7 Decommissioning Planning 73](#decommissioning-planning)

[8. Persons and Organizations Contacted
75](#persons-and-organizations-contacted)

[9. Acronyms and Abbreviations 77](#acronyms-and-abbreviations)

[10. List of Preparers 82](#list-of-preparers)

[11. Distribution List 84](#distribution-list)

[Appendix "A" 89](#__RefHeading___Toc77770063)

[Appendix "B" 90](#__RefHeading___Toc77770064)

[Appendix "C" 91](#__RefHeading___Toc77770065)

[Appendix "D" 92](#__RefHeading___Toc77770066)

[Appendix "E" 93](#__RefHeading___Toc77770067)

List of Appendices

  -------------- ----------------------------------------------------------
  **Appendix**   **Title**

  Appendix A     Public Comments

  Appendix B     Registry of Radioactive Sealed Sources and Devices; Safety
                 Evaluation of Device; Model -- VACIS^®^II; No.
                 CA0215D104B; Date -- 30 July 2003

  Appendix C     Registry of Radioactive Sealed Sources and Devices; Safety
                 Evaluation of Device; Model -- Mobile VACIS^®^; No.
                 CA0215D103S; Date -- 24 August 2000

  Appendix D     Recommended Operating Procedures for the Vehicle and Cargo
                 Inspection System (VACIS^®^)

  Appendix E     NRC Materials License for ^137^Cs/^60^Co Sealed Sources
                 (License No. 08-17447-01, Amendment 25)
  -------------- ----------------------------------------------------------

List of Figures

[Figure 1: VACIS^®^II scanning a tractor-trailer
17](#__RefHeading___Toc66788484)

[Figure 2: Typical VACIS^®^II fixed operator station
18](#__RefHeading___Toc66788485)

[Figure 3: Typical VACIS^®^II mobile operator station
19](#__RefHeading___Toc66788486)

[Figure 4: Typical building suitable for housing VACIS^®^II installation
20](#__RefHeading___Toc66788487)

[Figure 5: Mobile VACIS^®^ scanning a cargo container
22](#__RefHeading___Toc66788488)

[Figure 6: Typical Rail VACIS^®^ installation
26](#__RefHeading___Toc66788489)

[Figure 7: Pallet VACIS^®^ 28](#__RefHeading___Toc66788490)

[Figure 8: VACIS^®^II radiation safety exclusion zone
65](#__RefHeading___Toc66788491)

[Figure 9: Mobile VACIS^®^ radiation safety exclusion zone
66](#__RefHeading___Toc66788492)

[Figure 10: Rail VACIS^®^ radiation safety exclusion zone
67](#__RefHeading___Toc66788493)

[Figure 11: Pallet VACIS^®^ radiation safety exclusion zone
68](#__RefHeading___Toc66788494)

List of Tables

[Table I: Source variants offered for VACIS^®^
15](#__RefHeading___Toc66181301)

[Table II: National Ambient Air Quality Standards
39](#__RefHeading___Toc66181302)

[Table III: Idle emission factors, winter conditions (30° F, 13.0 psi
RVP gasoline). 48](#__RefHeading___Toc66181303)

[Table IV: Idle emission factors, summer conditions (75° F, 9.0 psi RVP
gasoline). 49](#__RefHeading___Toc66181304)

[Table V: Particulate matter emission factors
49](#__RefHeading___Toc66181305)

[Table VI: Idling emissions, winter conditions (30° F 13.0 psi RVP
gasoline), January-June 51](#__RefHeading___Toc66181306)

[Table VII: Idling emissions, summer conditions (75° F 9.0 psi RVP
gasoline), July-December 52](#__RefHeading___Toc66181307)

[Table VIII: Particulate matter emissions (PM10), January-December
53](#__RefHeading___Toc66181308)

[Table IX: Worst case idling vehicle emissions
53](#__RefHeading___Toc66181309)

[Table X: Conformity criteria for nonattainment areas
53](#__RefHeading___Toc66181310)

[Table XI: Conformity criteria for maintenance areas
54](#__RefHeading___Toc66181311)

[Table XII: Mobile VACIS^®^ noise measurement data
59](#__RefHeading___Toc66181312)

[Table XIII: VACIS^®^ radiation dose measurement data
69](#__RefHeading___Toc66181313)

[Table XIV: Body dose accident data 71](#__RefHeading___Toc66181314)

# Introduction

## Background

The Department of Homeland Security (DHS) was established in the
aftermath of the terrorist attacks of September 11^th^, 2001. The
department has three primary missions:

-   Prevent terrorist attacks within the United States,

-   Reduce America\'s vulnerability to terrorism, and

-   Minimize the damage from potential attacks and natural disasters.

The US Customs and Border Protection (CBP) became an official agency
within the DHS on March 1, 2003, combining employees from the Department
of Agriculture, the Immigration and Naturalization Service, the Border
Patrol, and the U.S. Customs Service. As the Nation's principal border
agency, the mission of CBP is to ensure goods and persons entering and
exiting the U.S. do so in compliance with all U.S. laws and regulations.
Of particular concern is the large number of cargo containers that enter
the country everyday. As CBP's Commissioner Robert C. Bonner, described
in testimony:[^2]

> "Because of the sheer volume of sea container traffic and the
> opportunities it presents for terrorists, containerized shipping is
> uniquely vulnerable to terrorist attack. Many national security
> experts believe that a terrorist attack using a container as a weapon
> or as a means to smuggle a terrorist weapon, possibly a weapon of mass
> destruction, is likely. These experts have pointed out that if
> terrorists use a sea container to conceal a weapon of mass destruction
> and detonate it on arrival at a port, the impact on global trade and
> the global economy would be immediate and potentially devastating -
> the economies of all nations could be adversely affected.
>
> "Given this vulnerable system, we realized the need to develop and
> implement a program that would enable us to better secure
> containerized shipping - the most important means of global commerce -
> against the terrorist threat. That program, which Customs proposed in
> January 2002, is the Container Security Initiative (CSI)."

The Container Security Initiative has four core elements:

-   ["First]{.underline}, stationing a team of U.S. Customs targeting
    personnel at foreign ports to identify \"high-risk\" containers
    before they are shipped to the U.S. ...

-   "[Second]{.underline}, pre-screening the \"high-risk\" containers at
    the foreign CSI port [before]{.underline} they are shipped to the
    U.S.

-   "[Third]{.underline}, using technology to pre-screen the high-risk
    containers. This permits the containers to be inspected rapidly
    without slowing down the movement of trade. This includes the use of
    both radiation detectors and large-scale radiographic imaging
    machines in order to detect potential terrorist weapons.

-   "[Fourth]{.underline}, using smarter, \"tamper-evident\" containers.
    ..."

The CBP also intercepts large quantities of contraband at our POEs.
Commissioner Bonner described in testimony: Contraband smuggling is a
serious and continuing problem in the United States (U.S.). For example,
in Fiscal Year 2002 alone, a total of 1,374,100 pounds of marijuana,
167,800 pounds of cocaine, and 4,100 pounds of heroin were seized
nationally by CBP (formerly the U.S. Customs Service (USCS) and the U.S.
Border Patrol (now the Office of Border Patrol, or OBP).[^3] Mr. Bonner
summarized the current OBP mission during a March 3, 2003 speech at the
OBP Change of Command Ceremony:

> *"...We need a strong and effective Border Patrol between our ports of
> entry to enforce the laws of the United States, to apprehend those who
> attempt to enter the United States illegally or attempt to bring in
> illegal drugs or other harmful substances..."*

The CBP is also responsible for apprehending individuals attempting to
enter the United States illegally, protecting agricultural and economic
interests from harmful pests and diseases; protecting American
businesses from theft of their intellectual property; and regulating and
facilitating international trade, collecting import duties, and
enforcing U.S. trade laws.

The CBP's mission is accomplished primarily through physical inspection
of cargo, conveyances, and persons as they enter the country. To improve
the inspection process, CBP continuously seeks technological solutions
that are cost effective and are safe for both humans and the
environment.

A promising new method of conducting inspections involves the use of NII
techniques, which employ technologies such as low-energy X-ray or
low-energy gamma radiation sources to "see" into cargo containers and
identify potential contraband. NII technologies allow Customs Inspectors
to inspect for contraband without having to physically enter into or
unload motor vehicles or containers. The effective and efficient
screening and processing of cargo, conveyances, and persons will allow
CBP to focus the bulk of its anti-smuggling and trade enforcement
resources on suspected and actual law violators, thereby increasing both
the potential and the reality of detection. Strategically placing these
systems at ports of entry (POEs) will provide an effective barrier along
the borders and will force smugglers to take higher risks to bring
contraband into the US, increasing the chance of interception.[^4]

As part of this multi-technology approach to combating the smuggling of
illicit drugs and contraband into the US, the Vehicle and Cargo
Inspection System (VACIS^®^) fulfills the current NII technology
requirement for gamma imaging technology identified in the *Ten-Year
Counterdrug Technology Plan and Development Roadmap*.

The CBP plan to shield the U.S. borders against drugs and other
contraband, by decreasing the probability of smuggling through POEs, is
enhanced by the introduction of VACIS^®^. This project provides a vital
element in CBP counterdrug and enforcement responsibilities. The
VACIS^®^ increases enforcement effectiveness and efficiency. The
VACIS^®^ augments the capabilities of the Customs Inspector by acting as
a force multiplier that enables inspectors to increase the quality,
quantity, and scope of their activities. With a projected 160 high
confidence inspections per day, VACIS^®^ is expected to increase the
number of high confidence inspections per day by approximately 615% over
that currently performed without an increase in inspection manpower.[^5]

## Why A Programmatic Environmental Assessment

The National Environmental Policy Act of 1969 (NEPA; 42 U.S.C.
4321-4347, 4372-4375), the Council on Environmental Quality (CEQ)
regulations implementing NEPA (40 Code of Federal Regulations \[CFR\]
Parts 1500 through 1508), and U.S. Treasury Department regulations for
NEPA compliance (Treasury Directive 75-02) directs CBP to fully
understand and take into consideration, during decision-making, the
environmental consequences of proposed Federal actions (projects).
Therefore, CBP must comply with NEPA before making Federal funds
available for the fielding and operation of gamma-ray non-intrusive
imaging equipment.

The NEPA regulations encourage agencies to "tier" their environmental
documents to eliminate repetitive discussions of the same issues and to
focus on the issues germane to the decisions at each level of
environmental review. Fielding and operating gamma imaging systems at
POEs is an undertaking that is nationwide in scope. Some issues
associated with fielding and operating the systems are broad and
relatively site-independent. They can be discussed and assessed without
specific knowledge of the location of the equipment. This document, a
Programmatic Environmental Assessment (PEA), fulfills that requirement.

Other issues are comparatively site-specific. These issues depend on
local conditions such as proximity to waterways or wildlife migratory
routes. For each operating location, site-specific information will be
collected and assembled into a site-specific Supplemental Environmental
Document (SED). The SED, in combination with the PEA, will assist
decision makers in assessing environmental consequences at the local
level, as described below.

## Programmatic Process

This PEA covers typical actions for the acquisition, fielding, and
operation of gamma-ray non-intrusive imaging equipment for use by the
CBP at sea, air, and land POEs. Because actions proposed for funding
under this PEA and impacts of these actions can vary based on location
and other site-specific criteria, a SED can be prepared for individual
VACIS^®^ projects. The resulting SEDs will tier off of this PEA in
accordance with 40 CFR Part 1508.28 when necessary. During the
preparation of a SED other environmental reviews may fulfill the
requirements of NEPA. Projects that contain elements or actions not
evaluated in this PEA can also be evaluated with a Categorical Exclusion
(CE), an Environmental Assessment (EA), or an Environmental Impact
Statement (EIS) as appropriate.

### Cumulative Impacts

Per 40 CFR 1508.7:

> > "Cumulative impact is the impact on the environment which results
> > from the incremental impact of the action when added to other past,
> > present, and reasonably foreseeable future actions regardless of
> > what agency (Federal or non-Federal) or person undertakes such other
> > actions. Cumulative impacts can result from individually minor but
> > collectively significant actions taking place over a period of
> > time."

Cumulative impacts resulting from site-specific fielding of individual
gamma imaging systems are not addressed in this PEA because analysis of
these impacts requires specific knowledge of other projects occurring
within or near the operating area. Cumulative impacts will be addressed
in each site-specific SED.

# System Description

The CBP plans to deploy four VACIS^®^ configurations:

1)  A semi-permanent version designed for inspection of motor vehicles
    and cargo containers (VACIS^®^II);

2)  A truck-mounted version designed for high-portability inspection of
    motor vehicles and cargo containers (Mobile VACIS^®^);

3)  A fixed version designed specifically for installation along
    railroad rights of way for the inspection of railroad cars (Rail
    VACIS^®^); and

4)  A fixed pallet (Pallet VACIS^®^) system designed for inspection of
    items stored on pallets and in boxes or crates.

Each VACIS^®^ configuration incorporates a low-energy radiation fixed
gauge comprising a gamma radiation source in a shielded enclosure, and a
sodium iodide detector array mounted between 15 and 30-feet from the
source. The cargo to be scanned is placed between the source and the
detector array. The radiation source is housed in a self-contained,
fireproof tungsten casing with a motor-driven lead aperture (shutter).
Depending on the VACIS^®^ configuration, either one shutter or two
shutters (primary shutter and secondary shutter) are opened, allowing
gamma radiation to scan the cargo. The detector array on the opposite
side of the cargo measures any gamma radiation that passes through the
cargo. The amount of gamma radiation detected indicates the thickness
and/or density of the cargo being scanned. This information is made
available at the operator's computer display as a shaded image, with the
denser material appearing darker and the less dense material appearing
lighter. The Customs and Border Protection Inspector, using his/her
training and experience, visually evaluates the shaded image using the
density, location, and shape of the components of the image to identify
possible contraband such as drugs, guns, or other imported contraband.

The radiation source used in all VACIS^®^ configurations is Cesium-137
(^137^Cs) or Cobalt-60 (^60^Co) with an activity of between 0.5 and 2.0
curies, depending on the VACIS^®^ configuration. Each VACIS^®^
configuration uses a different amount of source material, based mainly
on the speed at which the cargo to be scanned passes through the gamma
radiation. Increasing the curie level of the radiation source allows for
a higher cargo scan speed. Additionally, increasing the curie level of
the radiation source allows for a slightly greater degree of penetration
of the cargo. A tradeoff associated with increasing the curie level of
radiation is that, as a result, the cargo experiences an increased level
of radiation exposure. In all VACIS^®^ configurations, the ^137^Cs
source is expected to have an operational life of 15 years[^6],[^7] and
^60^Co has an operational life of 5 years.

Based on the aforementioned radiation source characteristics, VACIS^®^II
will employ 1.0 curie of ^137^Cs because it will be used primarily for
controlled, low-speed scanning of truck bodies and intermodal containers
that are composed of relatively thin metal. Rail VACIS^®^, on the other
hand, will be used to scan moving freight train rail cars with a speed
ranging from 0.5 to 5.0 miles per hour and whose construction may employ
thick metal. Hence, Rail VACIS^®^ will employ a 2.0-curie ^137^Cs
radiation source. Mobile VACIS^®^ has an essentially "in the middle"
radiation source requirement in that it will be used to scan cargo
(primarily trucks, intermodal containers, and some rail cars) at a speed
not quite as controlled and as slow as VACIS^®^ II, but not as variable
and as fast as Rail VACIS^®^. Because of this, Mobile VACIS^®^ will
employ 1.0 curies of ^137^Cs. The cargo that is normally scanned by the
Pallet VACIS^®^ tends to be fruits and vegetables that contain higher
water content; it was found that the Cesium source was not consistent
enough and was replaced with 0.5 curies of Cobalt (the smallest amount
of the four VACIS^®^ variants). Table I shows the number of curies
available offered for use in each VACIS^®^ variant.

[]{#__RefHeading___Toc66181301 .anchor}**Table I: Source variants
offered for VACIS^®^**

  ------------------------------------------------------------------------
  VACIS Configuration      Source Isotope      Source Activity (curies)
  ------------------------ ------------------- ---------------------------
  VACIS^®^II               Cesium-137          1.0

                           Cobalt-60           0.75

  Mobile VACIS^®^          Cesium-137          1.0

                           Cobalt-60           0.75

  Rail VACIS^®^            Cesium-137          2.0

                           Cobalt-60           1.0

  Pallet VACIS^®^          Cesium-137          0.5

                           Cobalt-60           0.25
  ------------------------------------------------------------------------

*(Source:* SAIC Safety & Security Products; available at
<http://www.saic.com/products/security>; Internet, accessed 19 February
2004)

Radiation safety exclusion zones have been established for the
VACIS^®^II, Mobile VACIS^®^, Rail VACIS^®^ and Pallet VACIS^®^ systems
in order to limit the radiation dose to no more than 0.05 mrem (50 µrem)
per hour above typical background/man-made radiation. The radiation
safety exclusion zones for the four VACIS^®^ configurations were
established from field measurements conducted by a Certified Health
Physicist.[^8] People and live animals would not intentionally be
allowed in the radiation safety exclusion zones during VACIS^®^
operations.

It should be noted that although it is a new application for CBP, the
radioactive fixed gauge has been used successfully and safely in
industry for many years, including measuring the thickness of paper
produced in paper mills and ensuring that bottles are filled to the
proper level in mass-production facilities such as beer breweries. Fixed
gauges specifically incorporating ^137^Cs are used in industrial
applications including measuring and controlling liquid flow in
pipelines, and as a density gauge in determining whether oil wells are
plugged by sand.

Detailed descriptions of the four VACIS^®^ configurations are provided
in the following subsections.

## VACIS^®^II

### Functional Characteristics

A representative photograph of a VACIS^®^II installation is shown in
Figure 1**.** A close-up photograph of a typical fixed VACIS^®^II
operator station is shown in **Figure 2**. A photograph of a typical
VACIS^®^II mobile operator station (e.g., recreational vehicle) is shown
in Figure 3. VACIS^®^II consists of two 90-foot long tracks that are
placed, in parallel, 30 feet apart. On one track is the radiation source
(1.0 curie of ^137^Cs or 0.75 curie of ^60^Co) and on the opposite track
is a 21-foot tall tower containing the sodium iodide detector array
sensors. During operation, the motor vehicle to be inspected parks
between the two tracks, and the driver exits the vehicle and is escorted
to a safe waiting area. The radiation source and the detector array
tower begin moving, in synchronized fashion, down the tracks as the scan
sequence is begun by the VACIS^®^II operator. The gamma rays are emitted
from the source, pass through the vehicle, and are detected by the
tower-mounted sensor array. The scan image is processed in the
VACIS^®^II operator station and displayed on a monitor for operator
identification of cargo density anomalies that may indicate suspected
contraband. Images of suspected contraband may be stored on the system
computer for potential use as evidence in smuggling prosecution cases.
The VACIS^®^II equipment runs on externally-supplied household
electrical power, requiring two 120 VAC, 20 A, 60 Hz circuits.

VACIS^®^II incorporates two radioactive source shutters, designated
primary and secondary, which are physically aligned so that the
secondary shutter is directly in front of the primary shutter. Each
shutter, alone, is sufficient to block the source radiation, and the
two-shutter system provides redundancy to enhance safety. During
operation, the primary shutter is opened and remains open, while the
secondary shutter is opened to commence a scan and closed to end the
scan. VACIS^®^II has an average scanning time of one foot per second and
an average inspection time of 2 to 3 minutes per vehicle. It is capable
of scanning objects up to 8.5 feet wide by 70 feet long, with a maximum
height of 14 feet. The exposed parts of VACIS^®^II are constructed of
stainless steel, providing resistance to rain, high humidity, and
moderate wind. The system can operate in temperatures ranging from 0 to
120° F.

At those sites where the weather is often particularly harsh, the entire
VACIS^®^II installation may be located in an existing or newly
constructed building. A typical building suitable for use in this
application is shown in Figure 4.

![](media/image2.jpeg){width="7.405555555555556in"
height="4.986805555555556in"}***Photograph Courtesy of SAIC***

[]{#__RefHeading___Toc66788484 .anchor}**Figure 1: VACIS**^®^**II
scanning a tractor-trailer**

![](media/image3.jpeg){width="6.433333333333334in"
height="5.0in"}***Customs and Border Protection Photograph***

> []{#__RefHeading___Toc66788485 .anchor}**Figure 2: Typical
> VACIS**^®^**II** **fixed operator station**

![](media/image4.jpeg){width="6.381944444444445in"
height="4.801388888888889in"}***Customs and Border Protection
Photograph***

[]{#__RefHeading___Toc66788486 .anchor}Figure 3: Typical VACIS^®^II
mobile operator station

![](media/image5.jpeg){width="6.252777777777778in"
height="4.854861111111111in"} ***Customs and Border Protection
Photograph***

[]{#__RefHeading___Toc66788487 .anchor}**Figure 4: Typical building
suitable for housing VACIS**^®^**II installation**

In order to accommodate the radiation safety exclusion zone discussed in
Section 6.14.2.3.1, each VACIS^®^ II installation will require a
rectangular footprint area measuring 110 feet x 65 feet, exclusive of
the operator station or any associated buildings.[^9]

The VACIS^®^II is equipped with several safety features to prevent
injury. These consist of flashing lights and an audible alarm indicating
when radiation is being emitted; micro-switches and shock absorbers at
the end of the track to prevent trolley over-travel; and emergency
shut-off buttons located in six different locations. The secondary
shutter closes automatically when the source or detector array tower
reaches the end of their pre-selected scan distance, and also
automatically closes in the event that the source or detector array
tower reaches the end of the track. The system operator may also
manually close the shutter from the operator station. Both the primary
and secondary shutters are of fail-safe designs, whereby each shutter
will automatically close upon loss of electric power to the VACIS^®^
equipment. The primary shutter is designed so that a padlock may be used
to secure the source in the OFF position.

### Operational Procedures

The basic VACIS^®^II operating steps are as follows:

1)  A radiation safety exclusion zone is established around the
    VACIS^®^II installation. The radiation safety exclusion zone is
    demarcated with rope or barriers and signage.

2)  At the start of a shift, the primary shutter is unlocked and the
    computer system is turned on. A key is needed to operate the primary
    shutter from the shutter control box located in the operator
    station.

3)  The system operator tests the primary and secondary shutters, and
    the associated indicating lights located in the operator station.

4)  The primary shutter is opened and kept opened throughout a shift.

5)  The secondary shutter is opened, and the area is surveyed to verify
    exposure rates outside the radiation safety exclusion zone are less
    than 0.05 mrem (50 µrem) per hour. The exposure rate shall be
    measured by a qualified operator using a calibrated survey meter.

6)  Traffic control personnel direct the driver of the motor vehicle to
    be scanned to drive into the area between the VACIS^®^II source and
    detector array tower tracks, and to park the vehicle.

7)  Traffic control personnel escort the driver/passengers of the
    vehicle to be scanned to a point outside of the radiation safety
    exclusion zone area and questions the driver whether there are any
    remaining persons and/or animals in the vehicle. If the driver
    indicates that there are, then the vehicle is not scanned and is
    identified for further detailed manual inspection. If the driver
    falsely indicates that there are no remaining persons and/or animals
    in the vehicle when in fact there are, and if the vehicle is
    subsequently scanned using VACIS^®^II, the remaining persons and/or
    animals will unintentionally be scanned along with the vehicle.
    However, they will receive only a very small radiation dose, as
    described in Section 6.14.1.5 (Effects of Irradiation on Persons).

8)  The system operator verifies there are no persons within the
    radiation safety exclusion zone.

9)  The system operator starts the scan from the computer. This opens
    the secondary shutter on the radiation source, and initiates the
    synchronous movement of the source and detector array tower along
    the length of the vehicle.

10) A density map is stored. The system operator inspects the density
    map to identify any contraband or potential contraband storage
    locations.

11) After the audible alarm has stopped sounding and the red indicator
    lights have stopped flashing, indicating that the secondary shutter
    is closed, the driver is escorted back to the vehicle. The driver is
    then directed to drive the scanned vehicle out of the radiation
    safety exclusion zone.

12) Steps 6 through 11 are repeated for each vehicle undergoing a scan.

13) At the end of a shift, both shutters are closed and the computer
    system is turned off. The key is removed from the shutter control
    box and the primary shutter is padlocked.

## MOBILE VACIS^®^

### Functional Characteristics

A representative photograph of Mobile VACIS^®^ is shown in **Figure 5**.
Mobile VACIS^®^ is similar to VACIS II^®^, except that it is installed
on a flatbed straight truck. The radiation source (also similar to that
used for VACIS^®^II) is located on a boom extending away from the truck,
and the sodium iodide detector array sensors are located on a tower
mounted on the truck. Mobile VACIS^®^ incorporates one source shutter.
The entire system runs on internally supplied household electrical
power, requiring two 120 VAC, 20 A, 60 Hz circuits which are supplied by
an onboard generator and rechargeable truck batteries. The operator
station is located within the cab of the Mobile VACIS^®^.

![](media/image6.jpeg){width="5.0in" height="3.75in"}\
***Photograph Courtesy of SAIC***

[]{#__RefHeading___Toc66788488 .anchor}Figure 5: Mobile VACIS^®^
scanning a cargo container

In order to accommodate the radiation safety exclusion zone discussed in
Section 6.14.1.3.2 (Mobile VACIS^®^), each Mobile VACIS^®^ will require
a square footprint area measuring 50 feet x 50 feet and a height of 17
feet. For storage purposes, a 26 foot long by 8 foot wide area is
required, with a 10 foot, 4 inch ceiling clearance.

Mobile VACIS^®^ is capable of scanning single rows of cargo containers
as well as tractor-trailers at a speed of 88 inches per second (5 miles
per hour). The system is equipped with lights to allow it to operate at
night and can operate in all types of weather.

Mobile VACIS^®^ can scan motor vehicles and cargo containers using two
operational modes:

Fixed Scanning Mode - During the fixed scanning mode of operation, the
Mobile VACIS^®^ parks in one place as motor vehicles to be scanned pull
up under the boom between the radiation source and detector array
sensors, and stop with the passenger cab just past the radiation source.
The VACIS^®^ scanning equipment is then turned on, and the driver of the
vehicle to be scanned slowly moves forward until the vehicle is through
the scan. The scanning equipment is then turned off.

Mobile Scanning Mode -- When in the mobile scanning mode of operation,
the Mobile VACIS^®^ is positioned so that the motor vehicle or cargo to
be scanned is lined up under the boom between the radiation source and
detector array sensors. The Mobile VACIS^®^ is then driven past the
vehicle or cargo container to be scanned, while the VACIS^®^ scanning
equipment is operating. When the Mobile VACIS^®^ reaches the end of the
vehicle or cargo container being scanned, the scanning equipment is
turned off.

In both Mobile VACIS^®^ operational modes, the scan images are sent to a
monitor located inside the truck cab where the operator is located. The
VACIS^®^ operator views the images to identify anomalies that should be
investigated further. The system computer can store these images for
potential use as evidence in smuggling prosecution cases.

At those sites where the weather is often particularly harsh, the entire
Mobile VACIS^®^ may be located and installed in an existing or newly
constructed building. A typical building suitable for use in this
application is shown in **Figure 4**.

Mobile VACIS^®^ is equipped with several safety features to prevent
injury. These consist of flashing lights and an audible alarm indicating
when radiation is being emitted, and emergency shut-off buttons. The
shutter closes automatically at the end of a pre-selected scan time. The
system operator may also manually close the shutter. The shutter is of a
fail-safe design, whereby the shutter will automatically close upon loss
of electric power to the VACIS^®^ equipment. The shutter is designed so
that a padlock may be used to secure the source in the OFF position.

### Operational Procedures

Mobile VACIS^®^ requires two trained operators. The scanning operator
sits in the cab of the Mobile VACIS^®^ and operates the scanning
equipment. The truck operator drives the Mobile VACIS^®^ when in mobile
scanning mode, helps with positioning the vehicle or cargo container to
be scanned, and helps ensure radiation safety (e.g., keeping persons
outside of the radiation safety exclusion zone).

The operating steps provided below are applicable when Mobile VACIS^®^
is in fixed scanning mode and motor vehicles are pulling up to be
scanned. Comparable steps are followed, as appropriate, during mobile
scanning mode operations.

The basic Mobile VACIS^®^ operating steps are as follows:

1)  A radiation safety exclusion zone is set up around the Mobile
    VACIS^®^. The radiation safety exclusion zone is demarcated with
    rope and signage.

2)  Pilasters, lane markers, and associated signage are set up and
    positioned.

3)  The Mobile VACIS^®^ computer system is turned on and the key is used
    to energize the control box. A password is required to access system
    software to open the shutter.

4)  The Mobile VACIS^®^ diesel engine is started.

5)  The shielded storage box that houses the radiation source is
    unlocked, the radiation source is unlocked, and the locking pin is
    removed from the radiation source.

6)  The radiation source and detector array tower are positioned using
    the Mobile VACIS^®^ hydraulic lifts.

7)  The radiation source shutter is opened, and the area is surveyed to
    verify exposure rates outside the radiation safety exclusion zone
    are less than 0.05 mrem (50 µrem) per hour. A qualified operator
    using a calibrated survey meter shall measure the exposure rate.

8)  An operational checklist is completed to ensure the safety lights
    and audible beacon are functioning appropriately and that all
    required signage is in place.

9)  The Mobile VACIS^®^ operator directs the driver of the motor vehicle
    to be scanned to drive forward and position the vehicle under the
    boom between the radiation source and detector array tower.

10) The Mobile VACIS^®^ operator asks the driver of the vehicle to be
    scanned whether there are any remaining persons and/or animals in
    the vehicle. If the driver indicates that there are, then the
    vehicle is not scanned and is identified for further detailed manual
    inspection. If the driver falsely indicates that there are no
    remaining persons and/or animals in the vehicle when in fact there
    are, and if the vehicle is subsequently scanned using Mobile
    VACIS^®^ then the remaining persons and/or animals will
    unintentionally be scanned along with the vehicle. However, they
    will receive only a very small radiation dose, as described in
    Section 6.14.1.5 (Effects of Irradiation on Persons) herein.

11) The Mobile VACIS^®^ operator and scanning operator verify there are
    no persons in the radiation safety exclusion zone.

12) The Mobile VACIS^®^ scanning operator opens the radiation source
    shutter either manually or automatically through system software,
    and a system operator asks the driver of the vehicle being scanned
    to pull forward.

13) A density map of the scanned vehicle is acquired and stored.

14) The radiation source shutter is closed either manually,
    automatically through system software, or by the safety-related
    timeout.

15) The Mobile VACIS^®^ scanning operator inspects the density image to
    identify any anomalies that may indicate the presence of contraband.

16) Steps 9 through 15 are repeated for each vehicle undergoing a scan.

17) At the end of operations, the radiation source shutter is closed and
    the key is removed from the control box. The system computer is
    turned off. The detector array tower and radiation source are
    returned to their storage locations. The radiation source is secured
    within the shielded storage box. The radiation source shutter is
    secured with the locking pin and padlock. The shielded storage box
    is locked.

## RAIL VACIS^®^

### Functional Characteristics

A representative photograph of Rail VACIS^®^ is shown in Figure 6. The
radiation source (2.0 curies of ^137^Cs or 1.0 curies of ^60^Co) is
located in a cabinet on one side of the railroad track, and the sodium
iodide detector sensor array is located on a 32-foot tall tower on the
other side of the track opposite from the radiation source.

The installation incorporates track speed sensing devices well in
advance of the Rail VACIS^®^ equipment, that are used in determining the
speed of the freight train to ensure the proper speed for railcar
scanning is maintained. As the train approaches, a light beam at the
Rail VACIS^®^ installation is activated on one side of the railroad
track that is directed across the track, and a detector on the opposite
side of the track detects the light beam. As each railcar breaks the
beam, the Rail VACIS^®^ equipment uses this information to identify the
discrete railcars being scanned. To aid the Rail VACIS^®^ operator in
identifying which railcar is being scanned, a radio frequency reader is
used to read the standardized identification markings located on the
sides of the railcars.

The system includes a video camera to record each railcar being scanned,
as well as a closed circuit TV camera for safety and surveillance. The
operator station, which houses the control system and operator
positions, can be located in a fixed building, portable building, or
mobile vehicle, depending on local site requirements. The Rail VACIS^®^
equipment runs on externally supplied household electrical power,
requiring two 120 VAC, 20 A, 60 Hz power circuits.

The area required for the Rail VACIS^®^ equipment will vary depending on
the installation site. In order to accommodate the radiation safety
exclusion zone (discussed in Section 6.14.1.3.3, "Rail VACIS^®^"), each
VACIS^®^ installation will require a rectangular footprint area
measuring 20 feet x 50 feet, exclusive of the operator station and any
associated buildings.[^10]

![](media/image7.jpeg){width="6.4215277777777775in"
height="6.276388888888889in"} ***Photograph Courtesy of SAIC***

[]{#__RefHeading___Toc66788489 .anchor}Figure 6: Typical Rail VACIS^®^
installation

### Operational Procedures

The basic Rail VACIS^®^ operating steps are as follows:

1)  At the start of a shift, the radiation source shutter is unlocked
    and the VACIS^®^ computer is turned on.

2)  Using radio communication, the Rail VACIS^®^ operator is alerted of
    an approaching freight train.

3)  As the train approaches the Rail VACIS^®^ installation, the speed
    sensors detect the speed of the freight train and the train crew is
    directed to adjust the train speed, as necessary, to ensure proper
    scanning of the railcars.

4)  The rail vehicle detection light is illuminated perpendicular to the
    railroad track.

5)  Once the locomotives are past the radiation source, the radiation
    source shutter is opened, commencing the scan of the railcars.

6)  As each railcar breaks the light beam, the Rail VACIS^®^ equipment
    uses this information to identify the discrete railcars being
    scanned.

7)  Using the radio frequency identification system, the Rail VACIS^®^
    equipment uses the standardized railcar identification markings to
    aid the system operator to identify which railcar is being scanned.

8)  As each railcar is scanned, the Rail VACIS^®^ equipment acquires,
    displays, and stores images of the scanned railcars. The system
    operator inspects the density image of each railcar to identify any
    anomalies that may indicate the presence of contraband.

9)  Step 8 is repeated for each scanned railcar.

10) After the last railcar has passed, the radiation source shutter is
    closed.

11) The system operator informs the freight train crew regarding whether
    any railcars in the train just scanned require detailed manual
    inspection.

12) At the end of the shift, the VACIS^®^ computer is turned off and the
    radiation source shutter is locked.

## PALLET VACIS^®^

### Functional Characteristics 

Figure shows a typical Pallet VACIS^®^ installation in a warehouse. The
radiation exclusion zone (Fig. 11), as defined by the Customs Radiation
Safety Officer, is 3 feet behind the radiation source that is enclosed
within the cabinet. The footprint for the Pallet VACIS^®^ Cabinet and
Conveyor is 31 feet long x 14.2 feet wide x 11.10 feet at its highest
point. The Command Center is a separate 8 feet x 8 feet office that is
linked to the cabinet mechanism by power and data cables that are not to
be stationed more than 50' from the cabinet. The radiation source (0.5
curie of ^137^Cs or 0.25 curie of ^60^Co) is mounted within a lead
enclosed steel cabinet. The Pallet VACIS^®^ system power requirements
consist of 208 VAC, 60 Hz, 80 amp, 3 phase. An Uninterruptible Power
Supply is installed in the event of a power failure. An external
gasoline generator could be used as an emergency power supply.

Each Pallet VACIS^®^ contains eight major components: A Command Center,
Lift Mechanism, Source Shelf, Detector Shelf, Cabinet, Programmable
Logic Controller (PLC) Panel, Electrical Panel, Conveyor and Pallet
Sensors. The Command Center is placed in a position that has a full,
unobstructed view of the Pallet VACIS^®^ equipment. Enclosed in the
Command Center are the VACIS^®^ operator, a Personal Computer, Closed
Circuit Television Monitors, the System Control Panel (SCP) and the
control pendant. The Lift Mechanism contains 25 gallons of type AW 32
petroleum oil (hydraulic fluid). The presence of the hydraulic fluid may
create the need for a berm to be built around the Cabinet. This berm
will eliminate the possibility of spilled hydraulic fluid migrating from
the general area of the spill.

The Pallet VACIS^®^ is equipped with several safety features to prevent
injury. Included in these features are: a Safety Brake system for the
conveyor and lift mechanism which will engage if the drive chain breaks;
flashing lights that indicate when radiation is being emitted; and
emergency shut-off buttons that will automatically actuate the shutter
in the closed position at the end of a pre-selected scan time. The
system operator may also manually close the shutter. The shutter is a
fail-safe design, whereby the shutter will automatically close upon loss
of electric power to the VACIS^®^ equipment. The shutter is designed so
that a padlock may be used to secure the source in the OFF position. The
radiation source has a primary and secondary shutter. The secondary
shutter will automatically close by spring actuation in the event of a
system failure. The primary shutter will close with the use of the
back-up battery if power is lost. Other areas of concern are Pinch Point
injuries caused by the Conveyor, Electrical safety that encompasses
equipment lockout/tag out procedures and electrostatic discharge
protection, hydraulic component maintenance safety, moving parts and
assemblies, and radiation safety.

> ![](media/image8.jpeg){width="4.70625in"
> height="3.6055555555555556in"}
>
> []{#__RefHeading___Toc66788490 .anchor}**Figure 7: Pallet VACIS^®^**

### Operational Procedures 

Prior to operating the Pallet VACIS^®^ system, a start-up routine is
required to ensure the unit is properly functioning. The start-up
checklist is as follows:

1)  Energize the Pallet VACIS^®^ by inserting and turning the key in the
    System Enable switch that is on the System Control Panel (SCP).

2)  Following system power-up, the Manual Jog function is tested. This
    consists of pressing the green button located on the Motor Starter
    to power-up the Hydraulic Power Unit (HPU).

3)  Retrieve the handheld pendant and press the RESET button to take the
    system out of the "E Stop" mode.

4)  On the pendant, press and hold the Input Conveyor switch to jog the
    conveyors. Ensure an audible tone is heard for two seconds prior to
    the conveyors moving. Also ensure the Load and End sections of the
    conveyor move at the same speed and that they operate smoothly.
    While holding the Input Conveyor button, depress the E-Stop button
    and ensure the conveyor stops.

5)  Perform the same procedures for the Output conveyor.

6)  Preset the Scan speed switch located on the SCP to MED.

7)  Using the pendant, press the Jog Lift switch upward into the UP
    position. Ensure the Detector Shelves operate smoothly while rising
    to 2 feet of the top position. Release the switch and verify the
    shelf stops immediately.

8)  Repeat the procedures for the downward direction.

**Note: Repeat this procedure several times while viewing from different
angles.**

It is a requirement for this system to normalize the Detectors once a
day or when the imaging becomes noticeably degraded. This process is to
be completed only after the Manual Jog procedure has been accomplished.

The Normalizing of the Detectors process is accomplished by:

1)  Jog the lift so that the Detector and Source shelves are completely
    above the conveyor surface.

2)  Open the first or second cabinet door on the source side of the
    system; remove the padlock; if the system is the ^60^Co, push the
    plunger in completely and close the doors.

3)  Press the Shutters Enable on the SCP and ensure the red light in the
    button illuminates.

4)  On the ^60^Co system, when the Primary Shutter opens, a light on the
    SCP should be illuminated. For the ^137^Cs systems press the button
    and ensure after several seconds of flashing that the light remains
    on.

5)  Select Normalize from the Acquire menu and verify the Secondary
    Shutter Open light illuminates and that the warning beacons on the
    cabinet are flashing. This process should take approximately 15 to
    20 seconds. On the computer screen, a detector window opens after
    the secondary shutter closes.

6)  On the computer screen, click the button in the top right hand
    corner to close the detector array window.

**The basic start-up and operating steps for pallet loading and testing
are as follows:**

1)  A forklift operator delivers the target pallet on to the load end of
    conveyer unit.

2)  The Red ENABLE button located in the Shutters section of the SCP is
    depressed. This command enables remote operation of the source
    shutters.

3)  The OPEN button located on the Primary Shutter portion of the SCP is
    pressed, which opens the primary shutter and turns on the lasers to
    assist in positioning the target.

4)  The detector and source shelves should have been parked near their
    scanning position. If this was not done, the Lift Jog Down switch
    may be used to position the target.

5)  The Auto Load button on the Input Conveyors section of the SCP is
    held until the light stops flashing. This switch moves the target
    into position within the Cabinet. Ensure the laser lines are visible
    on the Detector Shelf or are not visible on the target; use the JOG
    switch on the INPUT CONVEYOR panel to properly position the target.

6)  Select the appropriate scanning speed by positioning the Scan Speed
    Switch on the SCP.

7)  Depress the red Start Key located on the Auto Scan section of the
    SCP.

8)  When the lift has reached the required height that was preset during
    the System Setup, the scan will stop. If the need to stop the scan
    prior to the auto end is desired, press the Stop button located on
    the Auto Scan portion of the SCP.

9)  The forklift operator may now remove the pallet from the conveyor.

**The basic start-up and operating steps for pallet loading and testing
are as follows:**

1)  On the PC located in the Operator's Booth, select either the File:
    Exit menu and clicking on the Exit icon or by pressing the \<Alt\>
    +X on the keyboard.\
    \
    *Note: If the* VACIS^®^ *software detects unsaved files, a dialogue
    box will appear on the screen asking for a Yes, No or Cancel
    decision to be made.*

2)  At the Windows screen, select start followed by Shut Down.

3)  When prompted, select "Shut Down the Computer".

4)  Following computer shutdown, ensure:

    a.  The Primary and Secondary source shutters are fully closed

    b.  The Cabinet warning lights are off

    c.  The roll-up doors are fully closed

    d.  The Conveyor / Lift Mechanism operating alarm is secured

    e.  The Conveyor / Lift Mechanism, video cameras and monitors, UPS
        and Printer have had the power secured.

    f.  Turn the SYSTEM ENABLE keylock switch located on the SCP to the
        off position.

*Warning: Ensure the SCP's SYSTEM ENABLE key is removed and properly
secured.*

# Purpose and Need for the Action

## PURPOSE

The primary purpose of the proposed action is the fielding and operation
of gamma-ray non-intrusive imaging equipment for use at air, sea and
land POEs, to meet the need for gamma-ray NII systems identified in the
*National Drug Control Strategy*, and the *Ten-Year Technology
Development Plan and Development Roadmap.*[^11] A gamma imaging
detection system will enable the Customs and Border Protection Inspector
to perform the effective and efficient NII of cargo vehicles including
tanker and trailer trucks, trailer-mounted cargo containers, and
railroad cars for contraband such as illicit drugs, currency, and guns.
As a part of a multi-technology approach to combating the smuggling of
illicit drugs into the U.S., a gamma imaging system directly supports
CBP's *Narcotics Strategic Plan*[^12] to develop and introduce
technologies to identify narcotics and support the goals of the
*National Drug Control Strategy*[^13] to shield America's air, land, and
sea frontiers from the drug threat. Given the seriousness faced by CBP
in protecting our nation\'s borders it is envisioned all POEs are future
candidates for the fielding of gamma ray non-intrusive imaging
equipment.

## NEED

Created in 1789, U.S. Customs (now part of CBP under DHS) is one of the
Federal government's oldest agencies. Customs' original mission was to
collect revenue. Now, the unified CBP mission has expanded to include
ensuring all goods and persons entering and exiting the U.S. do so in
accordance with all U.S. laws and regulations. Even though the mission
has changed over time, stifling the drug trade remains a major objective
of the organization. As stated in its 2002 annual report:[^14]

> > "Although counterterrorism has become the number one priority of the
> > agency since the tragic events of September 11, 2001, Customs still
> > remains a leader in interdicting and investigating drug smuggling
> > activities and organizations. Our heightened state of security along
> > America's borders has, in fact, strengthened, not weakened, our
> > counterdrug effectiveness through the deployment of additional
> > manpower and NII technology assets."

The CBP's need for non-intrusive inspection technology is based on its
responsibilities to operate 301 POEs. Contraband can enter the U.S. by
air, land, and sea. Illegal items can be transported by or in people,
cargo, and conveyances including cars, trucks, aircraft, and vessels.
Customs Inspectors are, therefore, required to perform inspections of
cargo and conveyances as a prerequisite for entry into the U.S. In 2002,
CBP processed approximately 415 million people, 10 million containers
and trucks, 117 million private vehicles, 1 million aircraft and marine
vessels, and the collection of \$20B in tariffs. This tremendous and
growing workload demands a shift from manpower-intensive methods to more
efficient technology-based solutions.

The need for CBP to increase its investment in technology is apparent.
The effective and efficient screening and processing of low-risk cargo,
conveyances, and persons will allow CBP to focus the bulk of its
anti-smuggling and trade enforcement resources on suspected and actual
law violators, thereby increasing both the potential and the reality of
detection. Customs Inspectors need the ability to conduct
high-confidence inspections in a non-intrusive manner quickly and
efficiently. The NII technology provides CBP with the capability of
increasing the total number of inspections performed daily, and allows
for the examination of very difficult commodities (e.g., tankers and
hazardous materials) in a timely and cost effective manner.

The major focus of CBP's current plans for NII technology development
and acquisition are based on its *Narcotics Strategic Plan* and its
interdiction objective:

-   The goal of CBP narcotics strategy is to prevent the smuggling of
    narcotics into the U.S. by creating an effective narcotics
    interdiction, intelligence, and investigation capability that
    disrupts and dismantles smuggling organizations.

-   The objective for narcotics interdiction is to develop and introduce
    technologies and techniques to identify smuggled narcotics, to force
    smuggling organizations to change to higher risk smuggling methods,
    and to enlist the participation of other nations in efforts to
    disrupt the worldwide smuggling of narcotics.

The CBP strategy for NII technology development and acquisition is
influenced by the reality of its critical enforcement responsibilities
with respect to drug smuggling. Drug smuggling is a real and immediate
problem for the US; it is not a theoretical problem, nor one of the
future. The CBP's choices regarding new technology also must recognize
today's constraints on time and resources. If there is an available
technology that responds to current and foreseeable requirements and
priorities, and is both operationally and economically feasible, CBP
believes it has an obligation to put that technology into use as soon as
possible. CBP cannot afford to wait for the elusive, perfect system that
is always just over the horizon; rather, it must acquire effective
devices for today's most critical areas as soon as the technology is
available and affordable. The CBP also realizes that many operational
requirements are not satisfied by available technology, and that
development must be pursued strenuously to meet these needs. When these
efforts produce equipment which meets its criteria, CBP will add it to
its arsenal; not because it is new or represents the state-of-the-art,
but rather because it is necessary, effective, appropriate, and
affordable.[^15]

# The Proposed Action and Alternatives

## FIELDING AND OPERATION OF VACIS^®^ GAMMA IMAGING SYSTEM (Proposed Action)

The proposed action is to field and operate the VACIS^®^ gamma-ray
non-intrusive imaging equipment for use by CBP at its air, sea and land
POEs.

The VACIS^®^ program is part of a multi-technology approach to combating
the smuggling of contraband into the U.S. VACIS^®^ will enable the
Customs and Border Protection Inspector to perform the effective and
efficient non-intrusive inspection of cargo vehicles including tanker
and trailer trucks, trailer-mounted cargo containers, railroad cars and
individual pallets or crates. Modular in design and capable of being
rapidly deployed among different sites, VACIS^®^ will be capable of
detecting contraband located in the vehicle body and chassis, tires, gas
tanks, and hidden compartments. Complementing other new technologies
under the *USCS Five-Year Technology Acquisition Plan for the Southern
Tier*, the goals of the *National Drug Control Strategy and the USCS
Narcotics Strategy* will be directly supported by the VACIS
program.[^16]

The VACIS^®^ uses a low-energy gamma ray source (^60^Co and ^137^Cs) to
generate images of trucks and cars similar to the images created by
x-ray systems. However, VACIS^®^ can probe deeper into cargo than
low-energy x-ray systems, while emitting minimal radiation. Utilized as
an enforcement tool, VACIS^®^ will help CBP intercept narcotics
shipments, while allowing the rapid processing of lawful international
trade and travel.

The VACIS^®^ was originally developed by Science Applications
International Corporation (SAIC), with funding from CBP and the ONDCP,
to inspect empty tanker trucks. VACIS^®^ is largely a commercial
off-the-shelf procurement. Department of Defense sponsored tests for
VACIS^®^ were conducted at Thunder Mountain Evaluation Center (TMEC),
Fort Huachuca, Arizona.[^17]

The spending on contraband detection technologies that has occurred
since 1990 has been due, in large part, to Congressional direction.
Congress has appropriated funds for the acquisition of NII technology
and Automated Targeting Systems as part of the "Omnibus Consolidated and
Emergency Supplemental Appropriations Act, 1999 (P.L. 105-77, H.R. 4328,
H. Rept. 105-825)".

Specifically, the two sections in this appropriation are:

1)  Omnibus Crime Bill Initiatives -- (Non-Intrusive Inspection
    Technology and Automated Targeting Systems) for \$54M

2)  Emergency Supplemental Appropriations -- (Additional Non-Intrusive
    Inspection Technology to Augment the \$54M) for \$80M.

Gamma-ray imagers (e.g., VACIS^®^) are identified by specific line
items, and account for \$20.8M of the \$134M appropriations as
identified.[^18]

## ALTERNATIVES TO THE PROPOSED ACTION

The CEQ regulations for the preparation of Environmental Assessments for
Major Federal actions require an investigation and evaluation of
alternatives to the proposed action as part of each assessment.

### No Action Alternative

Inclusion of a "No Action" alternative in this PEA is required under
NEPA. The No Action alternative maintains the status quo and evaluates
the effects of not fielding VACIS or any other alternative action, thus
providing a benchmark against which project alternatives may be
evaluated. The No Action alternative is in conflict with CBP's mission
of drug interdiction, the objectives of the *National Drug Control
Strategy*, the *USCS Five-Year Technology Acquisition Plan for the
Southern Tier* and the scope of the *Ten-Year Technology Development
Plan and Development Roadmap*. Therefore, it is not a viable
alternative.

### Field a Gamma Imaging System other than VACIS

The ONDCP, Counterdrug Technology Assessment Center (CTAC) is
responsible for coordinating Federal counterdrug technology research and
development. The *Ten-Year Technology Development Plan and Development
Roadmap* has been prepared to satisfy the technology objectives within
the five goals of the *National Drug Control Strategy*. The Plan
concentrates on the counterdrug technology needed by all Federal
agencies with drug control missions. Federal agencies such as CBP are
consulted within the technology research and development decision
process, and will ultimately carry out implementation of the *Ten-Year
Technology Development Plan and Development Roadmap*.

The acquisition and fielding of gamma imaging technology is a priority
need in NII technology for which CTAC has solicited advanced concepts.
The identification of VACIS^®^ to meet the gamma imaging technology need
is a result of the technology assessment/ research and development
process outlined in the *Ten-Year Technology Development Plan and
Development Roadmap.*[^19] The PEA specifically addresses VACIS^®^
because it was the only gamma imaging inspection system commercially
available to the CBP at the time of past procurements and hence is the
system currently represented in the CBP inventory.

If CBP determines that future procurements of gamma imaging inspection
systems are warranted, they will be evaluated in a supplemental
environmental assessment to this PEA, to the extent they may differ from
the VACIS^®^.

On 19 March 1999, the Department of the Army, Fort Huachuca, Arizona
posted a Sources Sought notice in the Commerce Business Daily *CBDNet*
identifying a requirement for CBP to procure NII systems similar to
VACIS^®^II, and requesting responses from vendors able to provide
commercial off-the-shelf systems.[^20] The only vendor responding with a
commercially available product was SAIC.

# The Affected Environment

This section describes the existing conditions for each resource
category, including applicable statutes. Some resources have more, or
less, information than others concerning the existing conditions and
regulatory background. The difference between resources depends on the
nature of the resource, and is not an indicator of the resource's
importance. For example, resources such as climate, geology, soils,
hydrology, and flora and fauna species, are impossible to describe in a
document that considers installation of systems in 12 states and Puerto
Rico. A more detailed description of the affected environment will be
provided in a Supplemental Environmental Document (SED), as necessary,
to evaluate project impacts.

##  CONSULTATIONS

As part of the process of determining whether a VACIS^®^ installation
may significantly impact the resources located at or near the
installation site, CBP may be required to conduct consultations with
Federal, state, and local agencies. CBP will typically provide the
agencies with VACIS^®^ installation details such as location,
excavation/construction requirements, site photographs, and anticipated
vehicular traffic flow for use by the agencies in determining whether
there are any significant natural resource or socioeconomic impacts that
must be precluded or minimized. The typical types of consultations that
are required, as well as guidance in conducting these consultations, are
described in the following subsections.

### Coastal Zone Protection

The Coastal Zone is defined in 49 CFR Part 194 as "All United States
waters subject to the tide, United States waters of the Great Lakes and
Lake Champlain, specified ports and harbors on inland rivers, waters of
the contiguous zone, groundwaters, and ambient air proximal to those
waters."

The Coastal Zone Management Act (CZMA) requires CBP to ensure their
operations, activities, projects, and programs that affect the Coastal
Zone in or on coastal lands or waters are consistent, to the maximum
extent practicable, with the Federally approved Coastal Zone Management
Plan for the state. The CZMA authorizes states to administer approved
coastal non-point pollution programs. Advance concurrence from the state
Coastal Commission is required prior to taking an action affecting the
use of land, water, or natural resources in the Coastal Zone. In their
Coastal Zone management programs, states must list activities that
affect the Coastal Zone and, therefore, require a consistency
determination. CBP will review these lists to identify activities
applicable to the installation of VACIS^®^ that are likely to require a
consistency determination.

### Protection of Wetlands, and Floodplain Management

Executive Order (EO) 11990 "Protection of Wetlands" and EO 11988
"Floodplain Management" address the Federal agency actions required to
identify and protect wetlands and floodplains, minimize the risk of
flood loss and destruction of wetlands, and preserve and enhance the
natural and beneficial values of both floodplains and wetlands. In a
Federal Register notice of 24 May 1978 (43 FR 22311), the Department of
the Treasury advised, as a general rule, that it does not engage in
activities that would impact on floodplains or wetlands. Department of
the Treasury procedures implementing these EOs are incorporated in U.S.
Treasury Directive 75-02, *Department of the Treasury's National
Environmental Policy Act Implementing Procedures.*

CBP will evaluate the potential effects of actions in floodplains,
according to procedures outlined in U.S. Treasury Directive 75-02. If
required, CBP will obtain permits from the U.S. Army Corps of Engineers
(USACE) prior to discharging dredged or fill material into waters of the
US, including wetlands, in compliance with Section 404 of the Clean
Water Act.

### Endangered Species Protection

Section 7 of the Endangered Species Act of 1973 requires CBP to consult
with the U.S. Fish and Wildlife Service (USFWS) and the National Marine
Fisheries Service (NMFS) if proposed CBP-funded projects may affect
threatened and endangered species and/or their suitable habitat. CBP
will consult with the USFWS or the NMFS, as appropriate, on any CBP
action(s) that may affect any Federally listed threatened or endangered
species or their critical habitat, in order to ensure such actions are
not likely to jeopardize the continued existence of the species or
result in the destruction or adverse modification of the habitat. Such
consultations may be either formal or informal. When necessary, CBP will
prepare a biological assessment of the effects of a proposed action on
listed species to assist the USFWS or NMFS in issuing a biological
opinion regarding whether the action will jeopardize the continued
existence of the species. The Endangered Species Act of 1973 does not
require consideration of state-listed species. However, state laws and
regulations may govern the possession, propagation, sale, or taking of
such species.

### Historic and Archaeological Resources Protection

Section 106 of the National Historic Preservation Act of 1966 (NHPA)
requires a Federal agency with jurisdiction over a Federal, Federally
assisted, or Federally licensed undertaking to take into account the
effects of the agency's undertaking on properties included in, or
eligible for, the National Register of Historic Places (NRHP) and, prior
to approval of an undertaking, to afford the applicable State Historic
Preservation Officer (SHPO) an opportunity to consult on the
undertaking. Prior to initiating consultation, CBP must determine
whether cultural properties are present in the Area of Potential Effect
(APE), evaluate the property to determine the eligibility for listing in
the NRHP, and evaluate the potential effects of the proposed undertaking
on any NRHP-eligible property located in the APE.

Similarly, CBP is required to comply with Section 110 of the Act.
Section 110 requires "all Federal agencies shall assume responsibility
for the preservation of historic properties which are owned or
controlled by such agency." CBP's preservation-related activities will
be carried out in consultation with other Federal, State, and local
agencies, Indian tribes, Native Hawaiian organizations, and with
notification to the interested Public.

##  GEOLOGY AND SOILS

Potential impacts related to geology and soils are primarily related to
construction of structures in geologically sensitive areas, to
geohazards and potential earthquake damage to proposed new facilities,
and to possible impacts to soils, depending on facility siting and
construction requirements.

To avoid potential impacts to unique geologic resources, the relevant
county and city general plans should be consulted before siting new
facilities.

##  AIR QUALITY

### Air Quality Management

Air quality is managed through the Clean Air Act Amendments as well as
various state Clean Air Acts. The Federal and State Clean Air Acts are
implemented through a three-point strategy:

1)  Local controls for managing stationary, non-vehicular sources and
    permitting;

2)  State controls for setting emissions for motor vehicles, fuels, and
    consumer products; and

3)  Federal controls for interstate pollutants.

To further support the goal of reduced emissions, State Implementation
Plans (SIPs) have been adopted as an approach to reduce air pollution,
region by region, in future years. SIPs contain measures that allow each
region to reach attainment status (meet the primary standard for all air
quality criteria). Although Federal and state governments play a role in
managing the nation's air quality, the acts are implemented primarily at
the local level.

At the state and county levels, air quality is managed through numerous
Air Quality Management Districts (AQMDs). Each AQMD is responsible for
controlling air pollution within the district to meet all state and
Federal air quality standards. Using regional air quality data, each
AQMD adopts it own statutes to deal with the air quality problems
associated with that region, including setting emission limits for
stationary sources such as factories and power plants. In addition, each
district develops its own clean air plan and enforces local pollution
control laws.

### Applicable Air Quality Statutes

Several statutes exist to manage air quality, and many may apply to a
particular project; however, one statute in particular is, perhaps, the
most applicable to potential Federal projects: the New Source Review
(NSR) permitting process statutes. Under this permitting process, any
new potential source of emissions may have to be permitted by the AQMDs.
Even temporary sources, such as increased particulate matter less than
10 micrometers in diameter (PM~10~) due to construction, may require a
permit, depending on the district and its air quality. In most cases, a
permit may not be required for temporary, small-scale construction
measures. However, the AQMD associated with the project must be
contacted to ultimately determine regulation applicability, regardless
of project scale.

### Air Quality for the Criteria Air Pollutants

The Environmental Protection Agency (EPA) defines ambient air in 40 CFR
Part 50, as "that portion of the atmosphere, external to buildings, to
which the general public has access." In compliance with the 1970 Clean
Air Act (CAA) and the 1977 and 1990 Amendments (CAAA), the EPA has
promulgated ambient air quality standards and regulations. The National
Ambient Air Quality Standards (NAAQS) were enacted for the protection of
the public health and welfare, allowing for an adequate margin of
safety. To date, the EPA has issued NAAQS for six criteria pollutants:
carbon monoxide (CO), sulfur dioxide (SO~2~), particles with a diameter
less than or equal to a nominal 10 micrometers (PM~10~), ozone (O~3~),
nitrogen dioxide (NO~2~), and lead (Pb). The health and welfare effects
of the applicable criteria pollutants are listed in Table II.

There are two types of air quality standards: primary and secondary.
Primary standards are designed to protect sensitive segments of the
population from adverse health effects, with an adequate margin of
safety, which may result from exposure to criteria pollutants. Secondary
standards are designated to protect human health and welfare and,
therefore, in some cases, are more stringent than the primary standards.
Human welfare is considered to include the natural environment
(vegetation) and the man-made environment (physical structures). Carbon
monoxide is generated from motor vehicles and wood burning, and is
considered a human health risk. Nitrogen dioxide is a product of
combustion and can be seen as a brown haze. Organic gases react with
nitrogen dioxide to form ozone, which causes low visibility and health
effects including respiratory disease and eye irritation. Particulate
matter is a component of smoke and can have a variety of health effects,
depending on its chemical composition. Sulfur dioxide, which is
generated from burning fossil fuels, causes damage to vegetation and
reduces the health of humans and animals. Airborne lead, which is
generally produced by automobiles, can cause blood-related effects and
may also affect the central nervous and reproductive systems.

Exceeding a concentration level is a violation and constitutes a
nonattainment of the pollutant standard. If an air quality control
region violates the NAAQS for a pollutant, this region is defined as a
nonattainment area for that pollutant.

[]{#__RefHeading___Toc66181302 .anchor}**Table II**: National Ambient
Air Quality Standards

+------------------------+-----------------------+---------------------+
| POLLUTANT              | STANDARD VALUE \*     | STANDARD TYPE       |
+========================+=======================+=====================+
| **Carbon Monoxide      | 9 ppm (10 mg/m^3^)    | Primary             |
| (CO)**                 |                       |                     |
|                        | 35 ppm (40 mg/m^3^)   | Primary             |
| > 8-hour Average       |                       |                     |
| >                      |                       |                     |
| > 1-hour Average       |                       |                     |
+------------------------+-----------------------+---------------------+
| **Nitrogen Dioxide     | 0.053 ppm (100        | Primary & Secondary |
| (NO~2~)**              | µg/m^3^)              |                     |
|                        |                       |                     |
| > Annual Arithmetic    |                       |                     |
| > Mean                 |                       |                     |
+------------------------+-----------------------+---------------------+
| **Ozone (O~3~)**       | 0.12 ppm (235         | Primary & Secondary |
|                        | µg/m^3^)              |                     |
| > 1-hour Average       |                       | Primary & Secondary |
| >                      | 0.08 ppm (157         |                     |
| > 8-hour Average \*\*  | µg/m^3^)              |                     |
+------------------------+-----------------------+---------------------+
| **Particulate          | 50 µg/m^3^            | Primary & Secondary |
| (PM~10~)**             |                       |                     |
|                        | 150 µg/m^3^           | Primary & Secondary |
| > *Particles with      |                       |                     |
| > diameters of 10      |                       |                     |
| > micrometers or less* |                       |                     |
| >                      |                       |                     |
| > Annual Arithmetic    |                       |                     |
| > Mean                 |                       |                     |
| >                      |                       |                     |
| > 24-hour Average      |                       |                     |
+------------------------+-----------------------+---------------------+
| **Particulate          | 15 µg/m^3^            | Primary & Secondary |
| (PM~2.5~)**            |                       |                     |
|                        | 65 µg/m^3^            | Primary & Secondary |
| > *Particles with      |                       |                     |
| > diameters of 2.5     |                       |                     |
| > micrometers or less* |                       |                     |
| >                      |                       |                     |
| > Annual Arithmetic    |                       |                     |
| > Mean \*\*            |                       |                     |
| >                      |                       |                     |
| > 24-hour Average \*\* |                       |                     |
+------------------------+-----------------------+---------------------+
| **Sulfur Dioxide       | 0.03 ppm (80 µg/m^3^) | Primary             |
| (SO~2~)**              |                       |                     |
|                        | 0.14 ppm (365         | Primary             |
| > Annual Arithmetic    | µg/m^3^)              |                     |
| > Mean                 |                       | Secondary           |
| >                      | 0.50 ppm (1300        |                     |
| > 24-hour Average      | µg/m^3^)              |                     |
| >                      |                       |                     |
| > 3-hour Average       |                       |                     |
+------------------------+-----------------------+---------------------+
| **Lead (Pb)**          | 1.5 µg/m^3^           | Primary & Secondary |
|                        |                       |                     |
| > Quarterly Average    |                       |                     |
+------------------------+-----------------------+---------------------+

*(Source: U.S. Environmental Protection Agency \[EPA\] Office of Air
Quality Planning and Standards website
<http://www.epa.gov/air/criteria.html>*; accessed March 9, 2004)

\* Parenthetical value is an approximately equivalent concentration.

Hazardous air pollutants (HAPs), or toxic air contaminants, have no
established air quality standards, but have potential cancer and
noncancer health effects that are evaluated on a case-by-case basis.
Hazardous air pollutants are emitted from several sources including
fossil fuel burning, paints, and thinners. HAPs expected during the
Proposed Action include volatile compounds emitted during construction-
and maintenance-related painting operations (e.g., xylenes, toluene,
methyl ethyl ketone, etc.) and from gasoline- or diesel-powered engines
(benzene).

##  HYDROLOGY AND WATER QUALITY

Federal statutes and Executive Orders, state statutes, and state agency
regulations and directives protect water quality and the beneficial uses
of water. EO 11988 (Floodplain Management) and EO 11990 (Protection of
Wetlands) mandate control of activities that indirectly impact water
quality. Applicable Orders and other directives are described in various
sections of this PEA, where relevant.

### Federal Requirements

The Clean Water Act (CWA) regulates water quality of all discharges into
"waters of the United States (U.S.)." Both wetlands and "dry washes"
(channels that carry intermittent or seasonal flow) are considered
"waters of the U.S." Many states have adopted equivalent or more
stringent statutes than those found in the Federal directives, which are
enforced by State Water Resources Control Boards (SWRCBs) and Regional
Water Quality Control Boards (RWQCBs). USACE may need to be contacted
under Section 404 of the CWA if a VACIS® installation requires the
discharge of dredged or fill materials into the waters of the U.S.

### State Requirements

The SWRCBs and RWQCBs work together to protect state water resources,
and are responsible for establishing water quality standards and
objectives that protect the beneficial uses of different waters. RWQCBs
are responsible for protecting the surface, ground, and coastal waters
from pollution originating from point sources (e.g., sewage treatment
plant discharge) and nonpoint sources (e.g., runoff from urban paved
areas). Modifications and/or new construction of a facility may require
one or more of the following permits:

-   National Pollution Discharge Elimination System (NPDES) General
    Permit\
    \
    This Permit may be required as a facility is constructed or moved
    and if the facility discharges any waters other than to the sanitary
    sewer.

-   NPDES Stormwater Construction Permit\
    \
    This permit is required for any construction activity that will
    affect 1 acre or more, unless local restrictions impose a smaller
    acreage threshold. Specifically excluded is construction activity
    that includes "routine maintenance to maintain original line and
    grade, hydraulic capacity, or original purpose of the facility."

-   NPDES Stormwater Industrial Permit\
    \
    Stormwater permits are currently required for most industrial
    properties. If modifications are made or if an industrial facility
    is relocated, the permit must be modified to reflect these changes.

Some state Departments of Fish and Game regulate alterations made to
natural waterways. Modifications or new construction of facilities that
may impact the volume or quality of water entering a natural waterway
(such as a culvert discharging into a "dry wash") may be required to
obtain a Streambed Alteration Permit.

### County and City Requirements

Counties and cities have developed general plans that include
county-specific or city-specific descriptions of existing surface and
groundwater resources. Some urbanized counties and municipalities have
county-wide or area-wide stormwater permits that offer guidelines and
restrictions to new development that may impact modifications or
construction of new facilities. Additionally, some municipalities have
adopted Watershed Management Plans that may regulate or restrict
modification and/or construction of facilities that discharge into
waters within their plan area.

##  FLOODPLAINS

The term "floodplain" generally refers to the 100-year floodplain. The
100-year floodplain designates the area subject to inundation from a
flood having a 1 percent chance of occurring in any given year. This
flood is referred to as the "100-year flood" or "base flood" and may
occur more or less often than once every 100 years. In circumstances
known as "critical actions", the regulated flood-prone area is defined
by the 500-year floodplain. The 500-year floodplain designates the area
subject to inundation from a flood having a 0.2 percent chance of
occurring in any given year.

Floodplains are designated on National Flood Insurance Rate Maps (FIRMs)
or Flood Hazard Boundary Maps (FHBMs) for communities that are members
of the National Flood Insurance Program (NFIP). The NFIP and its
implementing regulations (44 CFR Parts 59 through 77) stipulate minimum
standards for floodplain development in communities that participate in
the program. Local governments incorporate these standards, or in some
cases more stringent standards, into their floodplain ordinances. In
addition to showing the locations of the 100-year and 500-year
floodplains, many FIRMs and FHBMs show the base flood elevation (BFE),
which is the estimated elevation of the 100-year flood. FIRMs and FHBMs
delineate floodplains with other descriptors; the most important of
these are the floodway and the 100-year coastal, high hazard floodplain.
The floodway is the channel of a river or other watercourse and adjacent
land areas that are required to remain free from development to
discharge the base flood without cumulatively increasing the
water-surface elevation. The coastal floodplain incorporates storm
surges and has more stringent statutes for development than the normal
100-year floodplain, because of the velocity of waves associated with
coastal flooding.

The NEPA compliance process requires Federal agencies to consider direct
and indirect impacts to floodplains that may result from Federally
funded actions. EO 11988 requires Federal agencies to take action to
minimize occupancy and modification of floodplains. Furthermore, EO
11988 requires that Federal agencies proposing to site a project in the
100-year floodplain must consider alternatives to avoid adverse effects
and incompatible development in the floodplain. If no practicable
alternatives exist to siting a project in the floodplain, the project
must be designed to minimize potential harm to, or within, the
floodplain. Furthermore, a notice must be publicly circulated explaining
the project and the reasons for the project being sited in the
floodplain.

##  THREATENED AND ENDANGERED SPECIES

The Endangered Species Act of 1973 (16 United States Code \[USC\]
Sections 1531 to 1534) requires Federal agencies to determine the
effects of their actions on threatened and endangered species of fish,
wildlife, plants, and their habitats, and take steps to conserve and
protect these species. This PEA assumes that CBP has requested
consultations under Section 7 of the Endangered Species Act, as amended,
for the installation of VACIS^®^.

##  CULTURAL RESOURCES

In addition to review under NEPA, consideration of impacts to cultural
resources is mandated under Sections 106 and 110 of the National
Historic Preservation Act (NHPA) and implemented by 36 CFR Part 800.
Requirements include identifying significant historic properties and
districts that may be affected by the proposed actions or alternatives.
Historic properties are defined in 36 CFR Part 60.4 as archaeological
sites, standing structures, or other historic resources listed on, or
determined potentially eligible for, the NRHP.

##  SOCIOECONOMICS

Impacts related to socioeconomic resources include changes to
demographics, housing, employment, the local economy, and public safety
hazards.

The U.S. Department of Commerce Bureau of the Census provides much of
the relevant data on demographics and housing. Although only conducted
once every 10 years, the U.S. census provides the most accurate and
detailed information for the years that data were acquired. In addition,
the census provides the basis for most projections and estimates
prepared by national, state, local, and private organizations. State,
county, and city information provide census data for political
subdivisions of the country, for example. In addition, census data are
provided by statistical subdivision that includes (in order of
decreasing size) tracts, block-numbering areas, block groups, and
blocks. These statistical subdivisions of counties were delineated to be
homogeneous with respect to demographics, economic status, and living
conditions. Most local governments have basic demographic, economic, and
employment data based on these political subdivisions.

EO 12898 requires Federal agencies to make achieving environmental
justice part of their mission by identifying and addressing
disproportionately high and adverse public health or environmental
effects of its programs, policies, and activities on minority and
low-income populations. EO 12898 also tasks Federal agencies to ensure
public notifications regarding environmental issues are concise,
understandable, and readily accessible.

##  LAND USE AND ZONING

Generally, land use refers to the existing function of real property.
Examples of the most common land use categories include residential,
commercial, industrial, public (or institutional), recreational,
agricultural, and open (or undeveloped). Many of these categories are
further subdivided, for example, high-, medium-, and low-density
residential or light and heavy industrial. Management plans; policies,
ordinances, and statutes that determine the types of uses that are
allowable or that protect specifically designated or environmentally
sensitive uses frequently regulate Land uses. Virtually every level of
government regulates land use. At the Federal level, for example,
land-use statutes range from the U.S. Department of Agriculture
restrictions to avoid soil erosion, to the designation of wilderness
areas. State Planning and Zoning Laws designate areas to be protected
because of scenic and scientific value, forest and agricultural
importance, and potentially hazardous conditions.

Land use regulation is most common at the local level. This local land
use regulation, or zoning, is the designation given by a governmental
unit to classify and regulate development. These zones generally use the
same terms listed above for land uses. Most incorporated cities and the
incorporated areas of many counties are subject to zoning ordinances. In
addition to geographically defining these zones, zoning ordinances
prohibit development that is inconsistent with land uses in the given
district. For example, building an industrial facility in a low-density
residential district would be prohibited in most city or county zoning
ordinances. Compliance with zoning ordinances is enforced by local
governments as part of the building permit process.

## PUBLIC SERVICES AND PUBLIC SAFETY

This section considers the impacts to services provided by political
jurisdiction, including police, fire, recreation, and education.
Although usually provided by the private sector, medical services and
utilities (including water, sewage, electricity, telephone, and natural
gas) are considered public services when assessing a community's ability
to handle infrastructure or demographic changes.

Guidelines and statutes regarding these resources are found at the local
level. Local jurisdictions frequently establish building codes and other
construction standards, and prescribe requirements for local police and
fire protection. Many components of utility services are also regulated
at the Federal and state level; however, these regulations do not
generally apply to impacts caused by CBP actions considered in this PEA.

## TRANSPORTATION

State Departments of Transportation are responsible for the design,
construction, and maintenance of the state highway systems, including
that portion of interstate highways within each state's boundaries. The
U.S. Department of Transportation Federal Highway Administration (FHWA)
provides funding and oversight of projects involving Federal highways.
Transportation planning agencies of local governments are responsible
for the design, construction, and maintenance of county and local roads.
Public transportation is managed by private, public, and
quasi-governmental agencies at the local level. Description of local
transportation networks and impacts to traffic conditions caused by the
installation and operation of VACIS® will be addressed in individual
SEDs.

## NOISE

The Occupational Safety and Health Administration (OSHA) noise standard
is the regulatory reference for hazardous occupational noise exposures.
Other consensus standard organizations such as the American Conference
of Governmental Industrial Hygienists (ACGIH) and the National Institute
of Occupational Safety and Health (NIOSH) have equivalent recommended
limits.

The OSHA standard for occupational noise exposure is found at 29 CFR
1910.95.[^21] This standard requires personal dosimeter testing and the
establishment of an effective hearing conservation program and
additional testing if exposure levels to noise are at or above the
"action level" of 85 dBA as an 8-hour time weighted average (TWA)
exposure. 85 dBA is 50% of the OSHA permissible exposure limit (PEL) of
90 dBA as an 8-hour TWA. To determine the potential for high noise
exposure and compliance with the OSHA noise standard, area sampling of
noise at potential high noise sources are taken with a calibrated sound
level meter (SLM) in an attempt to find areas with potential noise
pressure generation of 85 dBA or greater. An SLM is a device that
provides a reading of sound intensity at any given moment and location.
If areas are found greater than 85 dBA, additional study and
determination of actual employee exposure to the noise source is needed
to determine an employee's full shift, 8-hour average exposure, with
comparison of the results to the OSHA standard requirements. Noise
levels that do not exceed 85 dBA are below the level of consideration
and are acceptable occupational sound pressure levels. Below 85 dBA is a
level where nearly all individuals may be repeatedly exposed without
adverse effects on the ability to hear and understand normal speech.

The A-weighted scale of measurement (dBA -- decibels measured on an
A-weighted scale) represents sound level measurement of a wide range of
frequencies in a manner representative of the human ear's response. This
scale reduces the overall weight of the low and high frequencies with
respect to the medium frequencies, to simulate the response and relative
damage of human hearing to noise. Noise measurements for occupational
exposure are primarily expressed in dBA.

The Noise Control Act (P.L. 92-574) and its implementing regulations at
40 CFR Parts 201 through 211 limit noise exposures to the human
environment. Construction activities, the movement of rail equipment,
and the operations of heavy trucks and truck mounted equipment are
required to meet noise limits of the Noise Control Act regulations. In
addition, local ordinances may require noise controls specific to their
particular locales.

## HAZARDOUS MATERIALS AND WASTES 

Hazardous materials and wastes are regulated via a combination of
Federally and state mandated laws. A hazardous substance is defined as:

-   Any substance designated pursuant to Section 311(b)(2)(A) of the
    Clean Water Act, as amended (33 USC Section 466 et seq.)

-   Any toxic pollutant listed under Section 307(a) of the Clean Water
    Act, as amended (33 USC Section 466 et seq.)

-   Any element, compound, mixture, solution, or substance designated
    pursuant to Section 102 of the Comprehensive Environmental Response,
    Compensation, and Liability Act (CERCLA), as amended (42 USC Section
    9601 et seq.)

-   Any hazardous air pollutant listed under Section 112 of the Clean
    Air Act, as amended (42 USC Section 1857 et seq.)

-   Any imminently hazardous chemical substance or mixture with respect
    to which the EPA has taken action pursuant to Section 7 of the Toxic
    Substance Control Act, as amended (15 USC Section 2601 et seq.)

-   Any substance subject to management under Subtitle C of the Resource
    Conservation and Recovery Act (RCRA) as administered by the EPA
    Office of Solid Waste

-   Any substance as defined by a State Code for Hazardous Waste
    Control.

Hazardous substances should be disposed of in accordance with all
Federal and state hazardous waste regulations.

# Environmental Consequences

For each specific VACIS^®^ installation, a site-specific SED will be
prepared by CBP as described in Section 1.3 herein. Therefore, the
potential impacts and mitigation measures described in this section
would be augmented by a discussion of environmental consequences in each
SED based on a specific project area.

##  GEOLOGY AND SOILS

### No Action Alternative

Under the No Action alternative, current CBP inspection operations will
continue as normal. There will not be a requirement for the facility
construction or modification that may be associated with VACIS^®^
installation. Consequently, there will be no impact to geology or soils.

### Fielding and Operation of VACIS^®^

Preparing and installing the VACIS^®^ family of equipment will typically
require minimal construction at CBP border crossings and POEs.
Construction will typically occur on already-disturbed areas, is
consistent with current land uses, and will be in accordance with all
building codes and special earthquake provisions.

VACIS^®^II and Mobile VACIS^®^ sites will typically be located at
already-developed port and border stations that are paved with asphalt
or concrete. The VACIS^®^II operator station will be located in a
permanent structure, semi-permanent structure, or mobile van. At those
sites where the weather is often particularly harsh, entire VACIS^®^II
and Mobile VACIS^®^ systems may be located in an existing or
newly-constructed building. In these cases, existing warehouse buildings
may be used or the construction of prefabricated buildings on a concrete
foundation may be preferred. In either case, excavation or removal of
soil will typically be minimal.

Rail VACIS^®^ sites may be located at already-developed port and border
stations that are paved with asphalt or concrete, or may also be located
along railroad rights-of-way. These sites will typically require the
construction of a small concrete pier extending into the ground at least
20 feet deep for installation of the detector array tower, the
construction of a concrete pad for installation of the radiation source,
and a small cleared site for the operator station. The operator station
may be located in a permanent structure, semi-permanent structure, or
mobile van, depending on local site requirements.

The proposed Pallet VACIS^®^ sites may already have established covered
loading docks that will accommodate the equipment installation and
elemental protection for the equipment and the operators. At a minimum,
the Pallet VACIS^®^ will require a concrete pad large enough to
accommodate the Pallet VACIS^®^, Operator's Booth and maneuvering room
for a forklift. The proposed location at the commercial loading docks
will require electrical power for the Pallet system and Operator's
booth.

Construction may cause potential short-term erosion and soil loss;
however, applying appropriate best management practices (BMPs) during
construction can mitigate these impacts. Impacts to geological resources
and impacts from geo-hazards can be minimized by appropriate siting of
facilities and by applying appropriate geo-technical construction.
Furthermore, building design in compliance with EO 12699, "Seismic
Safety of Federal and Federally Assisted or Regulated New Building
Construction" and local codes and standards, can minimize effects of
seismic activity.

##  AIR QUALITY

### No Action Alternative

Under the No Action alternative, as congestion and traffic increase, air
quality at POEs and border crossings will likely worsen as more trucks
wait longer to pass through the inspection process. It should be noted,
however, that the fielding and operation of VACIS® systems will
typically result in an increase in the number of vehicles inspected once
inside the port facility, but will not typically affect the amount of
time required for vehicles to cross the border or enter POEs.

### Fielding and Operation of VACIS^®^

In deploying VACIS^®^, minimal quantities of fugitive dust (PM~10~) may
be produced as a result of construction activities. Other short-term
impacts to air quality from construction activities include carbon
monoxide and nitrogen oxides emissions resulting from
fossil-fuel-burning construction vehicles and equipment, and emissions
of reactive organic gases (ROGs) and hazardous air pollutants from
paints, thinners, and other solvents used at construction sites. The
implementation of BMPs during construction can keep emissions to
negligible levels. Examples of BMPs for construction activities include
watering disturbed areas, siting of staging areas to minimize fugitive
dust, and keeping construction vehicle engines tuned properly.
Quantities of these pollutants will likely be negligible.

### Idling Vehicle Emissions Calculations

Air quality impacts resulting from motor vehicle emissions will
primarily be the result of idling. As with driving emissions, idle
emissions are affected by a number of parameters. For analyses not
requiring detailed specific emission estimates tailored to local
conditions, the summary of idle emission factors found in Tables III and
IV can be used to obtain first-order approximations of emissions under
idle conditions.

The following acronyms and abbreviations are used in the tables:

-   CO: Carbon monoxide

-   GVW: Gross vehicle weight

-   NOx: Oxides of nitrogen (mostly NO and NO~2~)

-   PM~10~: Particulate matter, diameter ≤ 10 microns

-   psi: Pounds per square inch

-   RVP: Reid vapor pressure, a common method of expressing the
    volatility (tendency to evaporate) of gasoline; RVP is vapor
    pressure measured at 100° F (38° C)

-   VOC: Volatile organic compounds (for vehicles, this refers to
    exhaust emissions from incomplete combustion of gasoline, which is
    composed of a blend of hydrocarbon compounds).

Additionally, the following vehicle types are used in the tables:

-   LDGV: Light-duty gasoline-fueled vehicles, up to 6000 lb Gross
    Vehicle Weight (GVW) (gasoline-fueled passenger car)

-   LDGT: Light-duty gasoline-fueled trucks, up to 8500 lb GVW (includes
    pick-up trucks, minivans, passenger vans, sport-utility vehicles)

-   HDGV: Heavy-duty gasoline-fueled vehicles, 8501+ lb GVW (gas
    heavy-duty trucks)

-   LDDV: Light-duty diesel vehicles, up to 6000 lb GVW (passenger cars
    with diesel engines)

-   LDDT: Light-duty diesel trucks, up to 8500 lb GVW (light trucks with
    diesel engines)

-   HDDV: Heavy-duty diesel vehicles, 8501+ lb GVW (diesel heavy-duty
    trucks)

-   MC: Motorcycles (only those certified for highway use; all
    gasoline-fueled)

The tables present emission factors, in grams per hour (g/hr) and grams
per minute (g/min) of idle time, for volatile organic compounds (VOC),
carbon monoxide (CO), and nitrogen oxides (NOx). Idle emissions of
particulate matter (PM~10~) are provided for heavy-duty diesel vehicles
only; PM~10~ emissions from gasoline-fueled vehicles are negligible,
especially when the elimination of lead in gasoline and reductions of
sulfur content are considered. Emission factors are provided for both
summer and winter conditions for VOC, CO, and NOx. These idle emission
factors are from EPA's MOBILE5b highway vehicle emission factor model
(VOC, CO, NOx) and EPA's PART5 model (PM~10~ for heavy-duty diesel
vehicles only). These emission factors are national averages for all
vehicles in the in-use fleet of 1 January 1998 (winter) or 1 July 1998
(summer). PM~10~ idle emission factors for heavy-duty diesels are as of
1 January 1998.

[]{#__RefHeading___Toc66181303 .anchor}**Table III: Idle emission
factors, winter conditions (30°** F, 13.0 psi RVP gasoline).

+----------+------+------+------+------+------+------+------+------+
| **Pol    | *    | **LD | **LD | **HD | **LD | **LD | **HD | **   |
| lutant** | *Uni | GV** | GT** | GV** | DV** | DT** | DV** | MC** |
|          | ts** |      |      |      |      |      |      |      |
+----------+------+------+------+------+------+------+------+------+
| **VOC**  | g/hr | 21.1 | 30.7 | 44.6 | 3.63 | 4.79 | 12.6 | 20.1 |
|          |      |      |      |      |      |      |      |      |
| **\_**   | g    | 0    | 0    | 0    | 0    | 0    | 0    | 0    |
|          | /min | .352 | .512 | .734 | .061 | .080 | .211 | .335 |
+----------+------+------+------+------+------+------+------+------+
| **CO**   | g/hr | 371  | 487  | 682  | 10.1 | 11.5 | 94.6 | 388  |
|          |      |      |      |      |      |      |      |      |
| **\_**   | g    | 6.19 | 8.12 | 11.4 | 0    | 0    | 1.58 | 6.47 |
|          | /min |      |      |      | .168 | .191 |      |      |
+----------+------+------+------+------+------+------+------+------+
| **NOx**  | g/hr | 6.16 | 7.47 | 11.8 | 6.66 | 6.89 | 56.7 | 2.51 |
|          |      |      |      |      |      |      |      |      |
| **\_**   | g    | 0    | 0    | 0    | 0    | 0    | 0    | 0    |
|          | /min | .103 | .125 | .196 | .111 | .115 | .945 | .042 |
+----------+------+------+------+------+------+------+------+------+

*Source: EPA420-F-014, Emission Facts, Idling Vehicle Emissions, United
States EPA, Air and Radiation, Office of Mobile Sources, April 1998*

[]{#__RefHeading___Toc66181304 .anchor}**Table IV: Idle emission
factors, summer conditions (75°** F, 9.0 psi RVP gasoline).

+---------+------+------+------+------+------+------+------+------+
| **Poll  | *    | **LD | **LD | **HD | **LD | **LD | **HD | **   |
| utant** | *Uni | GV** | GT** | GV** | DV** | DT** | DV** | MC** |
|         | ts** |      |      |      |      |      |      |      |
+=========+======+======+======+======+======+======+======+======+
| **VOC** | g/hr | 16.1 | 24.1 | 35.8 | 3.53 | 4.63 | 12.5 | 19.4 |
|         |      |      |      |      |      |      |      |      |
|         | g    | 0    | 0    | 0    | 0    | 0    | 0    | 0    |
|         | /min | .269 | .401 | .597 | .059 | .077 | .208 | .324 |
+---------+------+------+------+------+------+------+------+------+
| **CO**  | g/hr | 229  | 339  | 738  | 9.97 | 11.2 | 94.0 | 435  |
|         |      |      |      |      |      |      |      |      |
|         | g    | 3.82 | 5.65 | 12.3 | 0    | 0    | 1.57 | 7.26 |
|         | /min |      |      |      | .166 | .187 |      |      |
+---------+------+------+------+------+------+------+------+------+
| **NOx** | g/hr | 4.72 | 5.71 | 10.2 | 6.50 | 6.67 | 55.0 | 1.69 |
|         |      |      |      |      |      |      |      |      |
|         | g    | 0    | 0    | 0    | 0    | 0    | 0    | 0    |
|         | /min | .079 | .095 | .170 | .108 | .111 | .917 | .028 |
+---------+------+------+------+------+------+------+------+------+

*Source: EPA420-F-014, Emission Facts, Idling Vehicle Emissions, United
States EPA, Air and Radiation, Office of Mobile Sources, April 1998*

#### Particulate Matter Emissions

The only vehicle category for which EPA has idle PM~10~ emission factors
is heavy-duty diesels. Particulate emissions are also observed to be
relatively insensitive to temperature, and so "winter" and "summer"
emission factors for idle PM~10~ are the same. These emissions are
summarized in Table V.

[]{#__RefHeading___Toc66181305 .anchor}**Table V**: Particulate matter
emission factors

  ----------------------------------- -----------------------------------
  Engine Size                         Emissions

  Light/Medium HDDVs (8501-33,000 lb  2.62 g/hr (0.044 g/min)
  GVW)                                

  Heavy HDDVs (33,001+ lb GVW)        2.57 g/hr (0.043 g/min)

  HDD buses (all buses, urban and     2.52 g/hr (0.042 g/min)
  inter-city travel)                  

  Average of all heavy-duty diesel    2.59 g/hr (0.043 g/min)
  engines                             
  ----------------------------------- -----------------------------------

*Source: EPA420-F-014, Emission Facts, Idling Vehicle Emissions, United
States EPA, Air and Radiation, Office of Mobile Sources, April 1998*

#### Potential Vehicle Idling Emissions Resulting from the Operation of VACIS^®^

Tables VI, VII, and VIII represent the idling vehicle emissions likely
to result from the operation of VACIS^®^. The shaded data in each table
identify the worst-case scenario for each pollutant. Calculations were
made based on the following assumptions:

> 1\) VACIS^®^ processes 10 vehicles per hour;
>
> 2\) VACIS^®^ will be operated during two 8-hour work shifts (16 hours)
> equaling 160 inspections per day;
>
> 3\) At any given time during each work shift, one vehicle will be
> undergoing inspection by VACIS^®^, and five vehicles will be queued
> for inspection;
>
> 4\) The vehicle undergoing inspection and all queued vehicles will be
> idling; and, therefore
>
> 5\) Calculated emissions are equivalent to six vehicles of each type
> shown idling simultaneously over a period of 16 hours per day.

[]{#__RefHeading___Toc66181306 .anchor}**Table VI: Idling emissions,
winter conditions (30°** F 13.0 psi RVP gasoline), January-June

+------+-------+------+------+------+------+------+------+------+
| P    | Units | LDGV | LDGT | HDGV | LDDV | LDDT | HDDV | MC   |
| ollu |       |      |      |      |      |      |      |      |
| tant |       |      |      |      |      |      |      |      |
+======+=======+======+======+======+======+======+======+======+
| **V  | lb/hr | 0    | 0    | 0    | 0    | 0    | 0    | 0    |
| OC** |       | .282 | .408 | .588 | .048 | .066 | .168 | .264 |
|      | l     |      |      |      |      |      |      |      |
|      | b/day | 4    | 6    | 9    | 0    | 1    | 2    | 4    |
|      |       | .512 | .528 | .408 | .768 | .056 | .688 | .224 |
|      | lb    |      |      |      |      |      |      |      |
|      | /half | 82   | 119  | [171 | 14   | 19   | 49   | 77   |
|      | yr    | 3.44 | 1.36 | 6.96 | 0.16 | 2.72 | 0.56 | 0.88 |
|      |       |      |      | ]{.m |      |      |      |      |
|      | lb/yr | 164  | 238  | ark} | 28   | 38   | 98   | 154  |
|      |       | 6.88 | 2.72 |      | 0.32 | 5.44 | 1.18 | 1.76 |
|      | tons  |      |      | [343 |      |      |      |      |
|      | /half | 0    | 0    | 3.92 | 0    | 0    | 0    | 0    |
|      | yr    | .408 | .594 | ]{.m | .066 | .096 | .240 | .384 |
|      |       |      |      | ark} |      |      |      |      |
|      | to    | 0    | 1    |      | 0    | 0    | 0    | 0    |
|      | ns/yr | .816 | .188 | [0   | .132 | .192 | .480 | .768 |
|      |       |      |      | .858 |      |      |      |      |
|      |       |      |      | ]{.m |      |      |      |      |
|      |       |      |      | ark} |      |      |      |      |
|      |       |      |      |      |      |      |      |      |
|      |       |      |      | [1   |      |      |      |      |
|      |       |      |      | .716 |      |      |      |      |
|      |       |      |      | ]{.m |      |      |      |      |
|      |       |      |      | ark} |      |      |      |      |
+------+-------+------+------+------+------+------+------+------+
| **   | lb/hr | 4    | 6    | 9    | 0    | 0    | 1    | 5    |
| CO** |       | .908 | .444 | .024 | .132 | .150 | .254 | .130 |
|      | l     |      |      |      |      |      |      |      |
|      | b/day | 78   | 103  | 144  | 2    | 2    | 20   | 82   |
|      |       | .528 | .104 | .384 | .112 | .400 | .064 | .080 |
|      | lb    |      |      |      |      |      |      |      |
|      | /half | 1433 | 1881 | [    | 38   | 43   | 366  | 1497 |
|      | yr    | 1.36 | 6.48 | 2635 | 5.44 | 8.00 | 1.68 | 9.60 |
|      |       |      |      | 0.08 |      |      |      |      |
|      | lb/yr | 2866 | 3763 | ]{.m | 77   | 87   | 732  | 2995 |
|      |       | 2.72 | 2.96 | ark} | 0.88 | 6.00 | 3.36 | 9.20 |
|      | tons  |      |      |      |      |      |      |      |
|      | /half | 7    | 9    | [    | 0    | 0    | 1    | 7    |
|      | yr    | .164 | .408 | 5270 | .192 | .216 | .830 | .488 |
|      |       |      |      | 0.16 |      |      |      |      |
|      | to    | 14   | 18   | ]{.m | 0    | 0    | 3    | 14   |
|      | ns/yr | .328 | .816 | ark} | .384 | .432 | .660 | .976 |
|      |       |      |      |      |      |      |      |      |
|      |       |      |      | [13  |      |      |      |      |
|      |       |      |      | .170 |      |      |      |      |
|      |       |      |      | ]{.m |      |      |      |      |
|      |       |      |      | ark} |      |      |      |      |
|      |       |      |      |      |      |      |      |      |
|      |       |      |      | [26  |      |      |      |      |
|      |       |      |      | .340 |      |      |      |      |
|      |       |      |      | ]{.m |      |      |      |      |
|      |       |      |      | ark} |      |      |      |      |
+------+-------+------+------+------+------+------+------+------+
| **N  | lb/hr | 0    | 0    | 0    | 0    | 0    | 0    | 0    |
| Ox** |       | .084 | .096 | .156 | .090 | .090 | .750 | .036 |
|      | l     |      |      |      |      |      |      |      |
|      | b/day | 1    | 1    | 2    | 1    | 1    | 12   | 0    |
|      |       | .344 | .536 | .496 | .440 | .440 | .000 | .576 |
|      | lb    |      |      |      |      |      |      |      |
|      | /half | 24   | 28   | 45   | 26   | 26   | [219 | 10   |
|      | yr    | 5.28 | 0.32 | 5.52 | 2.80 | 2.80 | 0.00 | 5.12 |
|      |       |      |      |      |      |      | ]{.m |      |
|      | lb/yr | 49   | 56   | 91   | 52   | 52   | ark} | 21   |
|      |       | 0.56 | 0.64 | 1.04 | 5.60 | 5.60 |      | 0.24 |
|      | tons  |      |      |      |      |      | [438 |      |
|      | /half | 0    | 0    | 0    | 0    | 0    | 0.00 | 0    |
|      | yr    | .120 | .138 | .222 | .126 | .126 | ]{.m | .048 |
|      |       |      |      |      |      |      | ark} |      |
|      | to    | 0    | 0    | 0    | 0    | 0    |      | 0    |
|      | ns/yr | .240 | .276 | .444 | .252 | .252 | [1   | .096 |
|      |       |      |      |      |      |      | .092 |      |
|      |       |      |      |      |      |      | ]{.m |      |
|      |       |      |      |      |      |      | ark} |      |
|      |       |      |      |      |      |      |      |      |
|      |       |      |      |      |      |      | [2   |      |
|      |       |      |      |      |      |      | .184 |      |
|      |       |      |      |      |      |      | ]{.m |      |
|      |       |      |      |      |      |      | ark} |      |
+------+-------+------+------+------+------+------+------+------+

[]{#__RefHeading___Toc66181307 .anchor}**Table VII: Idling emissions,
summer conditions (75°** F 9.0 psi RVP gasoline), July-December

+------+-------+------+------+------+------+------+------+------+
| P    | Units | LDGV | LDGT | HDGV | LDDV | LDDT | HDDV | MC   |
| ollu |       |      |      |      |      |      |      |      |
| tant |       |      |      |      |      |      |      |      |
+------+-------+------+------+------+------+------+------+------+
| **V  | lb/hr | 0    | 0    | 0    | 0    | 0    | 0    | 0    |
| OC** |       | .210 | .318 | .474 | .048 | .060 | .168 | .258 |
|      | l     |      |      |      |      |      |      |      |
|      | b/day | 3.36 | 5    | 7    | 0    | 0    | 2    | 4    |
|      |       |      | .088 | .584 | .768 | .960 | .688 | .128 |
|      | lb    | 61   |      |      |      |      |      |      |
|      | /half | 3.20 | 92   | [138 | 14   | 17   | 49   | 75   |
|      | yr    |      | 8.56 | 4.08 | 0.16 | 5.20 | 0.56 | 3.36 |
|      |       | 122  |      | ]{.m |      |      |      |      |
|      | lb/yr | 6.40 | 185  | ark} | 28   | 35   | 98   | 150  |
|      |       |      | 7.12 |      | 0.32 | 0.40 | 1.18 | 6.72 |
|      | tons  | 0    |      | [276 |      |      |      |      |
|      | /half | .306 | 0    | 8.16 | 0    | 0    | 0    | 0    |
|      | yr    |      | .462 | ]{.m | .660 | .084 | .240 | .372 |
|      |       | 0    |      | ark} |      |      |      |      |
|      | to    | .612 | 0    |      | 1    | 0    | 0    | 0    |
|      | ns/yr |      | .924 | [0   | .320 | .168 | .480 | .744 |
|      |       |      |      | .690 |      |      |      |      |
|      |       |      |      | ]{.m |      |      |      |      |
|      |       |      |      | ark} |      |      |      |      |
|      |       |      |      |      |      |      |      |      |
|      |       |      |      | [1   |      |      |      |      |
|      |       |      |      | .380 |      |      |      |      |
|      |       |      |      | ]{.m |      |      |      |      |
|      |       |      |      | ark} |      |      |      |      |
+------+-------+------+------+------+------+------+------+------+
| **   | lb/hr | 3    | 4    | 9    | 0    | 0    | 1    | 5    |
| CO** |       | .030 | .482 | .762 | .132 | .150 | .242 | .754 |
|      | l     |      |      |      |      |      |      |      |
|      | b/day | 4    | 71   | 156  | 2    | 2    | 19   | 92   |
|      |       | 8.48 | .712 | .192 | .112 | .400 | .872 | .064 |
|      | lb    |      |      |      |      |      |      |      |
|      | /half | 884  | 1308 | [    | 38   | 43   | 362  | 1680 |
|      | yr    | 7.60 | 7.44 | 2850 | 5.44 | 8.00 | 6.64 | 1.68 |
|      |       |      |      | 5.04 |      |      |      |      |
|      | lb/yr | 1769 | 2617 | ]{.m | 77   | 87   | 725  | 3360 |
|      |       | 5.20 | 4.88 | ark} | 0.88 | 6.00 | 3.28 | 3.36 |
|      | tons  |      |      |      |      |      |      |      |
|      | /half | 4    | 6    | [    | 0    | 0    | 1    | 8    |
|      | yr    | .422 | .540 | 5701 | .192 | .216 | .812 | .400 |
|      |       |      |      | 0.08 |      |      |      |      |
|      | to    | 8    | 13   | ]{.m | 0    | 0    | 3    | 16   |
|      | ns/yr | .844 | .080 | ark} | .384 | .432 | .624 | .800 |
|      |       |      |      |      |      |      |      |      |
|      |       |      |      | [14  |      |      |      |      |
|      |       |      |      | .250 |      |      |      |      |
|      |       |      |      | ]{.m |      |      |      |      |
|      |       |      |      | ark} |      |      |      |      |
|      |       |      |      |      |      |      |      |      |
|      |       |      |      | [28  |      |      |      |      |
|      |       |      |      | .500 |      |      |      |      |
|      |       |      |      | ]{.m |      |      |      |      |
|      |       |      |      | ark} |      |      |      |      |
+------+-------+------+------+------+------+------+------+------+
| **N  | lb/hr | 0    | 0    | 0    | 0    | 0    | 0    | 0    |
| Ox** |       | .060 | .078 | .132 | .084 | .090 | .726 | .024 |
|      | l     |      |      |      |      |      |      |      |
|      | b/day | 0    | 1    | 2    | 1    | 1    | 11   | 0    |
|      |       | .960 | .248 | .112 | .344 | .440 | .616 | .384 |
|      | lb    |      |      |      |      |      |      |      |
|      | /half | 17   | 22   | 38   | 24   | 26   | [211 | 7    |
|      | yr    | 5.20 | 7.76 | 5.44 | 5.28 | 2.80 | 9.92 | 0.08 |
|      |       |      |      |      |      |      | ]{.m |      |
|      | lb/yr | 35   | 45   | 77   | 49   | 52   | ark} | 14   |
|      |       | 0.40 | 5.52 | 0.88 | 0.56 | 5.60 |      | 0.16 |
|      | tons  |      |      |      |      |      | [423 |      |
|      | /half | 0    | 0    | 0    | 0    | 0    | 9.84 | 0    |
|      | yr    | .084 | .108 | .192 | .120 | .126 | ]{.m | .030 |
|      |       |      |      |      |      |      | ark} |      |
|      | to    | 0    | 0    | 0    | 0    | 0    |      | 0    |
|      | ns/yr | .168 | .216 | .384 | .240 | .252 | [1   | .060 |
|      |       |      |      |      |      |      | .056 |      |
|      |       |      |      |      |      |      | ]{.m |      |
|      |       |      |      |      |      |      | ark} |      |
|      |       |      |      |      |      |      |      |      |
|      |       |      |      |      |      |      | [2   |      |
|      |       |      |      |      |      |      | .112 |      |
|      |       |      |      |      |      |      | ]{.m |      |
|      |       |      |      |      |      |      | ark} |      |
+------+-------+------+------+------+------+------+------+------+

[]{#__RefHeading___Toc66181308 .anchor}**Table VIII**: Particulate
matter emissions (PM10), January-December

+----------+----------+------------+----------+----------+----------+
| **Pol    | *        | **Li       | **Heavy  | **HDD    | *        |
| lutant** | *Units** | ght/Medium | HDDV**   | Buses**  | *Average |
|          |          | HDDV**     |          |          | of all   |
|          |          |            |          |          | Heavy    |
|          |          |            |          |          | Duty     |
|          |          |            |          |          | Diesel   |
|          |          |            |          |          | E        |
|          |          |            |          |          | ngines** |
+----------+----------+------------+----------+----------+----------+
| **PM10** | > lb/hr  | 0.036      | 0.036    | 0.036    | 0.036    |
|          | >        |            |          |          |          |
|          | > lb/day | 0.576      | 0.576    | 0.576    | 0.576    |
|          | >        |            |          |          |          |
|          | >        | 105.12     | 105.12   | 105.12   | [105.12  |
|          |  lb/half |            |          |          | ]{.mark} |
|          | > yr     | 210.24     | 210.24   | 210.24   |          |
|          | >        |            |          |          | [210.24  |
|          | > lb/yr  | 0.048      | 0.048    | 0.048    | ]{.mark} |
|          | >        |            |          |          |          |
|          | > t      | 0.096      | 0.096    | 0.096    | [0.048   |
|          | ons/half |            |          |          | ]{.mark} |
|          | > yr     |            |          |          |          |
|          | >        |            |          |          | [0.096   |
|          | >        |            |          |          | ]{.mark} |
|          |  tons/yr |            |          |          |          |
+----------+----------+------------+----------+----------+----------+

### Worst Case Idling Vehicle Emissions

Using an equal split of 6 months per "winter" and "summer" emissions
factors, analysis of the data provided shows that the worst-case
scenario (operating only that vehicle type with the highest emission
rate) would result in the impacts as shown in Table IX.

[]{#__RefHeading___Toc66181309 .anchor}**Table IX**: Worst case idling
vehicle emissions

  ----------------------- ----------------------- -----------------------
  **Pollutant**           **Units (tons/yr)**     **Vehicle Type**

  **VOC**                 1.548                   HDGV

  **CO**                  27.420                  HDGV

  **NOx**                 2.148                   HDDV

  **PM~10~**              0.096                   All
  ----------------------- ----------------------- -----------------------

Table X compares the data presented in Table XI with the conformity
criteria for nonattainment areas. This comparison shows that the
estimated yearly emissions attributable to idling vehicles are well
below the allowable limits set in 40 CFR Part 93.153, *Determining
Conformity of Federal Actions to State or Federal Implementation Plans*
(the rule). The rule applies to those Federal actions that are located
in areas of nonattainment of the NAAQS.

[]{#__RefHeading___Toc66181310 .anchor}**Table X**: Conformity criteria
for nonattainment areas

  ------------------------------------------------------------------------
  Pollutant                          Criterion       Worst Case Idling
                                     (tons/yr)       (tons/yr)
  ---------------------------------- --------------- ---------------------
  **Ozone (VOCs or NOx):**                           1.548 (VOC);\
                                                     2.148 (NOx)

  **- Serious NAAs**                 50              

  **- Severe NAAs**                  25              

  **- Extreme NAAs**                 10              

  \-**Other ozone NAAs outside an    100             
  ozone transport region**                           

  \-**Marginal and moderate NAAs                     
  inside an ozone transport region**                 

  **CO:\                             100             27.420
  - All NAAs**                                       

  **SO2 or NO2:\                     100             
  - All NAAs**                                       

  **PM~10~:**                                        0.096

  **- Moderate NAAs**                100             

  **- Serious NAAs**                 70              

  **Pb:\                             25              
  - All NAAs**                                       
  ------------------------------------------------------------------------

*Source: 40 CFR Part 93.153, Determining Conformity of Federal Actions
to State or Federal Implementation Plans*

The rates shown in Table XI are those applicable to maintenance areas.
For ease of comparison, the worst case idling emission data from Table
IX are also shown.

[]{#__RefHeading___Toc66181311 .anchor}**Table XI**: Conformity criteria
for maintenance areas

  -----------------------------------------------------------------------
  Pollutant                          Criterion      Worst Case Idling
                                     (tons/yr)      (tons/yr)
  ---------------------------------- -------------- ---------------------
  **Ozone (NOx), SO2 or NO2:\        100            2.148 (NOx)
  - All maintenance areas**                         

  **Ozone (VOCs):**                                 1.548

  **- Maintenance areas inside an\   50             
  ozone transport region**                          

  **- Maintenance area outside an\   100            
  ozone transport region**                          

  **Carbon Monoxide\                 100            27.420
  - All maintenance areas**                         

  **PM~10~:\                         100            0.096
  - All maintenance areas**                         

  **Pb:\                             25             
  - All maintenance areas**                         
  -----------------------------------------------------------------------

*Source: 40 CFR Part 93.153, Determining Conformity of Federal Actions
to State or Federal Implementation Plans*

##  HYDROLOGY AND WATER QUALITY

### No Action Alternative

Under this alternative, impacts to water quality at existing POEs and
border crossings will not change. Hydrology will not be impacted as a
result of implementing the No Action Alternative.

### Fielding and Operation of VACIS^®^

Construction related to the installation of VACIS^®^ has the potential
to cause increased runoff and sedimentation during construction, and in
the period between construction and vegetation re-establishment.
Implementing stormwater and erosion-control BMPs during construction can
mitigate these impacts. In general, construction BMPs include
erosion-control and sediment-control techniques to limit the exposure
and transport of sediment, methods to minimize contact of stormwater
with construction materials and wastes, proper vehicle maintenance and
fueling practices, and minimizing off-site tracking of sediment.

A National Pollution Discharge Elimination System (NPDES) General Permit
or an NPDES Stormwater Construction Permit may be required for new
construction. CBP will confer with Regional Water Quality Control Boards
to determine permit requirements.

Due to minimal civil construction requirements associated with VACIS,
surface runoff will be negligible. No impacts to hydrology are expected
as a result of this alternative.

##  FLOODPLAINS

### No Action Alternative

The No Action alternative would not result in direct or indirect impacts
to floodplains.

### 6.4.2 Fielding and Operation of VACIS^®^ {#fielding-and-operation-of-vacis-3 .unnumbered}

Under this alternative, structures associated with the installation and
operation of VACIS^®^ will be built in compliance with EO 11988 and 44
CFR Part 9; therefore, a Federally funded facility cannot be sited in a
100-year floodplain unless there are no reasonable alternatives. Except
in these rare circumstances, there will be no impact to the floodplain.

If structures associated with the installation and operation of VACIS^®^
are constructed within a 100-year floodplain, the structures will be
elevated or flood proofed in compliance with the National Flood
Insurance Program and local floodplain ordinances. CBP will analyze and
identify potential adverse impacts the VACIS^®^ installation might have
on the floodplain. CBP would obtain the FEMA Flood Insurance Rate Map
(FIRM) the Flood Boundary Floodway Map (FBFM) and the Flood Insurance
Study (FIS) for the local site considered for construction of a VACIS^®^
facility. If a detailed map (FIRM or FBFM) is not available, CBP will
consult an FEMA Flood Hazard Boundary Map (FHBM). The regulatory
floodway would be identified, and the VACIS^®^ facility would be
constructed such that there would be no encroachments upon the floodway,
including fill, new construction, substantial improvements of structures
or facilities, or other development that would result in any increase in
flood levels within the community during the occurrence of the base
flood (i.e., 100-year) discharge.

In compliance with 44 CFR Part 9, a notice will be publicly circulated
explaining the project and identifying the reasons for the project being
sited in the floodplain.

##  BIOLOGICAL RESOURCES

### No Action Alternative

This alternative will have little or no impacts on biological resources
in the project area.

### Fielding and Operation of VACIS^®^

Activities associated with this alternative are primarily
construction-related and will not typically have an adverse affect on
biological resources in the project area. Most of the construction will
occur on concrete and asphalt surfaces in industrial sites. Construction
of Rail VACIS^®^ installations may result in the disturbance of a
limited amount of existing vegetation and the loss of associated
wildlife habitat within the footprint of the detector array, radiation
source, and operator station. Vegetation management within these areas
will not have adverse effects on biological resources in the immediate
vicinity of the Rail VACIS^®^ installation.

Construction and operation of VACIS^®^ will not have an impact on
wetlands or waters of the U.S. If a project will affect wetlands, CBP
will contact the USACE and local authorities to obtain a Section 404
Permit for wetland activities. CBP will mitigate damage to wetlands per
the Section 404 Permit, and otherwise comply with EO 11990.

Permits from the USACE will be required if any streams or other
watercourses are impacted. Coordination with the USFWS, state, and local
authorities as well as compliance with local statutes will be required.

##  THREATENED AND ENDANGERED SPECIES

### No Action Alternative

Activities associated with the No Action alternative will not have an
impact on proposed or listed threatened and endangered species.

### Fielding and Operation of VACIS^®^

Activities associated with this alternative are primarily related to
construction and operation of VACIS^®^ in industrial settings (border
crossings, POEs) and will not have an impact on proposed or listed
threatened and endangered species.

Construction of Rail VACIS^®^ may disturb the area within the footprint
of the detector array, radiation source, and operator station. The
probability is low that the ingress and egress of equipment and
personnel will adversely affect proposed or listed species present in
the immediate vicinity of the Rail VACIS^®^ installation. Potential
impacts will be short-term and may include disturbance/displacement of
individuals, and incidental disruption of suitable habitat.

If Federally listed or proposed threatened and endangered species have
the potential to be impacted, CBP will initiate consultation with the
USFWS or the NMFS, in compliance with Section 7 of the Endangered
Species Act. Potential impacts to Federally listed or proposed
threatened and endangered species will be evaluated and documented in an
SED.

##  CULTURAL RESOURCES

### No Action Alternative

Under this alternative, CBP will not fund any alternative action and, as
a result, no further cultural resources studies will be required under
Section 106 of the National Historic Preservation Act (NHPA).

### Fielding and Operation of VACIS^®^

Activities associated with this alternative are primarily related to
construction and operation of VACIS^®^ in industrial settings (POEs) and
will not have an impact on sites which are listed on, or potentially
eligible for, the National Register of Historic Places.

Construction of Rail VACIS^®^ may disturb the area within the footprint
of the detector array, radiation source, and operator station. The
probability is low that the ingress and egress of equipment and
personnel will adversely affect historical resources in the immediate
vicinity of the Rail VACIS^®^ installation.

If historical resources have the potential to be impacted, CBP will
initiate consultation with the applicable SHPO, in compliance with
Section 106 of the NHPA. Potential impacts to historical resources will
be evaluated and documented in an SED. Similarly, CBP will examine such
areas in compliance with Section 110 of the Act, which requires Federal
agencies to assume responsibility for the preservation of historic
properties under their purview.

##  SOCIOECONOMICS

### No Action Alternative

Under the No Action alternative, CBP inspections of vehicles will be
conducted as they are today and it is assumed that traffic will increase
at POEs. Vehicle backups may worsen, if an increasing number of trucks
require inspection, and they will wait longer to pass through the
inspection process. This can result in adverse impacts to businesses
that depend on the timely flow of goods across the border. As noted in
Section 6.2.1 herein, the fielding and operation of VACIS^®^ will not
typically impact (positively or negatively) the waiting time associated
with entry into the U.S.

### Fielding and Operation of VACIS^®^

Population will not be impacted because this alternative is not expected
to displace persons and business to other locations or attract new
population to the project area. Housing resources will not be impacted
because the population demand for these necessities is not expected to
increase with this alternative. This alternative is not expected to
impact property values. Impacts to the local economy, as a whole, will
be negligible. Demographic and economic indicators for local residents
will be studied to determine whether a disproportionate number (defined
as greater than 50 percent) of minority or low-income persons may be
adversely affected by the alternative. Potential environmental justice
impacts (per EO 12898) will be addressed in each site-specific SED.

##  LAND USE AND ZONING

### No Action Alternative

No change in land use and zoning will occur under the No Action
alternative.

### Fielding and Operation of VACIS^®^

The installation and operation of VACIS^®^ proposed under this
alternative will not impact land use or zoning. Buildings which
currently comply with local zoning ordinances are not expected to impact
land use or zoning as a result of making improvements. However,
improvements are generally prohibited for properties with nonconforming
uses unless the structure is brought into compliance. A nonconforming
use is one that is currently out of compliance with the zoning
ordinance, usually because the structure was built before the current
zoning regulation was executed. In such cases, local governments may
consider granting variances so that properties with nonconforming uses
can be improved without making other structural changes necessary to
comply with the zoning ordinance. Otherwise, CBP may seek a variance or
an amendment to the zoning designation so that the proposed use
complies.

## PUBLIC SERVICES

###  No Action Alternative

The No Action alternative will not affect communities' requirements for
public services.

### 6.10.2 Fielding and Operation of VACIS^®^ {#fielding-and-operation-of-vacis-9 .unnumbered}

Under this alternative, sufficient public service utility capacity will
exist at POEs to adequately handle operation of VACIS^®^ installations.

## TRANSPORTATION

###  No Action Alternative

Under the No Action alternative, it is assumed traffic will increase at
POEs.

###  Fielding and Operation of VACIS^®^

Temporary detours, traffic delays, and congestion may occur during
construction activities. Coordinating detour routes and signs with
appropriate cognizant agencies will mitigate these temporary impacts.

## NOISE

###  No Action Alternative

Under the No Action alternative, CBP-funded alternative actions will not
be pursued and, therefore, will not generate any noise in addition to
the noise already existing at POEs.

###  Fielding and Operation of VACIS^®^

In considering the noise associated with VACIS^®^II, Pallet VACIS^®^ ,
and Mobile VACIS^®^ operations, the installation of the Mobile VACIS^®^
may be considered the noisiest of the three, due to the fact that the
Mobile VACIS^®^ operators are located physically closer to noise
generators (Mobile VACIS^®^ and the vehicles being scanned) than in
VACIS^®^II and Pallet installations. Noise measurements were obtained
for Mobile VACIS^®^ using an SLM, and the acquired data are presented in
Table XII:[^22]

[]{#__RefHeading___Toc66181312 .anchor}**Table XII: Mobile VACIS^®^**
noise measurement data

+------------+------------------------------+--------------------------+
| Noise      | Operation                    | SLM Location             |
| (dBA)      |                              |                          |
+------------+------------------------------+--------------------------+
| 75         | Mobile VACIS^®^ (truck       | 1 ft from driver's side  |
|            | engine) idling               | of                       |
|            |                              |                          |
|            |                              | Mobile VACIS^®^ truck    |
+------------+------------------------------+--------------------------+
| 69         | Mobile VACIS^®^ (truck       | 22 ft from Mobile        |
|            | engine) idling               | VACIS^®^                 |
+------------+------------------------------+--------------------------+
|            |                              |                          |
+------------+------------------------------+--------------------------+
| 84         | Mobile VACIS^®^ equipment on | 1 ft from Mobile         |
|            | idle mode                    | VACIS^®^ motor           |
+------------+------------------------------+--------------------------+
| 70         | Mobile VACIS^®^ equipment on | 22 ft from Mobile        |
|            | idle mode                    | VACIS^®^ motor           |
+------------+------------------------------+--------------------------+
|            |                              |                          |
+------------+------------------------------+--------------------------+
| 70         | Mobile VACIS^®^ scanning a   | 25 ft from Mobile        |
|            | vehicle                      | VACIS^®^                 |
+------------+------------------------------+--------------------------+

Based on the noise measurements, the detected noise level never exceeds
the "action level" of 85 dBA for continuous noise, as specified by OSHA.
As a result, the fielding and operation of VACIS^®^II, Mobile VACIS^®^
and Pallet VACIS^®^ will not have a significant noise impact.

In considering the noise associated with Rail VACIS^®^ operations, 40
CFR Part 201.12 establishes noise standards for locomotive operations
under moving conditions. Specifically, it states that locomotives
manufactured on or before 31 December 1979 cannot produce sound levels
in excess of 96 dBA measured at 100 feet, and that locomotives
manufactured after 31 December 1979 cannot produce sound levels in
excess of 90 dBA measured at 100 feet. Although Rail VACIS^®^ workers'
noise exposures are not expected to be measured above the OSHA noise
regulatory "action level" (i.e., 85 dBA for an 8-hour work shift), it is
possible that transient loud noise from the movement of railroad
locomotives and cars may require operators to wear acceptable hearing
protection equipment during those parts of Rail VACIS^®^ operations.

Noise from the Mobile VACIS^®^ will not exceed limits from EPA Noise
Control Act regulations in Title 40 Code of Federal Regulations (CFR)
Part 205, "Transportation Equipment Noise Emission Controls." None of
the VACIS^®^ configurations are anticipated to violate local Nuisance
Noise ordinances.

## HAZARDOUS MATERIALS AND WASTES

###  No Action Alternative

Under the No Action alternative, there will not be an increase, or a
decrease, in the use of hazardous materials or the generation of
hazardous wastes.

### 6.13.2 Fielding and Operation of VACIS^®^ {#fielding-and-operation-of-vacis-12 .unnumbered}

The construction of VACIS^®^ facilities has the potential to result in
impacts from hazardous wastes or materials. Construction activities will
follow legal requirements for storage, handling, use, and disposal of
hazardous materials and wastes. Operation and maintenance of VACIS^®^
has little potential impact associated with hazardous materials and
wastes. Activities including greasing of VACIS^®^II tracks and refueling
of Mobile VACIS^®^ will follow legal requirements for storage, handling,
use, and disposal of hazardous materials and wastes.

## RADIOLOGICAL IMPACTS

###  No Action Alternative

Under the No Action alternative, there will be no changes to the
radiological consequences associated with current CBP methods for
vehicle and cargo inspections.

### 6.14.2 Fielding and Operation of VACIS^®^ {#fielding-and-operation-of-vacis-13 .unnumbered}

Radiation is measured using units that people seldom encounter. It is
important to relate the amount of radiation received by the body to its
physiological effects. Two terms used to relate the amount of radiation
received by the body are "absorbed dose" and "dose equivalent." The
specific units of measurement are:

-   Rad -- The term "rad" (radiation absorbed dose) is the special unit
    of absorbed dose of 100 ergs per gram.\
    \
    Different materials that receive the same exposure may not absorb
    the same amount of energy. The rad is the basic unit of the absorbed
    dose of radiation (i.e., alpha, beta, gamma, and neutron) to the
    energy they impart in materials. The dose of one rad indicates the
    absorption of 100 ergs per gram of absorbing material. One
    thousandth of a rad (millirad) is abbreviated "mrad," and one
    millionth of a rad (microrad) is abbreviated "µrad."

-   Rem -- The term "rem" (Roentgen equivalent man) is a special unit
    used for expressing dose equivalent.\
    \
    Some types of nuclear radiation produce greater biological effects
    for the same amount of energy imparted than other types. The rem is
    a unit that relates the dose of absorbed radiation to the biological
    effect of that dose. Therefore, to relate the absorbed dose of
    specific types of radiation, a "quality factor" must be multiplied
    by the dose in rad. One thousandth of a rem (millirem) is
    abbreviated "mrem," and one millionth of a rem (microrem) is
    abbreviated "µrem." For the gamma rays used in VACIS®, the quality
    factor is 1, meaning that 1 rad of dose results in 1 rem of dose
    equivalent.\
    \
    Dose equivalent (DE) in rem is the product of the amount of
    radiation absorbed in tissue, quality factor (QF), and each
    modifying factor (MF) at the location of interest. The formula for
    calculating dose equivalent is:

DE = rad x QF x MF.

#### Regulations and Dose Criteria

The Nuclear Regulatory Commission (NRC) promulgates regulations and
establishes standards for protection against radiation arising out of
activities conducted under licenses issued by the Commission. These
requirements are set forth in 10 CFR Part 20.

In 10 CFR Part 20, the NRC identifies two classifications of radiation
dose to people. The first classification, "occupational dose", is the
dose received by an individual in a restricted area or in the course of
employment in which the individual's assigned duties involve exposure to
radiation and to radioactive material from licensed and unlicensed
sources of radiation, whether in the possession of the licensee or other
person. It does not include the dose received from background radiation,
as a patient from medical practices, from voluntary participation in
medical research programs, or as a member of the general public. The
individuals subject to the occupational dose classification must closely
monitor their degree of radiation exposure using dosimeters.

The second radiation dose classification, "public dose", is the dose
received by a member of the public from exposure to radiation and to
radioactive material released by a licensee, or to another source of
radiation either within a licensee's controlled area or in unrestricted
areas. It does not include occupational dose or doses received from
background radiation, as a patient from medical practices, or from
voluntary participation in medical research programs. As promulgated by
the NRC in 10 CFR Part 20, the maximum permissible level of radiation
dose to individual members of the general public in unrestricted areas
(i.e., Public Dose) is 100 mrem (100,000 µrem) per year above the
typical 360 mrem (360,000 µrem) per year dose provided by natural
background and man-made radiation.

In 10 CFR 20.1003, NRC defines the philosophy of "ALARA":

> "ALARA (acronym for ''as low as is reasonably achievable'') means
> making every reasonable effort to maintain exposures to radiation as
> far below the dose limits in this part as is practical consistent with
> the purpose for which the licensed activity is undertaken, taking into
> account the state of technology, the economics of improvements in
> relation to state of technology, the economics of improvements in
> relation to benefits to the public health and safety, and other
> societal and socioeconomic considerations, and in relation to
> utilization of nuclear energy and licensed materials in the public
> interest."

As part of its ALARA program, **CBP has determined that the radiation
dose received by its personnel** **shall not exceed the allowable dose
for individual members of the general public in unrestricted areas.** As
a result, CBP will establish a physical radiation safety exclusion zone
around each VACIS^®^ installation, as described in Section 6.14.1.3
(Radiation Safety Exclusion Zones), **to equally protect the general
public and CBP personnel from radiation emissions in accordance with the
maximum dose permitted under 10 CFR Part 20.**[^23]

#### Exposure Pathways

The radiation exposure pathway for the general public in unrestricted
areas is created from exposure to scattered radiation from the
radioactive source used in each VACIS^®^ configuration, while the
shutter is open during cargo scanning operations. However, in all cases,
the radiation dose received by the general public **will not exceed 100
mrem (100,000 µrem) per year above typical background/man-made
radiation**, which is the whole body exposure limit for individual
members of the general public.[^24]

Since CBP has chosen the upper permissible level of radiation dose of
its personnel to be the same as that of the general public in
unrestricted areas, Customs and Border Protection Inspectors are not
designated as occupational radiation workers. CBP has chosen the
criterion of 2000 hours per year as the maximum expected exposure time
(i.e., 8 hours a day, five days a week, 50 weeks per year) for its
personnel (which is considered the worst-case exposure regime for any
individual, general public or otherwise). Based on this time of
exposure, and based on the Public Dose criterion of 100 mrem (100,000
µrem) per year, a typical CBP Inspector who is assigned at a VACIS^®^
operational site cannot experience a radiation dose greater than 0.05
mrem (50 µrem) per hour above typical background/man-made
radiation.[^25]

#### Radiation Safety Exclusion Zones[^26]

In order to limit VACIS^®^ radiation dose to no more than 0.05 mrem (50
µrem) per hour above typical background/man-made radiation, CBP has
established **radiation safety exclusion zones** for VACIS^®^II, Mobile
VACIS^®^, Rail VACIS^®^ and Pallet VACIS^®^. Neither the general public
nor CBP personnel will be allowed in the radiation safety exclusion
zones during VACIS^®^ operations. The radiation safety exclusion zones
for the four VACIS^®^ configurations were established from field
measurements conducted by a Certified Health Physicist, and are
described in the following subsections.

##### VACIS^®^ II

The radiation safety exclusion zone for VACIS^®^II is 110 feet in length
and 65 feet in width, as depicted in **Figure 8**. At the edges of this
radiation safety exclusion zone, the radiation dose will not exceed 0.05
mrem (50 µrem) per hour above typical background/man-made radiation.
Additional discussions regarding the VACIS^®^ II radiation source may be
found in *Registry of Radioactive Sealed Sources and Devices; Safety
Evaluation of Device; Model -- VACIS*^®^*II; No. CA0215D104G; Date -- 18
August 2000*, which is included as Appendix A.

##### Mobile VACIS^®^ 

The radiation safety exclusion zone for Mobile VACIS^®^ is 50 feet in
length and 50 feet in width, as depicted in **Figure 9**. At the edges
of this radiation safety exclusion zone, the radiation dose will not
exceed 0.05 mrem (50 µrem) per hour above typical background/man-made
radiation. Additional discussions regarding the Mobile VACIS^®^
radiation source may be found in *Registry of Radioactive Sealed Sources
and Devices; Safety Evaluation of Device; Model -- Mobile VACIS; No.
CA0215D103S; Date -- 24 August 2000*, which is included as Appendix B.

##### Rail VACIS^®^

The radiation safety exclusion zone for Rail VACIS^®^ is 50 feet in
length and 20 feet in width, as depicted in **Figure 10**. At the edges
of this radiation safety exclusion zone, the radiation dose will not
exceed 0.05 mrem (50 µrem) per hour above typical background/man-made
radiation. A "Registry of Radioactive Sealed Sources and Devices"
document that addresses the Rail VACIS^®^ radiation source has not yet
been issued to the public.

##### Pallet VACIS^®^

The radiation safety exclusion zone for the Pallet VACIS^®^ system
extends 3 feet directly behind the radiation source as shown in **Figure
11**. At the edges of this radiation safety exclusion zone, the
radiation dose will not exceed 0.05 mrem (50 µrem) per hour above
typical background/man-made radiation.

#### Effects of Irradiation on Cargo

The total radiation dose experienced by cargo subjected to VACIS^®^ II
scanning is approximately 0.005 mrad (5 µrad) per scan, which is
approximately five orders of magnitude less than the typical 360 mrad
(360,000 µrad) per year dose experienced as a result of natural and
man-made background radiation.

A CBP Memorandum for Record from Dr. Siraj M. Khan, Certified Health
Physicist, dated 22 November 1999, addresses VACIS^®^ compliance with
U.S. Food and Drug Administration regulations regarding irradiation of
food. This memorandum states:

> "Title 21, Part 179, Subpart B, Section 179.21, Paragraph (b) (2) (ii)
> of the Code of Federal Regulations (CFR) requires that a statement
> that no food shall be exposed to radiation sources listed in paragraph
> (a) (1) and (2) of that section so as to receive an absorbed dose in
> excess of 10 grays (1000 rads) be attached to equipment using these
> radiation sources.
>
> The Vehicle and Cargo Inspection System (VACIS^®^) uses a sealed
> cesium-137 radiation source for the inspection of trucks, cargo
> containers, railcars and other vehicles. A radiation safety survey was
> performed in 1996 on a prototype VACIS^®^ using a one curie cesium-137
> source. Subsequent calculations based on those measurements indicate
> that the radiation dose to food at the center of the truck is 5
> microrad which is a billions \[sic\] times less than that allowed by
> this regulation. Details of these calculations are presented in the
> technical report entitled Radiation Safety Guidelines for a Contraband
> Detection System dated November 1996. The radiation dose to food from
> mobile VACIS^®^ and railroad VACIS^®^ will be about 8 and 10 microrad,
> respectively, because they use 1.6 and 2 curie radiation sources.
>
> Based on the above discussion, the VACIS^®^ equipment (fixed truck,
> mobile and railroad) is in full compliance with 21 CFR 179.21."

#### Effects of Irradiation on Persons

As stated in Section 6.14.1.1 (Regulations and Dose Criteria), the NRC
has established the maximum allowable value of radiation dose that may
be received by individuals in unrestricted areas (individual members of
the general public) to be 100 mrem (100,000 µrem) per year above typical
background/man-made radiation.

> []{#__RefHeading___Toc66788491 .anchor}**Figure 8: VACIS**^®^**II
> radiation safety exclusion zone**
>
> []{#__RefHeading___Toc66788492 .anchor}**Figure 9: Mobile VACIS^®^
> radiation safety exclusion zone**
>
> []{#__RefHeading___Toc66788493 .anchor}**Figure 10: Rail VACIS^®^
> radiation safety exclusion zone**
>
> []{#__RefHeading___Toc66788494 .anchor}**Figure 11: Pallet VACIS^®^
> radiation safety exclusion zone**

CBP conducted testing to determine the dose that a person hidden in
cargo would experience during VACIS^®^ scanning operations.[^27]
Currently, this test has not been completed for the Pallet VACIS^®^
system. The data from this testing are presented in Table XIII.

[]{#__RefHeading___Toc66181313 .anchor}**Table XIII: VACIS^®^**
radiation dose measurement data

  ------------------------------ ----------------------------------------
  VACIS^®^ Configuration         Maximum Measured Dose\
                                 (µrem per scan)

  VACIS^®^II                     5

  Mobile VACIS^®^                4

  Rail VACIS^®^                  2.5
  ------------------------------ ----------------------------------------

Assuming the worst case scenario (i.e., VACIS II^®^ at 5 µrem per scan),
to reach the maximum allowable "per year" radiation dose, a person would
have to be scanned 20,000 times per year (which equates to approximately
54 scans per day, every day, for one year). Since the chance of this
frequency of exposure is extremely remote, it is concluded that VACIS^®^
radiation will not have a significant impact on persons located in
scanned cargo.

#### Source Material Operations

##### Transportation

The VACIS^®^ ^137^Cs radiation source has an effective operational life
of 15 years, the ^60^Co source has an effective operational life of 5
years, and the estimated operational lifetime of each VACIS^®^
configuration (exclusive of radiation source) is 30 years.[^28],[^29]
Hence, transportation of the radiation source material separate from the
VACIS^®^ equipment may only be required during installation at each
VACIS^®^ site, during replenishment operations (transporting in the
fresh source, and transporting out the spent source), and when each
VACIS^®^ site is decommissioned. In this scenario, a total of four truck
shipments per ^137^Cs VACIS^®^ installation and twelve shipments per
^60^Co VACIS^®^ installation would be expected on local and interstate
highways over a 30-year time span. Since local roadways going to and
from each planned VACIS^®^ site are typically heavily traveled by cargo
and industrial traffic, four or twelve additional truck shipments over
the 30 year timeframe are not expected to be noticeable in existing
traffic. In all cases, the shipment of the source material will be in
full and total compliance with U.S. Department of Transportation
regulations.

Additionally, the source material will be transported within the Mobile
VACIS^®^ equipment as it moves between sites. Though the movement of
Mobile VACIS^®^ will be conducted at variable intervals, these movements
will not have a significant impact on the heavy traffic typically
experienced at POEs.

In all cases, the marking, packaging, and transportation of the source
material in all VACIS^®^ configurations will be in full and total
compliance with U.S. Department of Transportation regulations 49 CFR
Part 172.310 "Class 7 (radioactive) Materials, Marking"; 49 CFR Part
173.471, "Packaging"; and 10 CFR Part 71, "Packaging and Transportation
of Radioactive Material".

##### Installation 

VACIS^®^II and Rail VACIS^®^ components will be shipped individually,
and assembled at the location where the system is to be used. No
radiation exposure to VACIS^®^ personnel or to members of the public
will result from either the shipment or assembly of the system because
the radiation source will not yet have been installed in the system.
Each ^137^Cs/^60^Co source will each be shipped in a shielded cask to
the VACIS^®^ site, and will be installed in the VACIS^®^ equipment by
the vendor, SAIC. Mobile VACIS^®^ will be shipped to its initial
installation site as a unit with the ^137^Cs source already installed by
the vendor, SAIC.

##### Maintenance

CBP personnel will periodically perform limited maintenance on VACIS^®^,
such as lubricating the tracks on VACIS^®^II and replacing small
components such as light bulbs on all VACIS^®^ configurations. Whenever
this maintenance is performed, the shutter on the ^137^Cs/^60^Co source
shielded container will be kept in the closed position.

Non-routine maintenance will be performed by the vendor, SAIC. Whenever
major disassembly of the VACIS^®^ equipment is required, the
^137^Cs/^60^Co source will be removed from the system and kept in a
shielded storage cask.

##### Disposal

Each VACIS^®^ installation will generate radioactive waste in the form
of either reusable or non reusable ^137^Cs radiation source material.
The disposal of each form of radioactive waste is summarized below:

Radioactive source material not exceeding its useful life, in its sealed
container, will be removed under health physics supervision and stored
in a separate radiological controlled location for future use or
shipment. Packaging and off-site shipment of the radiation source
material will follow U.S. Department of Transportation (DOT)
regulations.

Radioactive source material exceeding its useful life, in its sealed
container, will be packaged according to DOT specifications and shipped
by the radiation source manufacturer to an approved disposal site.

#### Effects of Accidents

Under accident conditions associated with handling, storage, and use of
the ^137^Cs/^60^Co source housing, it is unlikely that any person would
receive an external radiation dose or dose commitment in excess of the
dose to the appropriate organ as specified in Table XIV:[^30]

[]{#__RefHeading___Toc66181314 .anchor}**Table XIV**: Body dose accident
data

  ----------------------------------------------------------- -----------
  Part of Body                                                Dose

  Whole body; head and trunk; active blood-forming organs;    15 rem
  gonads; or lens of eye.                                     

  Hands and forearms; feet and ankles; localized areas of     200 rem
  skin averaged over areas no larger than 1 cm^2^ (0.15       
  in^2^).                                                     

  Other organs.                                               50 rem
  ----------------------------------------------------------- -----------

The worst Design Basis Accident is the open shutter scenario and the
inability to close the shutter on the ^137^Cs source shielded container.
The recommended response for this situation is described in the USCS
document *Recommended Operating Procedures for the Vehicle and Cargo
Inspection System (VACIS*^®^*)* dated 15 February 2000, which is
included as Appendix C herein.

#### Radiation Safety 

VACIS^®^II, Mobile VACIS^®^, Pallet VACIS^®^ and Rail VACIS^®^ all
incorporate redundant safety controls, such as emergency shutoff
pushbutton controls at several locations on the VACIS^®^ equipment.
Additionally, in the event of a power loss, each VACIS^®^ configuration
has a safe shutoff mode in which the shutter on the ^137^Cs/ ^60^Co
source shielded container automatically closes.

The personnel assigned to operate VACIS^®^ will be specifically trained
for safe gamma radiation system operations. Training for the VACIS^®^
operators will consist of lectures and courses in basic radiation
physics, radiation safety, biological effects of radiation,
instrumentation, radiation control, and operating procedures during
normal and emergency conditions.

#### Licensing

CBP currently holds an NRC Materials License for ^137^Cs/ ^60^Co sealed
sources (License number 08-17447-01, Amendment 15) issued on 11 December
2001 and with an expiration date of 31 August 2003. A copy of this
license is included as Appendix D. The NRC requires that CBP be in full
and total compliance with the Materials License and all of the 28
conditions as specified in the license in addition to all statements,
representations, and procedures in the license's application and
correspondence as indicated on Page 8 of the license. Nuclear Regulation
(NUREG)-1556, Volume 4, October 1998, entitled *Program-Specific
Guidance About Fixed Gauge Licenses*, will then automatically become a
condition of CBP's license.

# Decommissioning Planning

The NRC has established technical and financial regulations for
decommissioning licensed nuclear facilities (53 CFR Part 24018, 27 June
1988). These regulations address decommissioning planning, needs,
timing, funding methods, and environmental review requirements for
public and private facilities having licenses under 10 CFR Parts 30, 40,
50, 70, and 72. The intent of the regulations is to ensure the
decommissioning of all licensed facilities will be accomplished in a
safe and timely manner, and that licensees will provide adequate funds
to cover all costs associated with decommissioning.

The regulations specify that a facility licensee either must set aside
money for decommissioning activities or must provide a guarantee,
through a third party, that funds will be available. The funds set aside
or guaranteed are determined by a Decommissioning Funding Plan (DFP),
which the licensee provides. The requirements for financial assurance
are specific to the types and quantities of byproduct material
authorized on a license, and a licensee does not need to take any action
to comply with the financial assurance requirements if the total
inventory of licensed material does not exceed the thresholds specified
in 10 CFR Parts 30.35(b) and 30.35(d). For ^137^Cs, this threshold is
100,000 curies. Because CBP's inventory of ^137^Cs/ ^60^Co does not
exceed the 100,000 curie threshold, the financial assurance requirements
do not apply to the VACIS^®^ program.

The NRC requires licensees to maintain, in an identified location,
records important to facility decommissioning. These records include
architectural drawings of structures and equipment where each radiation
source was used or stored. In addition, if fixed radiation sources have
experienced unusual occurrences (e.g., leaking radiation sources or
other incidents that involve spread of contamination), records need to
be maintained describing contamination that remains after cleanup or
that may have spread to inaccessible areas. CBP will maintain these
records for each VACIS^®^ installation, in accordance with NRC
requirements.

It is difficult to estimate the useful lifetime of a VACIS^®^
installation prior to any decommissioning because

1)  The degree and duration of user demand for gamma imaging technology
    is unknown, and

2)  All that may be needed to extend the operational life of the
    VACIS^®^ equipment is a replacement radiation source sealed
    container.

Additionally, future development of gamma imaging technology may enable
upgrades to be made to an existing VACIS^®^ installation, thereby
extending its useful lifetime.

However, it remains worthwhile to consider decommissioning procedures
that may be necessary for a VACIS^®^ installation approximately 30 years
after first operation. Potential decommissioning procedures are
summarized below:

-   Components such as detector array towers, rails, and Mobile VACIS^®^
    would be removed to a temporary storage area for possible reuse at
    another VACIS^®^ installation.

-   Radiation source material not exceeding its useful life, in its
    sealed container, would be removed under health physics supervision
    and stored in a separate radiological controlled location for future
    use or shipment. Packaging and off-site shipment of the radiation
    source material would follow U.S. Department of Transportation (DOT)
    regulations.

-   Radiation source material exceeding its useful life, in its sealed
    container, would be packaged according to DOT specifications and
    shipped by the radiation source material manufacturer to an approved
    disposal site.

Because no parts of building structures or equipment will be
contaminated from exposure to radiation, they would be available for
reuse. Hardware and equipment would be processed using standard CBP
procedures for disposition of excess government-owned property.

# 8. Persons and Organizations Contacted {#persons-and-organizations-contacted .Chapter-Title}

The following individuals, shown in alphabetical order, were contacted
during the development of the VACIS^®^ PEA:

Brent Bolton

Industrial Hygienist

Department of the Treasury

United States Customs Service

HRM-Safety Branch

6026 Lakeside Boulevard

Indianapolis, Indiana 46268

\(317\) 290-3020 ext 1139

James Britt

Industrial Hygienist, Environmental Compliance

Department of the Treasury

US Customs and Border Protection

HRM-Safety Branch

6026 Lakeside Boulevard

Indianapolis, Indiana 46268

\(317\) 290-3020 ext 1040

Kevin Feeney

Environmental Programs Manager

US Customs and Border Protection

1300 Pennsylvania Ave NW

Washington, DC 20229

\(202\) 927-0461

Dr. Siraj Khan

Certified Health Physicist

Department of the Treasury

United States Customs Service

Applied Technology Division

1300 Pennsylvania Avenue NW, Suite 1575

Washington, DC 20229

\(202\) 344-2025

John King

Department of Commerce

National Oceanic & Atmospheric Administration

Office of Ocean and Coastal Reserve Management

\(301\) 713-3155 ext 195

Ed Mayernik

Acquisition Branch Chief

Department of the Treasury

United States Customs Service

Applied Technology Division

1300 Pennsylvania Avenue NW, Suite 1575

Washington, DC 20229

\(202\) 344-1994

Tom McCulloch

Historic Preservation Specialist

Advisory Council on Historic Preservation

Old Post Office Building

1100 Pennsylvania Avenue NW, Suite 809

Washington, DC 20004

\(202\) 606-8505

William McGovern

Department of Homeland Security

GSA Bldg

7^th^ St SW

Washington, DC 20220

\(202\) 692-4225

Dan Peterson

United States Department of the Interior

U.S. Fish and Wildlife Service

National Wetland Inventory

Arlington Square

4401 North Fairfax Drive, Room 400

Arlington, Virginia 22203

\(703\) 358-2161

Rick Sayers

United States Department of the Interior

U.S. Fish and Wildlife Service

Office of Endangered Species

4401 North Fairfax Drive, Room 420

Arlington, Virginia 22203

\(703\) 358-2171

Carolyn Whorton

VACIS^®^ Program Manager

Department of the Treasury

United States Customs Service

Applied Technology Division

1300 Pennsylvania Avenue NW, Suite 1575

Washington, DC 20229

\(202\) 344-2002

# 9. Acronyms and Abbreviations {#acronyms-and-abbreviations .Chapter-Title}

  ------------------------------------------------------------------------
  Term       Description
  ---------- -------------------------------------------------------------
  \'         Feet

  ^137^Cs    Cesium-137

  A/amp      Amperes

  ACGIH      American Conference of Governmental Industrial Hygienists

  ACHP       Advisory Council on Historic Preservation

  ALARA      As Low As Reasonably Achievable

  APE        Area of Potential Effect

  AQMD       Air Quality Management District

  B          Billion

  BFE        Base Flood Elevation

  BMP        Best Management Practice

  CA         California

  CAA        Clean Air Act

  CAAA       Clean Air Act Amendment

  CBP        Customs and Border Protection

  CE         Categorical Exclusion

  CEQ        Council on Environmental Quality

  CERCLA     Comprehensive Environmental Response, Compensation, And
             Liability Act

  CFR        Code of Federal Regulations

  cm^2^      Square centimeter

  CO         Carbon monoxide

  ^60^Co     Cobalt-60

  CTAC       Counterdrug Technology Assessment Center

  CWA        Clean Water Act

  CZMA       Coastal Zone Management Act

  dBA        Audio decibel

  DE         Dose Equivalent

  ° C        Degrees Celsius

  ° F        Degrees Fahrenheit

  DFP        Decommissioning Funding Plan

  DNL        Day-Night Average Sound Level

  DOT        U.S. Department of Transportation

  EA         Environmental Assessment

  EIS        Environmental Impact Statement

  EO         Executive Order

  EPA        Environmental Protection Agency

  FHBM       Flood Hazard Boundary Map

  FHWA       Federal Highway Administration

  FIRM       Flood Insurance Rate Map

  FL         Florida

  FONSI      Finding Of No Significant Impact

  FR         Federal Register

  FY         Fiscal year

  g/hr       Grams per hour

  g/min      Grams per minute

  GA         Georgia

  GVW        Gross vehicle weight

  HDD        Heavy-duty diesel

  HDDV       Heavy-duty diesel vehicle

  HDGV       Heavy-duty gasoline-fueled vehicle

  HPU        Hydraulic Power Unit

  Hz         Hertz

  in^2^      Square inch

  LA         Louisiana

  lb         Pounds

  LDDT       Light-duty diesel truck

  LDDV       Light-duty diesel vehicle

  LDGT       Light-duty gasoline-fueled truck

  LDGV       Light-duty gasoline-fueled vehicle

  M          Million

  MC         Motorcycle

  MF         Modifying Factor

  mg/m^3^    Milligram per cubic meter

  MI         Michigan

  mph        Miles per hour

  mrad       Millirad (equals 0.001 of a rad)

  µrem       Microrem (equals 0.000001 or a rem)

  mrem       Millirem (equals 0.001 of a rem)

  NAA        Nonattainment area

  NAAQS      National Ambient Air Quality Standards

  NCA        Noise Control Act of 1972

  NEPA       National Environmental Policy Act

  NFIP       National Flood Insurance Program

  NHPA       National Historic Preservation Act of 1966

  NII        Non-Intrusive Inspection

  NIOSH      National Institute of Occupational Safety and Health

  NJ         New Jersey

  NM         New Mexico

  NMFS       National Marine Fisheries Service

  NO         Nitrogen oxide

  NO~2~      Nitrogen dioxide

  NO~x~      Oxides of nitrogen

  NPDES      National Pollution Discharge Elimination System

  NRC        Nuclear Regulatory Commission

  NRHP       National Register of Historic Places

  NSR        New Source Review

  NUREG      Nuclear Regulation

  NY         New York

  O~3~       Ozone

  ONDCP      Office of National Drug Control Policy

  OSHA       Occupational Safety and Health Administration

  Pb         Lead

  PEA        Programmatic Environmental Assessment

  PEL        Permissible exposure limit

  PLC        Programmable Logic Center

  PM~2.5~    Particulate matter less than 2.5 micrometers in diameter

  PM~10~     Particulate matter less than 10 micrometers in diameter

  POEs       Ports of Entry

  ppm        Parts per million

  PR         Puerto Rico

  psi        Pounds per square inch

  QF         Quality Factor

  Rad        Radiation absorbed dose

  RCRA       Resource Conservation and Reclamation Act

  Rem        Roentgen equivalent man

  ROG        Reactive Organic Gas

  RVP        Reid vapor pressure

  RWQCB      Regional Water Quality Control Board

  SAIC       Science Applications International Corporation

  SC         South Carolina

  SCP        System Control Panel

  SED        Supplemental Environmental Document

  SHPO       State Historic Preservation Officer

  SIP        State Implementation Plan

  SLM        Sound level meter

  SO~2~      Sulfur dioxide

  SWRCB      State Water Resources Control Board

  TMEC       Thunder Mountain Evaluation Center

  TWA        Time weighted average

  TX         Texas

  µg/m^3^    Microgram per cubic meter

  µrad       Microrad

  µrem       Microrem

  US         United States

  USACE      U.S. Army Corps of Engineers

  USC        United States Code

  USCS       U.S. Customs Service

  USFWS      U.S. Fish and Wildlife Service

  VA         Virginia

  VAC        Volts alternating current

  VACIS^®^   Vehicle and Cargo Inspection System

  VOC        Volatile organic compounds

  yr         Year
  ------------------------------------------------------------------------

# 10. List of Preparers {#list-of-preparers .Chapter-Title}

The following individuals, shown in alphabetical order, prepared the
VACIS^®^ PEA

**Ronald Bentley** -- Mr. Bentley is a Program Manager and Senior
Scientist with Veridian Corporation (now General Dynamics -- Advanced
Information Systems). He has a Bachelor of Science degree in Chemical
Engineering and a Master of Science degree in Aero spatial Engineering.

**Kevin T. Feeney --** Mr. Feeney is the CBP Environmental programs
manager. HE has a Bachelor of Science degree and a Masters of Public
Administration in Environmental and City Planning. He also has over 25
years in environmental experience dealing with hazardous materials,
waste, and NEPA.

**David Houde** -- Mr. Houde is a Senior Engineer formally with Veridian
Corporation (now General Dynamics -- Advanced Information Systems). He
has a Bachelor of Science degree in Electrical Engineering.

**Scott Matthews** -- Mr. Matthews is an Environmental Analyst formally
with Veridian Corporation (now General Dynamics -- Advanced Information
Systems). He has a Bachelor of Science degree in Public Affairs /
Environmental Science and Management.

**Tania McDonald** -- Ms. McDonald is an Environmental Analyst formally
with Veridian Corporation (now General Dynamics -- Advanced Information
Systems). She has a Bachelor of Science degree in Environmental Science
& Management, and a Master of Science degree in Environmental
Management.

**Thomas "Chico" Nelson** -- Mr. Nelson is an Environmental Analyst with
Organizational Strategies, Inc. He has over 20 years in environmental
experience dealing with hazardous materials, waste, and NEPA.

**Steven Samnick** -- Mr. Samnick is a Program Manager and Senior
Scientist with Veridian Corporation (now General Dynamics -- Advanced
Information Systems). He has a Bachelor of Science degree in
Mathematical Physics.

**Bill Snow** -- Mr. Snow is a Program Manager with Veridian Corporation
(now General Dynamics -- Advanced Information Systems).

**Michael Terpilak** -- Mr. Terpilak is a radiation safety specialist
with Ray-Safe Associates, Silver Spring, Maryland. He is a Certified
Health Physicist.

**Skip Wallace** -- Mr. Wallace is a Senior Research Analyst with
Veridian Corporation (now General Dynamics -- Advanced Information
Systems). He has Bachelor of Science, Occupational Safety and Health
with a minor in Chemistry

**David Walls** -- Mr. Walls is a Program Manager formally with
Organizational Strategies Inc. He has a Master of Science degree in
Environmental Management.

**Richard Whitman** -- Mr. Whitman is a Radiation Safety Officer with
the Bureau of Customs and Border Protection Safety Branch, Indianapolis,
Indiana.

# 11. Distribution List  {#distribution-list .Chapter-Title}

**Richard W. Tobin II,**

**Deputy Director, AZ Dept. of Environmental Quality**

**3033 North Central Avenue Phoenix, AZ 85012**

**Terry Roberts,**

**Chief, CA State Clearinghouse**

**P.O. Box 3044 Sacramento, CA 95814**

**Jasmin Raffington,**

**Coordinator, FL State Clearinghouse, Dept. of Community Affair**

**2555 Shumard Oak Blvd. Suite 320**

**Tallahassee, FL 32399**

**James Setser**

**Chief, Program Coordination Branch, GA Dept. of Natural Resources**

**Jesse Hill Junior Drive, Suite 1152**

**205 Butler Street, SE Atlanta, GA 30334**

**Genevieve Salmonson, Director**

**HI Office of Environmental Quality Control**

**235 South Beretania Street Room 702**

**Honolulu, HI 96813**

**Eric Brenner**

**Senior Advisor for Regulatory Affairs, Office of IL Governor Rod R.
Blagojevich**

**444 North Capitol Street, NW Suite 240**

**Washington, IL 20001**

**J.Dale Givens, Secretary**

**LA Dept. of Environmental Quality**

**P.O. Box 82263**

**Baton Rouge, LA 70884**

**Jay Wichersham Director**

**MA Environmental Policy Act Office, Executive Office of Environmental
Affairs**

**251 Causeway Street Suite 900**

**Boston, MA 02114**

**Linda C. Janey, J.D., Deputy Director**

**Capital Planning and Development Review Division, MD Dept. of
Planning**

**301 West Preston Street Suite 1104**

**Baltimore, MD 21201**

**Brooke Barnes**

**Office of the Commissioner of Environmental Protection, State of
Maine**

**State House Station #17**

**Augusta, ME 04333**

**Richard Pfaff**

**Coordinator, Regional Review, Southeast MI Council of Governments**

**535 Griswold Suite 300**

**Detroit, MI 48226**

**Joe Bagnoli**

**Policy Manager, Healthy Vital Communities Initiative**

**State Capitol Room 130**

**St. Paul, MN 55155**

**Charles Chisolm**

**Executive Director, MS Dept. of Environmental**

**P.O. Box 20305**

**Jackson, MS 39289**

**Todd Everts**

**Director, Legislative Environmental Quality Council**

**State Capitol, Room 171**

**P.O. Box 201704 Helena, MT 59620**

**Chrys Baggett**

**Environmental Policy Act Coordinator, NC State Clearinghouse**

**State Capitol, Room 171**

**P.O. Box 201704 Helena, MT 59620**

**Kenneth C. Koschek**

**Supervising Environmental Specialist**

**Office of Permit Coordination&Environmental Review**

**NJ Dept. of Environmental Protection**

**P.O. Box 418**

**Trenton, NJ 08625-0418**

**Peter Maggiore**

**Secretary, NM Environmental Department**

**1190 St. Francis Drive**

**P.O. Box 26110**

**Santa Fe, NM 87502**

**James R. Boyd**

**Manager, Governmental Services, ND Division of Community Services**

**600 East Boulevard Avenue, Dept 105**

**Bismark, ND 58505**

**Joseph Sieber**

**Dept. of Environmental Protection Policy and Press Office**

**P.O. Box 2063**

**Harrisburg, PA 17105**

**Hermenecildo Ortiz**

**President, PR Planning Board**

**Minillas Government Center**

**P.O. Box 41119**

**San Juan, PR 00940**

**Omeagia Burgess**

**Grant Coordinator, Office of State Budget**

**NBSC Boulevard 1122 Lady Street,**

**12th Floor**

**Columbia, SC 29201**

**Billy Phenix**

**Environmental Policy Director, Governor\'s Policy Office**

**P.O. Box 12428**

**Austin, TX 78711**

**David Rocchio**

**Legal Counsel to the Governor, Office of the Governor**

**Pavillion Office Building 109 State Street**

**Montpelier, VT 05609**

**Ellie L. Irons**

**Environmental Impact Review Manager, VA Dept. of Environmental
Quality**

**P.O. Box 10009**

**Richmond, VA 23240**

**Barbara Ritchie**

**SEPA Unit Supervisor, WA Dept. of Ecology**

**P.O. Box 47703**

**Olympia, WA 98504**

[^1]: From the Port Activities web page on CBP website; accessed March
    4, 2004:
    [http://www2.fpm.wisc.edu/safety/Radiation/2000%20Manual/chapter9.pdf](http://www2.fpm.wisc.edu/safety/Radiation/2000 Manual/chapter9.pdf)

[^2]: U.S. Customs and Border Protection, "[Testimony of Commissioner
    Robert C. Bonner, U.S. Customs and Border Protection Before the
    National Commission on Terrorist Attacks Upon the United States,
    January 26,
    2004](http://www.cbp.gov/xp/cgov/newsroom/commissioner/speeches_statements/jan262004.xml)";
    available from
    <http://www.cbp.gov/xp/cgov/newsroom/commissioner/speeches_statements/jan262004.xml>;
    accessed 9 March 2004.

[^3]: FY02 Cocaine, Marijuana, & Heroin Seizure Stats, from the
    Performance and Annual Report Fiscal Year 2002, p.14; Customs
    Website; accessed March 3, 2004
    <http://www.customs.gov/ImageCache/cgov/content/publications/customs_5fannual_5freport2002_2epdf/v1/customs_5fannual_5freport2002.pdf>

[^4]: Investment Review Board, High Technology Sub-Group -- Imaging and
    Re-locatable Inspection *System*; USCS; 29 January 1999; Page 2.

[^5]: Investment Review Board, High Technology Sub-Group -- Imaging and
    Re-locatable Inspection *System*; USCS; 29 January 1999; Page 8.

[^6]: Registry of Radioactive Sealed Sources and Devices; Safety
    Evaluation of Device; Model -- VACIS^®^II; No. CA0215D104B; 30 July
    2003.

[^7]: Registry of Radioactive Sealed Sources and Devices; Safety
    Evaluation of Device; Model -- Mobile VACIS^®^; No. CA0215D103S; 24
    August 2000.

[^8]: ONDCP International Technology Symposium, 8-10 March 1999.

[^9]: Written comment received from Michael Terpilak, Certified Health
    Physicist, 14 August 2000.

[^10]: National Drug Control Strategy, 2001 Annual Report, Counterdrug
    Research and Development *Blueprint Update*; Office of National Drug
    Control Policy; Appendices B and D.

[^11]: Investment Review Board, High Technology Sub-Group -- Imaging and
    Re-locatable Inspection *System*; USCS; 29 January 1999; Page 2.

[^12]: National Drug Control Strategy, 2000 Annual Report, Counterdrug
    Research and Development *Blueprint Update*; Office of National Drug
    Control Policy; Page 6.

[^13]: Customs Service: Drug Interdiction Efforts; Briefing Report,
    GAO/GGD-96-189BR; 26 September 1996; accessed March 3, 2004
    (<http://www.druglibrary.org/schaffer/GOVPUBS/gao/pdf35.pdf>).

[^14]: <http://www.customs.gov/ImageCache/cgov/content/publications/customs_5fannual_5freport2002_2epdf/v1/customs_5fannual_5freport2002.pdf>;
    accessed March 4, 2004

[^15]: Investment Review Board, High Technology Sub-Group -- Imaging and
    Re-locatable Inspection *System*; USCS; 29 January 1999; Page 7.

[^16]: Ten-Year Counterdrug Technology Plan and Development Roadmap;
    Office of National Drug Control Policy; June 1998.

[^17]: Investment Review Board, High Technology Sub-Group -- Imaging and
    Re-locatable Inspection *System*; USCS; 29 January 1999; Page 7.

[^18]: Ten-Year Counterdrug Technology Plan and Development Roadmap;
    Office of National Drug Control Policy; June 1998.

[^19]: Telephone conversation with Carolyn Whorton, Program Manager,
    USCS, 24 January 2001.

[^20]: *CBDNet* Submission No. 306715; 9 March 1999; Gamma-Ray
    Inspection System, Sources Sought for commercial items.

[^21]: 29 CFR 1910.95, Occupational Noise Exposure

[^22]: Recommended Operating Procedures for the Vehicle and Cargo
    Inspection System (VACIS^®^); USCS; 15 February 2000; Page 4.

[^23]: E-mail received from Dr. Siraj M. Khan, Certified Health
    Physicist, USCS; 23 January 2001.

[^24]: Radiation Safety Guidelines for Gamma-Ray Imaging Systems; Dr.
    Siraj M. Khan, Certified Health Physicist, USCS; Page 9.

[^25]: Written comments received from Michael Terpilak, Certified Health
    Physicist, 14 August 2000.

[^26]: *Radiation Dose to Stowaways in Vehicles*; Dr. Siraj M. Khan,
    Certified Health Physicist, USCS; Dr. Paul Nicholas, USCS; Michael
    S. Terpilak, Certified Health Physicist, Consultant.

[^27]: *Radiation Dose to Stowaways in Vehicles*; Dr. Siraj M. Khan,
    Certified Health Physicist, USCS; Dr. Paul Nicholas, USCS; Michael
    S. Terpilak, Certified Health Physicist, Consultant.

[^28]: Registry of Radioactive Sealed Sources and Devices; Safety
    Evaluation of Device; Model -- Mobile VACIS^®^; No. CA0215D103S; 24
    August 2000.

[^29]: Registry of Radioactive Sealed Sources and Devices; Safety
    Evaluation of Device; Model -- VACIS^®^II; No. CA0215D104B; 30 July
    2003.

[^30]: Registry of Radioactive Sealed Sources and Devices; Safety
    Evaluation of Device; Model -- VACIS^®^II; No. CA0215D104B; 30 July
    2003.