NARCOTICS INTERDICTION:

Customs Management Action Needed To

Ensure Benefits Of Non-Intrusive Inspection

Technology Are Fully Realized

 OIG-01-084 August 10, 2001

Office of Inspector General

*******

The Department of the Treasury
Contents

Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 1

Audit Report....................................................................................................................................... 3

Results in Brief........................................................................................................................ 4

Background ............................................................................................................................. 5

Findings and Recommendations ......................................................................................... 8

Finding 1 Customs Has Not Measured The Effectiveness Of Non-Intrusive

Inspection Equipment And Some Equipment Was Underutilized................. 8

Recommendations..............................................................................................18

Finding 2 Property Controls Over NII Equipment Were Not Effective.........................19

Recommendations..............................................................................................24

Finding 3 Logistical Planning For The Deployment Of Some Large NII Systems

Has Not Always Been Adequate......................................................................26

Recommendations..............................................................................................30

Finding 4 Personal Radiation Detectors Were Not Always Worn

And Related Enforcement Data Was Not Being Collected..........................31

Recommendations..............................................................................................33

Finding 5 Unneeded Equipment Funded By The Consolidated Omnibus Budget

Reconciliation Act Was Not Transferred ........................................................34

Recommendation................................................................................................35

Appendices

Appendix 1: Objectives, Scope, and Methodology....................................................... 37

Appendix 2: Description of Equipment/Systems............................................................38

Appendix 3: Management Comments.............................................................................45

Appendix 4: Major Contributors to this Report...............................................................53

Appendix 5: Report Distribution........................................................................................54

Abbreviations
Contents

Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 2

ATD Applied Technology Division

CDK Contraband Detection Kit

Customs United States Customs Service

CF Customs Form

COBRA Consolidated Omnibus Budget Reconciliation Act of 1985

FY Fiscal Year

GPRA Government Performance and Results Act of 1993

GSA General Services Administration

MTXR Mobile Truck X-Ray

NEEMR National Enforcement Equipment Maintenance and Repair Program

NII Non-Intrusive Inspection

OFO Office of Field Operations

OIG Office of Inspector General

OIT Office of Information Technology

ONDCP Office of National Drug Control Policy

PIMS Property Information Management System

PPS Personal Property Section

PRD Personal Radiation Detector

RV Recreational Vehicle

SEACATS Seized Asset and Case Tracking System

SOP Standard Operating Procedure

U.S. United States

VACIS Vehicle and Cargo Inspection System

XRIS X-Ray Inspection System
OIG Audit

Report

The Department of the Treasury

Office of Inspector General

Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 3

August 10, 2001

Mr. Charles W. Winwood

Acting Commissioner

U.S. Customs Service

In Fiscal Year (FY) 1999, the United States (U.S.) Customs Service

(Customs) received a $134 million appropriation to enhance its counterdrug

operations by acquiring non-intrusive inspection (NII) technology.

NII technology refers to a variety of advanced systems that permit Customs

inspectors to inspect cargo and conveyances for the presence of narcotics

or other contraband without physically opening or entering the shipment.

The funding has enabled Customs to accelerate a 5-year technology

acquisition plan that was developed for the Southern tier of the U.S.

Over the past few years, Customs purchased and deployed large NII

equipment such as Mobile Truck X-Ray Units, Fixed-Site Truck X-Ray

Systems, and Vehicle and Cargo Inspection Systems (VACIS), as well as

smaller equipment such as Mobile X-Ray Vans, Busters, Personal Radiation

Detectors (PRD), and Itemisers. As Customs deployed the equipment,

expectations were high that this equipment would enhance Customs ability

to reduce the supply of illicit drugs entering the country.

We conducted this audit to determine if Customs NII equipment, acquired

for counterdrug and other enforcement activities, has been achieving

expected benefits, effectively used, and properly accounted for and

controlled. We conducted our work from November 1999 to October 2000

at Customs Headquarters in Washington, D.C., and at Customs ports in

Boston, Massachusetts; JFK Airport, New York; Newark, New Jersey;

Miami, Florida; Port Everglades, Florida; Laredo, Texas; Pharr/Hidalgo,

Texas; Brownsville, Texas; Nogales, Arizona; and Detroit, Michigan. A

more detailed description of our objective, scope and methodology is

provided as Appendix 1.
Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 4

Results in Brief

The use of NII equipment was expected to benefit Customs by improving

the ratio of seizures to examinations, allowing less delays for legitimate

conveyances and cargo, and reducing the amount of drugs entering the

country. We were unable to determine if the use of this equipment has

achieved these goals. Customs has not developed performance measures

or otherwise evaluated the effectiveness of this equipment. Although

Customs provided data that showed NII equipment had contributed to

170 narcotics seizures from October 1998 to June 2000, we found errors

with this data that raised questions about its validity, and Customs could not

determine whether or not these seizures would have been made without the

equipment. Moreover, we found that Customs needs to do a better job in

monitoring equipment utilization, and that the limited data available showed

some pieces of equipment were underutilized.

In addition, we believe Customs needs to better account for this equipment.

We found several instances in which the National Enforcement Equipment

Maintenance and Repair equipment database (used for developing

maintenance and repair budgets) did not reconcile with Customs official

property listing, the Property Information Management System (PIMS). We

found neither database to be accurate, due to a lack of internal controls,

particularly in monitoring the movement of equipment from one location to

another. We also found other property accountability weaknesses, including

detachable pieces of equipment that were not separately accounted for in

PIMS, and certain PIMS property codes that were confusing.

Further, we identified several other weaknesses that could negatively affect

Customs ability to meet its NII equipment performance goals. For example,

the deployment of large NII systems was not always adequately planned.

Also, Customs inspectors did not always wear their assigned PRDs, devices

useful in detecting radioactive materials, and unneeded equipment, funded

by the Consolidated Omnibus Reconciliation Act of 1985, was not

transferred to other locations where it could be effectively used, but instead

was left idle.

We made several recommendations to improve the management of NII and

other inspection equipment. The recommendations include: (1) establishing

performance measurements; (2) collecting and analyzing NII utilization data;

(3) taking various actions to improve property inventory controls;
Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 5

(4) monitoring to ensure PRDs are being used; and (5) improving planning,

and working better with the General Services Administration in addressing

construction issues for large NII systems.

Customs concurred with our findings and recommendations and has agreed

to implement corrective actions. Customs response to our draft report is

provided in Appendix 3.

Background

Mission and High-Technology Equipment

One of the missions of Customs is to guard against illegal drugs entering

the U.S. To enhance this effort and improve the quality of inspections,

Customs has begun to increase its reliance on high-technology,

NII equipment. These pieces of equipment permit Customs officials to

inspect cargo and conveyances for the presence of narcotics, or other

contraband, often without having to perform the costly, time-consuming

process of unloading cargo or having to drill or dismantle conveyances.

Customs believes this equipment allows inspection of areas that are difficult

or not possible with conventional inspection, including inside tires and gas

tanks of vehicles.

Customs considers NII technology to include only the newer and larger

pieces of equipment, such as Mobile Truck X-Rays (see Figure 1), rail

systems, VACIS, and Fixed-Site Truck X-Rays. Smaller pieces of

non-intrusive equipment, including Busters, fiberscopes, PRDs, and even

mobile x-ray vans, fall outside of Customs NII definition. Customs refers to

these other pieces as "inspection equipment." However, in this audit, we

included all equipment large and small under the umbrella of "NII

equipment." (Appendix 2 provides a brief description of various pieces of NII

equipment).

Acquisition Plan/Funding

The increased emphasis on NII equipment can be traced to early 1998 with

the development of the U.S. Customs Service Five-Year Technology

Acquisition Plan for the Southern Tier. This plan and subsequent iterations

focus on large pieces of equipment such as truck, rail, sea container,

vehicle and mobile x-ray systems for use at Southern border ports from

California to Puerto Rico.
Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 6

Major NII funding began in FY 1999 when Customs received $134 million1

enabling the bureau to accelerate the 5-year technology acquisition plan.

Contingent on additional congressional funding, the plan includes a 5-year

deployment schedule, with the highest risk ports receiving equipment as

funds and the production of new technology become available. The plan

was updated in July 1999, and again in April 2001. As funding became

available, Customs purchased more and more NII equipment. Currently,

over 50 large NII systems are in operation nationwide (up from 14 at the end

of FY 1999) with an additional 51 large systems funded and scheduled for

delivery by the end of FY 2002. Customs officials estimate that completion

of the acquisition plan will require an additional $70-80 million.

Figure 1: Mobile Truck X-Ray

Source: OIG

Development/Acquisition/Maintenance

Much of the NII technology used by Customs flows from military initiatives.

The Office of National Drug Control Policy (ONDCP) works with the

Department of Defense and Customs in developing and testing

NII technologies. Customs funds a Department of Defense, NII technology

 

1

This amount funded only the large pieces of NII equipment and does not include research

and development, repair and maintenance, and salary costs.
Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 7

testing and evaluation facility at Fort Huachuca, Arizona, a military base that

also provides field installation support.

The decision to procure a given NII system is made jointly by the Customs

Office of Information and Technology (OIT) and the Office of Field

Operations (OFO), based on the outcome of developmental, technical, and

operational evaluations. The Anti-Smuggling Division, OFO, makes a

preliminary determination of the numbers and types of systems

(e.g., systems to examine trucks, pallets, etc.) needed at Customs locations

based on smuggling threats, traffic analyses, and other factors. The Applied

Technology Division (ATD), OIT,2 then performs detailed site surveys to

determine which system may feasibly be placed at a given port. The

outcomes of these surveys are provided to OFO for a final determination.

Once NII equipment is procured, the ATF's National Enforcement

Equipment Maintenance and Repair (NEEMR) program staff, based in

Woodbridge, Virginia, are responsible for equipment maintenance. Repairs

are typically performed by NEEMR technicians, contract field service

technicians around the country, or by appropriate vendors.

In addition to systems already in place, Customs is currently developing

and/or testing several new pieces of equipment. These include a Mobile

Truck X-Ray- Low Undercarriage View; Sea Container X-Ray; and Gamma

Ray Pallet System.

Rail VACIS

Customs data shows that in FY 2000 over 570,000 railroad cars entered the

U.S. along the Mexican border, but only a small number of these cars were

inspected. Threat assessments indicate rail is a high-risk area. To address

this threat, Customs plans to install a Rail VACIS at each of nine Southern

border rail crossings. The cost of the system components is approximately

$2 million each. However, there are substantial costs for site preparation

and construction, potential lease payments to landowners, and other costs

that will vary by location. ATD estimates these costs to be $500,000 per

site, but the final costs will remain unknown until detailed site surveys are

completed and construction contracts are awarded.

 

2

 ATD supports all elements of the Customs enforcement and facilitation processes through

the technical implementation of operational requirements and when applicable, the

development, acquisition, testing, evaluation, and logistics support of new technology.

Within ATD are the following branches: Program Support; Research, Development &

Evaluation; Systems Acquisition; and Technology Support.
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Technology Are Fully Realized (OIG 01-084) Page 8

Findings and Recommendations

Finding 1 Customs Has Not Measured The Effectiveness Of

Non-Intrusive Inspection Equipment And Some Equipment

Was Underutilized

NII equipment was expected to benefit Customs by improving the ratio of

narcotic seizures to examinations, allowing less delays for legitimate

conveyances and cargo, and reducing the amount of illegal drugs entering

the country. In particular, Customs believes the equipment will improve the

quality of inspections and allow inspectors to examine areas that are difficult

or impossible to view using conventional means. We were unable to

determine whether this equipment has achieved the goals Customs

established. Customs has not developed performance measures or

otherwise evaluated the effectiveness of this expensive high technology

equipment. Customs did provide seizure data showing NII equipment

contributed to 170 narcotics seizures between October 1998 and

June 2000. However, this data had errors raising questions about its

validity. In addition, Customs indicated it would have been difficult to

determine whether the seizures only occurred because of equipment use, or

whether the seizures would have occurred anyway.

Nevertheless, (with or without performance measures or cost benefit

analyses) it is reasonable to expect that, in order to maximize effectiveness,

the equipment should be extensively utilized. We found, however, that

Customs has not gathered or analyzed sufficient data to determine

equipment utilization. In the absence of a large Customs equipment

utilization database, we analyzed available utilization data and spoke with

port personnel. We found that many pieces of equipment were not being

fully utilized due to maintenance problems, insufficient staffing, inspectors

choosing not to use the equipment, and overall lack of Customs

management oversight.

To Customs' credit they have taken several positive actions to address the

need for performance measures such as (1) conducting a preliminary

cost-benefit analysis of Fixed-Site Truck X-Rays, and (2) beginning to

collect utilization data for all pieces of large NII equipment. We commend

Customs for these actions but more is needed. At present, the combination

of a lack of performance measures and underutilization of equipment places

Customs at risk of not achieving its narcotic interdiction goals and could
Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 9

place Customs in a tenuous position in justifying future purchases of

equipment.

Also, in the case of measuring performance, we caution Customs that the

existing seizure database may not be accurate and that factors other than

total seizures need to be weighed in any analysis. Further in developing

performance measures or conducting cost-benefit analyses, we believe that

it is important to ensure that maintenance and repair costs are considered.

NII Equipment Expected To Provide Many Benefits

Customs purchased NII equipment to assist in meeting its strategic goal3 of

reducing the amount of illegal drugs entering the U.S. As stated in the

July 1999 edition of the U.S. Customs Service Five-Year Technology

Acquisition Plan For the Southern Tier, Customs expected that the

equipment would provide other benefits such as:

• improvements in the ratio of seizures to examinations;

• increases in numbers of seizures and arrests by Customs and other

agencies;

• less delays for legitimate conveyances and cargo; and

• changes in smuggling modes and methods.

Also, it was expected that the NII equipment would assist Customs

outbound enforcement efforts in interdicting undeclared currency, the

majority of which is derived from proceeds involving narcotics trafficking.

While Customs expected NII equipment to upgrade its inspection

capabilities, it is important to note that, as with any technology, NII

equipment has limitations. For example, at one of the ports we visited

during our audit, we reviewed a VACIS logbook and found that for roughly

55 percent of the x-rays performed, the inspector could not see through the

containers. This, however is not necessarily a negative, because the

 

3

This goal was established to comply with the Government Performance and Results Act of

1993 (GPRA). GPRA requires federal agencies to establish performance goals and

measures and to report annually on the degree to which the goals were met. The Customs

performance measures relative to this strategic goal are (1) pounds of narcotics seized ,

and (2) number of seizures. These goals and measures are for all Customs narcotics

seizures, some of which would occur from using NII equipment.
Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 10

VACIS was intended to detect anomalies in the conveyance itself (e.g., fuel

tank, tires, or frame) and not necessarily the cargo. We point out this

limitation only to demonstrate that NII equipment is not infallible.

Customs Needs To Evaluate NII Equipment

The importance of narcotics interdiction and the high cost of future

NII equipment purchases necessitate Customs being able to measure

NII equipment performance. Customs simply needs to know the degree that

the existing equipment is effective and whether additional purchases make

sense. We found, however, that Customs has not developed performance

measures or otherwise evaluated NII equipment performance against the

strategic goal (reducing illegal drugs) or any of the expected benefits noted

above.

Customs agreed that performance measures are needed for the

NII equipment and told us that they are working to develop data definitions,

reporting processes, and collection tools in order to build a database and to

see what data elements could best be used as performance measures. As

a rough first step in this process, Customs has performed a preliminary

cost-benefit analysis on the Fixed-Site Truck X-Rays, and, for all the large

NII equipment, has begun collecting utilization data (see pages 15-17 below

for utilization data on the Fixed-Site Truck X-Rays). We think this is

commendable. However, to the extent that seizure data is incorporated into

any measurement system, we caution Customs that (1) the existing seizure

database has reliability issues that need to be addressed, and (2) the use of

seizure data as the only performance measure is subject to some risk.

Also, in developing performance measures or conducting cost-benefit

analyses, we believe that it is important to ensure that maintenance and

repair costs are factored.

Data Reliability Issues Need To Be Addressed

Presently, Customs ATD collects NII-related seizure data from three primary

sources:

• commercial cargo seizure reports inputted by port inspectors into the

Customs Seized Asset and Case Tracking System database;

• daily seizure reports issued by OFO via electronic mail and;

• various monthly reports received from the ports.
Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 11

The July 1999 edition of the Five-Year Technology Acquisition Plan for the

Southern Tier states that the use of NII equipment should result in

improvement in the ratio of seizures to examinations:

• increase in numbers of seizures and arrests by Customs and other

agencies;

• less delay for legitimate conveyances and cargo; and

• changes in smuggling modes and methods.

At our request, Customs provided us with seizure statistics from the

ATD database for the period of October 1998 to June 2000. This data

showed that NII equipment contributed to 170 narcotics seizures weighing

152,525 pounds. In order to test the accuracy of this database, we

reviewed Customs press releases to see if they matched the data. Several

did not. Customs later confirmed the accuracy of the press release

information. For example, the ATD database did not include a

September 1999, 1,389-pound marijuana seizure involving the use of a

laser range finder. Also, an 80-pound cocaine seizure from using a full

cargo x-ray unit was correctly reported in a press release, but incorrectly

entered into the database as a marijuana seizure.

In addition, we obtained a seizure listing from the Laredo, Texas, Port of

Entry for the period February 20, 1999 to March 4, 2000, and matched that

list to the ATD statistics. We found only 4 of 13 seizures on the Laredo

listing were in the ATD database. Among the seizures not listed in the ATD

database were three marijuana seizures with a combined weight of over

850 pounds.

In our opinion, these examples raise questions as to the validity of the

database, and point to the need for Customs to institute some method of

quality control to ensure an accurate database.

Limitations Of Seizure Data

As Customs wrestles with the difficult problem of implementing a

methodology to measure the effectiveness of NII equipment, we think it is

important to point out that the use of seizure data as the sole indicator is

subject to some risk. Inherent difficulties exist in measuring the

performance of any piece of equipment. This is especially true for

equipment used to detect narcotics. For example, outcome measures such

as the number of, and volume of, seizures may not necessarily be a good
Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 12

indicator. An increase in seizures could indicate effectiveness, but also may

only reflect the fact that more drugs are entering the country. Further, the

use of NII equipment is part of an integrated effort by Customs to interdict

narcotics and it may be difficult to attribute any given seizure to the use of

the equipment. For example, was the seizure due to the equipment? the

use of a canine? good inspector judgment? sound intelligence information?

or a combination of the above elements? If so, what percentage of any

given seizure could be attributed to the equipment? We believe that these

questions are important and Customs should consider them in developing

performance measures for NII equipment.

Maintenance and Repair Costs.

In implementing performance measures and/or performing cost-benefit

analyses, maintenance and repair costs need to be considered. Several

years ago, the funding for enforcement equipment maintenance and repair

was left to the discretion of the equipment user or an Assistant

Commissioner. In 1994, Customs officials recognized that high technology

equipment, used in the support of inspection, investigation, and interdiction

activities, needed to be better managed, and required regular maintenance

to ensure it was operating properly, and to avoid expensive and time

consuming repairs. As a result, NEEMR was established for the purpose of

having consistent application of quality maintenance and repair service

agency-wide, and to optimize the availability of equipment and take

advantage of economies of scale. In FY 2000, NEEMR maintenance costs

were approximately $11.3 million. The use of maintenance and repair costs

as an evaluation factor would assist Customs in not only assessing

equipment performance but also NEEMR's performance.

The Importance Of Utilizing NII Equipment

In the meantime, as Customs moves towards development of performance

measures, one would expect that NII equipment be fully utilized. In fact,

Customs recognized the importance of utilizing this equipment as evidenced

by a November 1999 agreement4 with the National Treasury Employees

Union. Relative to the assignment of inspectors to large NII equipment, the

agreement states that "...minimum staffing levels must be maintained

during all operational hours of the port and the systems must be continually

 

4

 National NII Technology Assignments, Implementation & Operational Procedures Plan,

 November 1999.
Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 13

in use, pending traffic volume, during all port operational hours." The

agreement further states that "...management and primary teams will

ensure that the system operates continuously during port hours of

operation." As detailed below, we found that Customs lacks data on

equipment utilization, but based on our analysis it appears that many pieces

of equipment are underutilized.

More Equipment Utilization Data Is Needed

Customs has established the following three principal systems to collect

utilization and maintenance data from the ports.

• Fixed-Site Truck X-Ray - A variety of data is recorded on a daily

basis, including the number of vehicles x-rayed, hours the system

was down, and hours the system was available. The data is

forwarded to officials in Customs ATD, where monthly utilization

indice reports are produced for further analysis.

• VACIS - A quarterly, standardized maintenance log is prepared by

VACIS site personnel and faxed on a weekly basis to NEEMR for

analysis of systems failures. Some of the categories on the log are:

time up; non-system downtime; a description involving "incidents";

and corrective action taken. We were advised that NEEMR

personnel review this data to identify consistent and persistent

problems that may be recurring to see if there are specific problems

with the equipment.

• X-Ray System Monthly Report - This report is used for Nll equipment

such as the Mobile X-Ray Vans, pallet x-rays, and the x-ray systems

located at the airports. The report is supposed to be faxed on a

monthly basis to NEEMR. Five major data categories appear on this

report: control unit meter readings; general use of system;

enforcement results; seizure numbers; and comments. The number

of hours that the system is actually x-raying items are included in the

report.

We attempted to analyze data from the above sources to determine if

NII equipment were being optimally utilized. However, we found the

systems to be lacking because Customs has not fully developed these

databases. For example, when we began our audit, an approximate 2-year

backlog of X-Ray System Monthly Repots had not been entered into the

NEEMR database. In the case of the VACIS, Customs could not provide us
Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 14

with any analysis of data received from the field. The best equipment

utilization data available was a Headquarters' analysis of Fixed-Site Truck

X-Ray systems (see below, pages 15-17).

Some Pieces Of NII Equipment Are Not Fully Utilized

In attempting to evaluate NII equipment utilization, we reviewed a Customs

Fixed-Site Truck X-Ray study, and spoke with Headquarters and port

personnel at the locations we visited. We also reviewed local data, where

available. As detailed below, we found that Fixed-Site Truck X-Rays

appeared to be marginally underutilized and Mobile X-Ray Vans were

underutilized to a much greater extent. Although the data is somewhat

limited, we believe these systems were not optimally utilized due to

maintenance problems, insufficient staffing, inspectors choosing not to use

the equipment, and lack of Customs management oversight. These causes

raise numerous potential issues such as contractor performance, adequacy

of maintenance contracts, location of staff and equipment, acceptability of

the equipment by the staff, and even the adequacy of the equipment itself.

However, the volume of documentation and available data is insufficient to

draw any definitive conclusions related to these potential problems.

Fixed-Site Truck X-Ray Data At Seven Ports

Customs analyzed Fixed-Site Truck X-Ray data of seven Southern ports.

For five of the ports, the data was analyzed for the period October 1998 to

May 2000; for one port the period covered was May 1999 to May 2000; and

for the other, the data was analyzed for the period July 1999 to May 2000.

1. Otay Mesa, California,

2. Calexico, California,

3. Nogales, Arizona,

4. Pharr, Texas,

5. Ysleta, Texas,

6. El Paso Texas, and

7. Laredo, Texas

For these ports, Customs captured monthly data on the total number of

hours the cargo operations area was open; the actual number of hours the

truck x-ray operated during the cargo operations time; and the number of
Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 15

truck x-ray examinations performed. Customs expected the Fixed-Site

Truck X-Ray to perform six examinations for every hour that the cargo

facility was operational. Customs, however, believed a rate of 85 percent of

that standard would be acceptable, allowing for maintenance and repairs.

The results of this study, however, showed that the utilization rate fell below

the 85 percent standard. Although several of the ports, on some of the

months, met the 85 percent standard; for the total duration of the study, only

Otay Mesa achieved an 85 percent utilization rate. The combined monthly

averages for all ports ranged from a low of 61 percent (January 1999 and

April 2000) to a high of 79 percent (October 1999). Table 1 depicts the

overall results for each of the seven ports.

Table 1: Fixed-Site Truck X-Ray Utilization

Port Actual

Exams

Number of

Exams if

100%

Utilized

Actual

Utilization

Rate

Otay Mesa 41,247 47,630 86.6%

Nogales 15,517 19,932 77.9%

Laredo 19,922 25,673 77.6%

Calexico 28,280 37,782 74.9%

Ysleta 31,855 42,919 74.2%

El Paso 22,416 33,106 67.7%

Pharr 13,654 49,104 27.8%

Total 172,891 256,146 67.5%

Based on our review of Customs' back-up data and conversations with

some port personnel, it appears that the primary causes for underutilization

were equipment failure, and at times, lack of staffing. In the case of Pharr,

(utilization rate of 27.8 percent) the back-up data clearly shows these
Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 16

causes apply. Information gleaned from the Pharr back-up data shows the

following:

• March 1999-The system closed 7 days due to operational problems;

on 10 other days the equipment was down 1 to 4 hours due to repair

problems.

• June 1999-The system closed 10 days for contractor work or

operational problems.

• July 1999-The system closed 2 days due to lack of personnel, and on

2 other days the system was non-operational ranging from 5 to

8 hours each, due to operational problems.

• November 1999-The system was not in operation for 9 days due to

lack of personnel, and on several other days was non operational

due to repairs.

• January 2000-The system was non-operational 11 days due to

repairs and a lack of personnel.

Mobile X-Ray Vans

As noted above, Mobile X-Ray Van data sent to headquarters from the ports

was greatly backlogged. Therefore, in attempting to gauge utilization, we

reviewed reports at the ports we visited and spoke with port officials about

this matter. We found that, generally, Mobile X-Ray Vans were greatly

underutilized. For example, at the Port of Detroit, utilization records showed

significant downtime for two vans. For the 10-month period of

February 1, 1999, to November 30, 1999, the van assigned to the airport

operated an average of 23 hours per month, while the cargo area x-ray van

averaged 56 hours per month. According to port inspectors, the x-ray truck

was not used more due to equipment malfunctions.

At Miami, during the 13-month period of October 1, 1998, to

October 31, 1999, the Mobile X-Ray Van at the airport was used an average

of only 14 hours per month. As in the case of Detroit, according to Customs

personnel, the lack of usage was primarily due to malfunctioning equipment.

At Nogales, however, underutilization appeared to be due to inspectors

preferring not to use the equipment. To illustrate, during the 6-month period

of May through October 1999, the van was operated (was turned on) an

average of 193 hours per month; however, it was used to perform x-rays an

average of only 2.3 hours per month (4.6 minutes per day).
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Recommendations

1. The Commissioner of Customs should ensure that the effectiveness of

non-intrusive inspection equipment is measured.

Management Comment. Customs concurred and is developing an

automated data collection system to replace the existing manual one.

The system, once completed, will result in Customs having real-time

data on throughput, enforcement results, maintenance and repairs, and

utilization.

OIG Comment. We consider this recommendation to have a satisfactory

management decision. However, final action is pending because

Customs has not completed development of an automated system.

2. The Commissioner of Customs should ensure that quality controls are

established so that seizure data is accurate.

Management Comment. Customs concurred and will periodically

compare the NII database records with the Seized Asset and Case

Tracking System (SEACATS).

OIG Comment. We consider this recommendation to have a satisfactory

management decision with final action completed.

3. The Commissioner of Customs should ensure that Customs better

collects and analyzes non-intrusive inspection utilization data and, based

on this analysis, takes action to ensure that the equipment is optimally

utilized.

Management Comment. Customs concurred. Corrective actions include

the issuance of a memorandum clarifying Customs expectations on the

effective utilization of deployed NII equipment. Customs will also issue a

revised data collection form to improve the manual collection of data

pending completion of the automated system discussed above in

Recommendation 1.

OIG Comment. We consider this recommendation to have a satisfactory

management decision with final action completed when Custom begins

using its new data collection form.
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Finding 2 Property Controls Over NII Equipment Were Not Effective

We found several instances where NEEMR's equipment database, used for

developing maintenance and repair budgets, did not reconcile with PIMS,

Customs official property database. We found that neither database was

accurate. There were instances where equipment was listed in the

NEEMR database but not in PIMS, even though the equipment was

physically located at the port and therefore should have been in PIMS.

Conversely, items located at the ports were correctly listed in PIMS but not

in the NEEMR database. This occurred due to a lack of internal controls,

particularly in monitoring the movement of equipment to the ports. Once we

brought this to Customs attention, Customs took appropriate corrective

action.

We also found two other internal control weaknesses. First, individual

pieces of equipment, such as Laser Range Finders and Busters, are

sometimes included as part of a larger piece of equipment, such as a

Contraband Detection Kit. These smaller pieces, which can be detached

and used independently, were not bar-coded and recorded separately in

PIMS. Second, some of the property codes used were confusing and

inconsistent. Customs has taken corrective action to address the confusing

property codes but has not acted to address the detachable equipment

issue. In order to protect its investment in NII equipment, Customs needs to

bar code the detachable equipment and monitor the use of this equipment

to ensure that its newly established controls are effective.

Customs Property Information Management System And NEEMR

Equipment Database

As is the case with all other Customs property, NII equipment is accounted

for in PIMS. However, NEEMR also maintains its own NII equipment

database, which is used for purposes such as developing a maintenance

and repair budget. Typically, NII equipment is accounted for in one of two

ways based on its value:

1. For equipment valued at less than $5,000, NEEMR inspects and

tests the equipment, and attaches bar codes and sends instructions

with the equipment to the port. NEEMR also sends a

Customs Form (CF) 33, Property Transfer Action. The port is

responsible for creating a property record in PIMS, and is supposed
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to sign the CF 33 and return the form to NEEMR. The signed CF 33

signifies to NEEMR that the equipment was delivered.

2. For equipment exceeding $5,000 in value, Customs Personal

Property Section (PPS), National Logistics Center, in Indianapolis,

creates a temporary PIMS record. These are normally large pieces

of equipment sent directly to the ports. NEEMR will be onsite for the

deployment of these large systems. After delivery, the port creates a

permanent PIMS record.

When we started our audit, NEEMR did not have the capability to add,

delete, or change a PIMS record. NEEMR was able to query only. During

our audit, this changed.

Three Reviews Performed

In an effort to determine the adequacy of controls over NII equipment, at

each port we visited, we performed three separate reviews:

1. We attempted to reconcile NEEMR's NII property listing with the

"official" property list contained in PIMS, including conducting

detailed conversations with the port's Local Property Officer. We

also reviewed various property files at each port.

2. We reviewed CF 52s, Report of Property For Survey, from FY 1998

up until the time of our visit. These forms are completed for personal

property items that are stolen, missing, damaged, or destroyed

through other than normal wear and tear. We also obtained a listing

of all NII equipment "written off" via the Board of Survey process for

all ports.

3. We reviewed CF 259s, Personal Clothing and Equipment Record.

CF 259s are completed whenever personal property is assigned to

Customs employees.

Our NEEMR/PIMS Reconciliation Showed Discrepancies And The Need

For Better Controls.

We found several instances where equipment was listed in the NEEMR

database but not in PIMS, even though the equipment was physically

located at the port. Conversely, we found items located at the ports and on

the PIMS listing but not in NEEMR's database. Also, we found equipment

was lost due, in part, to inadequate controls, including NEEMR not following
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up on missing CF 33s. Further, although we found no related lost

equipment, individual pieces of equipment, which were part of a larger piece

of equipment but could be detached and used separately, were not

recorded separately in PIMS. Finally, we found that property codes used for

various pieces of equipment were confusing. The following are some

examples of property control problems identified during our field visits.

Lost Equipment Cause Unknown

On August 2, 1999, in responding to an OFO technology survey, the port of

Miami could not locate14 PRDs, 1 Buster, and 1 Laser Range Finder. We

estimate the acquisition value of this equipment to be about $25,000.

Equipment Valued At Less Than $5,000 Per Item Lost Or Not Entered Into

PIMS Due To Lack Of NEEMR Monitoring.

Twenty PRDs, listed in NEEMRs database but not in PIMS, were shipped to

the port of Laredo by NEEMR, via FedEx, in March 1999. The port had no

record of receiving them, and NEEMR could not locate for us the signed

CF 33 acknowledging receipt by the port. In this case, about $27,000 in

equipment was lost or stolen because NEEMR did not monitor this

shipment. First, NEEMR didn't review PIMS to see if equipment records

were created by the port, and second NEEMR did not monitor or inquire into

the whereabouts of the missing CF 33.

A similar situation showing the lack of NEEMR monitoring occurred in

March 2000, when a Buster shipped to Brownsville, Texas, was lost. The

equipment was never entered into PIMS, we could not locate the equipment

at the port, and NEEMR could not provide us a copy of the signed CF 33

documenting that the port received the equipment.

We also found a case in which 50 PRDs, valued at about $65,000, were

sent to Newark, New Jersey, and received by the port, but not entered into

PIMS. In this case, the port failed to enter the records and NEEMR never

knew it because NEEMR failed to monitor the CF 33s. After we brought this

to Customs attention, the port entered the records into PIMS.

Equipment Exceeding $5,000 Not Entered Into PIMS

The prior examples were related to equipment purchases of less than

$5,000. We also found problems in accountability of high-dollar pieces of

equipment, the responsibility for which is shared by the PPS in Indianapolis
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and the individual ports. In Newark, a VACIS (roughly $1 million) was not

listed in PIMS, even though the equipment was operating at the port.

Similarly, in Miami a Mobile X-Ray Van was not listed in PIMS, as was an

x-ray system at the JFK mail facility in New York. An apparent reason for

these pieces of equipment not being listed in PIMS were delays by the

PPS staff in Indianapolis in entering the equipment into the system.

Detachable Units Were Not Accounted For In PIMS And Property Codes

Were Confusing

We also found accountability weaknesses related to (1) detachable pieces

of equipment and (2) property codes used for various pieces of equipment.

For example, Fiber Optic Scopes and Laser Range Finders, when

purchased separately, were bar-coded and inventoried in PIMS. However,

radiation detectors that accompanied X-Ray Vans or Pallet X-Ray Units,

were not separately accounted for in PIMS, nor were Fiber Optic Scopes or

Laser Range Finders that were included in Contraband Detection Kits. We

believe that this represents an equipment control weakness and that

detachable radiation detectors, Fiber Optic Scopes, and Laser Range

Finders should be separately accounted for in PIMS.

Also, many property codes in PIMS were confusing. A six-digit

"property code" was used to categorize specific types of equipment. For

example, property code --------- represented "x -ray/density testing

equipment." One type of equipment, such as a Buster, could be found

under different property codes, i.e., --------- and ----------. This also creates

difficulties when conducting a property inventory. For example, in order to

determine how many Busters are physically located at a given port, the local

property officer has to review the entire property printout and may find the

Busters are listed in several places under three or four different property

codes.

Corrective Actions Taken By Customs

When we brought the above deficiencies to Customs attention, officials

acknowledged the weaknesses in NII property controls, and stated that a

lack of communication between all parties contributed to the problem. To

their credit, they also took action to address most of the deficiencies. First,

for NII equipment costing less than $5,000, NEEMR has dedicated one staff

person to process and transfer property. Second, NEEMR has now gained

the ability to enter into PIMS equipment costing less than $5,000. Third,

NEEMR also has implemented a refined process in which a
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Logistics Technician tracks the CF 33s sent out with the equipment and

follows-up with phone calls when an unusually long time transpires before

receiving the form back from the port. In the case of equipment exceeding

$5,000, PPS will better monitor the process. For the confusing property

codes, Customs told us that all Busters, Itemisers, and PRDs incorrectly

coded will be recoded. Customs, however, has not addressed the need to

bar-code and account for radiation detectors, Fiber Optic Scopes, and Laser

Range Finders that are part of larger x-ray units or contained in Contraband

Detection Kits.

Our Board Of Survey Review Showed The Need For Better

Controls Over Busters

According to Customs records, 18 Busters nationwide, costing about

$83,000, have been lost, stolen, or were missing, and therefore "written off"

via the Board of Survey Process. In addition, our work disclosed three

additional Busters that were lost and should have gone through the Board of

Survey process (total cost about $15,000). Although we are uncertain of the

cause of these losses, it appears that controls were lax. For example, in a

memorandum dated July 12, 1999, the Chief of the Technology Support

Branch wrote that a utilization log should be maintained, and that Busters

should always be signed in and out when they are taken from a secure

area. During our field visits, we did not see evidence that log books were

maintained at all ports.

We believe a need exists to tighten controls over Busters. In addition to

being a valuable enforcement tool, Busters are relatively costly (roughly

$5,000 a piece), contain radioactive material, and are about the size of a

brick, and therefore easy to lose.

Our Review Of Personal Clothing And Equipment Records Showed

The Need For Better Controls Over PRDs

We found the need to better control PRDs. CF 259, Personal Clothing and

Equipment Record, is used to document the assignment of Customs

property to a specific individual. A CF 259 is supposed to be completed and

signed by the custodian whenever property is assigned. During our field

visits, we reviewed the ports' CF 259s to determine if PRDs issued to

inspectors were recorded and signed for. We found the following:

• At one port, 92 out of 113 PRDs were not signed for until 2 months

after they had physically been issued to inspectors.
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• At another port, the local property officer's initials were not affixed on

20 CF 259s, as required, when the PRDs were issued to inspectors.

• We saw CF 259 records with dates indicating NII equipment had

been received by inspectors before the equipment was actually

acquired by the port.

Recommendations

1. The Commissioner of Customs should ensure that detachable radiation

detectors, Fiber Optic Scopes, and Laser Range Finders are accounted

for separately in the Property Information Management System.

Management Comment. Customs has implemented this

recommendation.

OIG Comment. We consider this recommendation to have a satisfactory

management decision with final action completed.

2. While NEEMR has taken action to correct certain deficiencies, the

Commissioner of Customs should emphasize to all Customs employees

the need to adhere to prescribed Property Information Management

System property procedures.

Management Comment. Customs concurred and has taken a number of

steps to upgrade property controls. Customs has implemented new

procedures. For example, detachable units are now recorded

separately, PRDs are recorded by ATD and then sent to the field, and

equipment exceeding $5,000 is recorded when the obligating document

is received versus physical receipt. Customs also commented that the

OIG was incorrect in stating that certain equipment was not recorded in

PIMS but operating at the ports.

OIG Comment. We consider this recommendation to have a satisfactory

management decision with final action completed. We acknowledge that

we incorrectly reported some equipment as not being listed in PIMS, and

have made the appropriate corrections in this final report.
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3. The Commissioner of Customs should issue a notice emphasizing the

need and importance of accounting for Busters on a routine basis and

should require the use of Buster logbooks.

Management Comment. Customs concurred and will address this

matter in a new Personal Property Management Handbook that will be

distributed by September 30, 2001.

OIG Comment. We consider this recommendation to have a

satisfactory management decision with a projected final action date of

September 30, 2001.

4. The Commissioner of Customs should issue a notice emphasizing the

need to ensure that CF 259s for Personal Radiation Detectors are

properly maintained.

Management Comment. Customs concurred and will address the use of

CF259s for Personal Radiation Detectors in the new Personal Property

Management Handbook to be issued by September 30, 2001.

OIG Comment. We consider this recommendation to have a

satisfactory management decision with a projected final action date of

September 30, 2001.

5. The Commissioner of Customs should ensure through the use of

self-inspections, or some other form of monitoring, that controls over

non-intrusive inspection equipment are being followed.

Management Comment. Customs concurred and will amend the

Personal-Property Self-Inspection Worksheet to specifically address NII

equipment. In addition, the Fleet and Property Management Branch will

recommend to the Management and Inspection Division that NII

equipment be included in its reviews.

OIG Comment. We consider this recommendation to have a satisfactory

management decision with final action pending revision of the

self-inspection worksheet and reviews conducted by the Management

and Inspection Division.
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Finding 3 Logistical Planning For The Deployment Of Some Large NII

Systems Has Not Always Been Adequate

The immediate and effective utilization of several expensive large

NII systems has been somewhat hampered by insufficient logistical

planning. Specifically, Customs encountered many problems in the

deployment of VACIS and Fixed-Site Truck X-Ray equipment which led to

maintenance difficulties, downtime, and security risks at some ports. Some

of the problems apparently occurred due to the General Services

Administration (GSA)5 not coordinating with Customs, and in other cases it

appears that Customs rushed to get the equipment operational at the

expense of planning. Some of the planning problems we found included:

• at Brownsville, Texas, significant delays were experienced in the

installation of a Fixed-Site Truck X-Ray;

• a truck chassis snagged the above ground cables (cable should have

been underground) disabling the VACIS at Laredo,Texas;

• a Fixed-Site Truck X-Ray, at Pharr, Texas, was so exposed to

unfavorable weather conditions that Customs had to resort to stuffing

artificial Christmas tree branches in fencing to block dirt, sand, and

the wind from hampering equipment operation; and

• at some ports, the VACIS and Fixed-Site Truck X-Ray equipment

were deployed some distance away and out of sight of the "directing"

inspector, posing a risk that vehicles will not report for inspection.

Delays In Getting A Fixed-Site Truck X-Ray Operational At Brownsville,

Texas

At the Port of Brownsville, Texas-Los Tomatoes, a significant delay

occurred with the installation of a Fixed-Site Truck X-Ray system,

apparently due to GSA not coordinating with Customs. The system had

been installed approximately 9 months prior to our visit and was not

operational due to 37 facility discrepancies (GSA was responsible for 34 of

these and the vendor for the other 3) that included a poorly constructed

truck exit ramp. Of interest is the fact that six Fixed-Site Truck X-Ray

 

5 As builder and landlord for the Civilian Federal Government, the GSA is responsible for

certain construction projects at Customs ports.
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systems had already been installed and tested at other ports prior to the

Brownsville production.

To illustrate the problem with the exit ramp, pictured below is (1) a typical

Fixed-Site Truck X-Ray provided to us by Customs, and (2) a photograph,

taken by us at Brownsville, showing the exit ramp where trucks disengage

from the pulley. (See Appendix 2 for a description of the Fixed-Site Truck

X-Ray.)

In the case of the ramp at Brownsville, due to the natural contour of the

earth, it was believed that "Low Boy" trucks (used to carry heavy equipment

with the bed being close to the ground), comprising about 1 percent of the

truck traffic at Brownsville, would scrape the ground when exiting the pulley.

Therefore, it was decided that an exit ramp should be constructed.

However, the inclining ramp with a height of more than two feet resulted in

the truck drivers being on such a steep incline that they couldn't see the

ramp. This of course created a danger that trucks could be driven off the

side of the ramp and possibly overturn.

Figure 2: Typical Fixed-Site Truck X-Ray

Source: Customs
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Figure 3: Fixed-Site Truck X-Ray Exit Ramp

at Brownsville, Texas

Source: OIG

According to Customs, the problem with the Brownsville system as well as

certain other Fixed-Site Truck X-Rays was caused by GSA not coordinating

with Customs. According to Customs, the Fixed-Site Truck X-Ray had

suffered from the beginning by a lack of a well-coordinated effort by GSA.

The site at Calexico, CA, was to be the baseline for future Fixed-Site Truck

X-Rays. However, when the Calexico plans were forwarded to GSA, they

were often not used because GSA is divided into regions and the regional

managers would use different engineering firms. These firms would add or

subtract features, and many times the plans were not forwarded to the

ATD project office or Indianapolis for approval prior to construction.

In addition, Customs stated that the GSA-appointed construction manager

was chosen without any input from Customs, did not fully understand

Customs requirements, and did not have Customs best interests in mind.

The ATD project office would send personnel to construction sites to offer

advice and point out deficiencies, but much of this advice was ignored.

GSA would contract for both the construction manager and the construction

company and effectively excluded the ATD project office from the process.

In summary, according to Customs, the Brownsville project was an example

where the GSA project managers assumed they knew what Customs

needed and built the facility without Customs input.
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Logistical Planning Problems

At several locations Customs encountered maintenance problems,

downtime, and potential security or safety risks because VACIS and

Fixed-Site Truck X-Ray equipment were deployed without sufficient

logistical planning. Although it is difficult to determine the exact cause for

the lack of planning, it appears that Customs rushed to get the equipment in

place. Four cases are detailed below.

VACIS-Laredo

A VACIS was deployed at one of the bridges at Laredo, Texas. However,

because there was no electricity close by, Customs had to power the unit

from the accompanying Recreational Vehicle (RV) that houses the monitors

and controls. This necessitated Customs periodically driving the RV to a

gas station for refueling. Customs personnel provided a front and rear

escort to and from the gas station, thereby tying up resources. To correct

this problem, Customs ran electrical cables to the VACIS from the electrical

source. These cables, however, were above ground and ran across a truck

pathway, resulting in a truck chassis snagging the cables and disabling the

VACIS. At the time of our visit to Laredo, workers were cutting concrete to

bury the cables.

Fixed-Site Truck X-Ray-Pharr

The positioning of the Fixed-Site Truck X-Ray at Pharr, Texas, was

constructed in a location exposed to the elements. In order to protect the

Fixed-Site Truck X-Ray from wind-blown dust and sand, Customs

constructed fencing extending out on both sides for about 25 feet and

stuffed the fencing with artificial Christmas tree branches.

VACIS And Fixed-Site Truck X-Ray Equipment Out Of Line Of Sight Of

Directing Inspector

We also observed at some locations that there were little or no controls to

ensure that a truck, which had been directed by an inspector to drive

through a VACIS or a Fixed-Site Truck X-Ray, did in fact proceed to the

designated x-ray area. Often the "directing" inspector was located a good

distance away, or was not in visual sight, of the x-ray system. Some

Customs port officials acknowledged this is a problem and commented that

part of the reasons were due to space limitations or poor logistical planning
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when the systems were installed. Customs Headquarters officials

commented that they are working to address this issue.

Recommendations

1. The Commissioner of Customs should direct Customs officials in

Headquarters and Indianapolis to meet with the appropriate

GSA officials to further discuss problems associated with the installation

and deployment of large non-intrusive inspection systems, and develop

solutions to prevent them from recurring.

Management Comment. Customs concurred and will schedule a

meeting with GSA to discuss problems associated with installing and

deploying NII equipment.

OIG Comment. We consider this recommendation to have a satisfactory

management decision with final action completed when Custom meets

with GSA.

2. The Commissioner of Customs should ensure that a formal planning

process be adopted for the deployment and installation of the major

non-intrusive inspection systems and that the process be monitored to

ensure compliance.

Management Response. Customs concurred and will put in writing a

formal planning process. Customs stated that it has been effective in

planning the deployment of NII equipment, and that the OIG noted

issues with only 3 of the 60 deployments.

OIG Comment. We consider this recommendation to have a satisfactory

management decision with final action pending the completion of the

planning document. We are unable to comment on the 60 deployments

that Customs stated were successful, because we did not review these

deployments.

3. The Commissioner of Customs should ensure that, at all ports with large

non-intrusive inspection systems, a process is developed to ensure that

all conveyances directed for examination by these systems, do in fact

report for inspection.

Management Comment. Customs will analyze options for providing

greater assurance that conveyances directed for examination do in fact
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report for inspection. The analysis will consider pros and cons of the

options including the limitations posed by the peculiarities of specific port

locations.

OIG Comment. We consider this recommendation to have a satisfactory

management decision with final action pending the completion of

Customs analysis.

Finding 4 Personal Radiation Detectors Were Not Always Worn And

Related Enforcement Data Was Not Being Collected

At various ports, we found that Inspectors did not always wear and use

PRDs, as required by Customs policy. These devices, about the size of a

pager, are intended to alert inspectors of the presence of radioactive

materials that can be used for purposes such as terrorist attacks. We also

found that, at the Port of Miami, 25 PRDs went unused for over a year and,

at Nogales, only 9 of 40 PRDs were assigned because inspectors were

concerned with false alarms. Further, Customs does not collect data on

incidents in which PRDs detect radioactive materials. We believe that the

danger associated with radioactive materials necessitates Customs

ensuring that PRDs are worn and used by individuals performing

inspectional duties. Also, Customs should collect data on PRD detections

to assist in national security and enforcement efforts.

PRDs Are Required To Be Used

Customs has been tasked with deterring the transportation and trade in

illegal nuclear materials, and to guard the borders against threats of

terrorism. One of Customs many strategies in dealing with this area is the

deployment of PRDs to airports and land border ports. PRDs are small

devices that hook on to Customs inspectors' belts. When a certain level of

radiation is detected, the PRDs emit an alarm. To date, over 3,400 PRDs

have been sent to the ports for use by Customs inspectors. When more

funds become available, Customs plans to issue PRDs to all of its

inspectors.

On June 22, 1998, Customs issued a Standard Operating Procedure (SOP),

entitled Radiation Detection Program. This document, addressing the use

of PRDs and larger radiation detection equipment, requires those inspectors

issued PRDs to wear and use them while performing inspector duties. The

SOP also requires ports to issue local policies and to assign a Radiation
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Detection Coordinator to oversee port activities, including distribution and

maintenance of the PRDs.

Ports Are Not Always In Compliance With Radiation Detection Policies

Ports have implemented local Radiation Detection Policies, but inspectors

are not always wearing and using PRDs when performing inspection duties.

During our field visits to ports, we randomly asked a total of 97 inspectors at

10 ports to show us their PRDs and demonstrate to us that they were in

working order. Eight of the 97 did not have their assigned PRDs with them,

and 4 had them but they were not operable. These four inspectors told us

that their PRDs needed batteries but they had not taken the time to replace

them.

We were also informed that some inspectors do not turn the PRDs on

because of periodic false readings or calibration problems, and one

commented that, even though you may have been issued a PRD, "...if you

don't have it, nobody notices." ------------------------------------------- --------

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Also, at the Port of Miami, we found 25 PRDs locked in a file cabinet and

unassigned for over a year. When we brought this matter to local

management, they stated that the PRDS would be immediately assigned to

inspectors.

Need To Track And Evaluate PRD Performance

Customs does not presently collect data on incidents involving PRDs.

According to Customs officials, during the early distribution of PRDs, reports

on radiation incidents were forwarded to Headquarters OFO. Customs told

us that these incidents, plus others known to the ATD, showed the use of

PRDs have resulted in:

• several detections of unmarked hazardous materials (inbound and

outbound),

• detection of illegal imports of nuclear material,
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• safety concerns with radioactive material passing through the port of

entry, and,

• an intentional instance of incorrectly documenting and labeling a

shipment as containing radioactive Cesium to disguise 20 pounds of

cocaine.

We believe significant incidents involving PRDs need to be formally

reported, tracked, and evaluated by Customs Headquarters. Capturing this

information may be valuable for national security concerns, useful to other

federal agencies, and may provide useful enforcement analysis.

Recommendations

1. The Commissioner of Customs should ensure, through the use of

self-inspections, or some other form of monitoring, that the existing

policy requiring Personal Radiation Detectors use be followed.

Management Comment. Customs concurred and the Management

Inspection Division will be asked to include Personal Radiation Detectors

as part of their core review areas when conducting audits at field

locations. In addition, the Customs Self-Inspection Program includes the

use of worksheets for radiation detectors at the locations where the

devices are used.

OIG Comment. We consider this recommendation to have a satisfactory

management decision with final action completed.

2. The Commissioner of Customs should require ports that are not using

Personal Radiation Detectors to justify why they are not using them, and

require the Personal Radiation Detectors be sent to other ports that can

make use of them.

Management Comment. Customs concurred and will update its SOP for

the Radiation Detection Program to mandate that Personal Radiation

Detectors be issued to uniformed officers and that they be used daily. In

addition, a memorandum to that effect will be distributed to all field

offices.

OIG Comment. We consider this recommendation to have a satisfactory

management decision. However, final action remains pending the

updating of the SOP and the issuance of the memorandum.
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3. The Commissioner of Customs should ensure that data is captured for

significant incidents involving Personal Radiation Detectors.

Management Comment. Customs concurred and has updated its

Radiation Detection SOP to require the reporting of significant instances.

OIG Comment. We consider this recommendation to have a satisfactory

management decision with final action completed.

Finding 5 Unneeded Equipment Funded By The Consolidated

Omnibus Budget Reconciliation Act Was Not Transferred

,

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 . The basis for this belief was that COBRA specifies how user

fees are to be used. One usage is for the provision of inspectional

personnel and equipment to enhance Customs services for those persons

paying the fee. The statute also includes a proportionality clause that

directs the enhanced salaries and equipment be "...distributed on a basis

proportionate to the fees collected." Thus, the local Customs personnel

believed that the equipment could only be used in an airport facility where

Customs collected passenger user fees.

Customs Headquarters officials stated that, as a result of this legislative

language, there has always been a great deal of confusion within Customs

as to the process of disposing of COBRA-funded equipment. Customs Chief

Counsel's Office provided the following opinion:

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Customs indicated the above guidelines provide the ports with the

necessary latitude for the disposition of equipment. However, we believe

not all Customs locations that have unused or unneeded COBRA-funded

NII equipment are fully aware of these guidelines. As a result, some

NII equipment acquired through COBRA funds may not be used in an

optimum manner.

Recommendation

1. The Commissioner of Customs should issue a written notice to all

Customs ports directing them to identify non-intrusive inspection

equipment funded by the Consolidated Omnibus Budget Reconciliation

Act of 1985 and follow the procedures outlined in the Chief Counsel's

opinion on transferring or disposing of such equipment that is not being

used by a given location.

Management Comment. Customs concurred. Customs will post a

notice on the Personal Property Bulletin Board, and include this

information in the Customs Property Handbook.

OIG Comment. We consider this recommendation to have a satisfactory

management decision. However, final action remains pending the

updating of the property handbook and the posting on the bulletin board.

* * * * * *

We would like to extend our appreciation to Customs for the cooperation

and courtesies extended to our staff during the review. If you have any

questions, please contact me at (617) 223-8640 or Richard Tyler,

Audit Manager, at (617) 223-8643. Major contributors to the report are

listed in Appendix 4.

/s/

Donald P. Benson

Regional Inspector General for Audit
Appendix 1

Objectives, Scope, and Methodology

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Technology Are Fully Realized (OIG 01-084) Page 35

The objective of this audit was to determine if pieces of high

technology equipment, acquired for counterdrug and other

enforcement activities, are adequately justified, can be accounted for,

and are effectively used. To accomplish this objective, our audit work

included the following:

• Visited the following Customs facilities and conducted interviews

with various Customs officials:

♦ JFK Airport, New York

♦ Boston, Massachusetts

♦ Newark, New Jersey

♦ Miami, Florida

♦ Port Everglades, Florida

♦ Laredo, Texas

♦ Pharr/Hidalgo, Texas

♦ Brownsville, Texas

♦ Nogales, Arizona

♦ Detroit, Michigan.

• Interviewed Customs Headquarters personnel from OFO and OIT.

• Observed NII equipment in use at the ports we visited.

• Reviewed applicable policies, procedures, directives and manuals.

• Reviewed and evaluated equipment utilization logs, property

inventory files, and training records.

• Reviewed enforcement results related to the NII equipment.

The dates of the documents we reviewed ranged from FY 1998 to

FY 2000, inclusive. We performed our field work from November 1999

to October 2000. We conducted our audit work in accordance with

generally accepted government auditing standards.
Appendix 2

Description of Equipment/Systems

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DESCRIPTION OF EQUIPMENT/SYSTEMS

AIRPORT / MAIL X-RAY INSPECTION SYSTEM (101 GT/GTA) - An

easily moveable detection system that can inspect large packages,

baggage, and mail and provides detection of explosives, illegal drugs,

and metal weapons.

Model 101GT

AUTOMATED TARGETING SYSTEM (ATS) - A computer software

system designed to assess shipment entry information for known

smuggling indicators and identify and direct inspectional attention to

high-risk shipments. The system has a number of components

regarding the filtering of shipment data processed against a series of

rules, including query capability, report production, and the ability to

place holds on shipments for document review or for an inspection.
Appendix 2

Description of Equipment/Systems

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BUSTER - The Portable Contraband Detector “Buster” examines

areas not normally accessible to inspectors. It is a hand-held device

that detects unusual densities behind homogenous surfaces, such as

walls or roofs of cargo containers, car doors, or fenders. For example,

ordinary car tires, filled only with air, when measured by the buster,

give density readings within a known range. However, if contraband is

hidden in the tire, the density reading will be higher than normal. The

Buster weighs just 3 pounds and uses a microprocessor and gamma

ray backscatter technology.

Radiation Detection Device, Model K-910B (Buster)
Appendix 2

Description of Equipment/Systems

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Technology Are Fully Realized (OIG 01-084) Page 38

CONTRABAND DETECTION KITS - These kits provide field officers

with proven technology in kit form for convenience and security. Each

contraband detection kit contains: a portable contraband detector (or

Buster), a fiber optic scope, an ultrasonic range finder, a metal pocket

probe, cargo probes, and an extension mirror.

Contraband Detection Kit (CDK)

FIBERSCOPE - Used on vehicles to perform visual examinations in

areas inaccessible to inspectors, such as behind walls, door panels

and in air conditioning vents. Safe to use in solvents and gasoline for

fuel tank inspections. Used on boats for inspections under decks and

other hard to examine areas.

FIXED-SITE TRUCK X-RAY - (See page 27 for a photograph.) A

detection system that can inspect large trucks, automobiles, or cargo

containers. This unit provides detection of explosives, illegal drugs,
Appendix 2

Description of Equipment/Systems

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Technology Are Fully Realized (OIG 01-084) Page 39

and metal weapons. The truck x-ray system is made up of three main

components: (1) x-ray inspection system (XRIS); (2) the facilities

required to house the various XRIS components; and (3) ancillary

equipment required to support or complement the system.

The x-ray subsystem creates "flying spot" x-ray beams that scan a

vehicle as it is being towed by a transport system. Transmission

detectors sense the intensity of the x-ray beam that passes through the

vehicle being scanned. Backscatter and sidescatter detectors sense

scattered radiation from the interaction of the x-ray beam and the

scanned vehicle. Images are formed and transmitted for display at an

operator's console.

The operator's console is equipped with the software necessary to

display images for analysis; store, annotate and print the images; and

create and store database records.

ITEMISER - Is a dual function detection and identification system,

ideally suited for detecting trace quantities of narcotics and explosives.

The Itemiser searches for trace quantities of contraband that may

contaminate the surfaces of baggage, vehicles, cargo pallets, and all

types of containers in which contraband is hidden.

LASER RANGE FINDERS - This equipment detects hidden

compartments in a cargo container by using a laser beam to measure

the length. Eliminates the need for the inspector to physically measure

it, which is not always possible when the container is loaded.
Appendix 2

Description of Equipment/Systems

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Technology Are Fully Realized (OIG 01-084) Page 40

MOBILE X-RAY VAN - General Motors vans that have the ability to

inspect break-bulk cargo, baggage, mail parcels. Differentiating high

density and low density objects in confused and non-confused

backgrounds. Also provides rapid deployment capability by a single

inspector or entire crew of inspectors.

Model 101 Van

MOBILE TRUCK X-RAY (MTXR) - (See page 6 for a photograph). A

non-intrusive x-ray system providing images of vehicles and trucks for

contraband such as drugs, guns, and currency. The MTXR is housed

in a cabinet on a truck chassis and is operated by a three-man crew. It

operates by slowly driving past a parked vehicle with an extended

x-ray boom going over the target vehicle. When the inspection

process is complete, the x-ray unit folds quickly into its storage cradle

for over-the-road transport to the next intended usage site.
Appendix 2

Description of Equipment/Systems

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Technology Are Fully Realized (OIG 01-084) Page 41

PALLET X-RAY INSPECTION SYSTEM - A detection system that can

inspect large objects that will not fit into smaller units and provides

detection of explosives, illegal drugs, and metal weapons. Used by

Customs at many locations for palletized cargo inspection.

Model 101XL

RADIATION PAGER /PERSONAL RADIATION DETECTOR (PRD) -

The radiation pager, weighing only 6 ounces, is a personal gamma-ray

radiation detector for use in the interdiction and location of nuclear

materials. This equipment is approximately the size of message pager

and is intended to be worn on a belt. The pager/PRD can operate for

year or more on a pair of commonly available AA alkaline batteries.
Appendix 2

Description of Equipment/Systems

Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 42

VEHICLE AND CARGO INSPECTION SYSTEM (VACIS) - This

system is capable of effective and efficient non-intrusive inspection of

tankers, cargo vehicles, including trailer trucks, and trailer mounted

sea and air containers. This system may also be used for inspection of

smaller vehicles such as cars, pick-up trucks, and towed vehicles,

e.g. trailers and boats. It can be used to detect contraband located in

the vehicle's structure, tires, gas tanks, and hidden compartments.

The system is modular and is capable of being disassembled,

relocated, and reassembled.

The VACIS is capable of processing a typical vehicle every 4 minutes.

Since there are no vehicle weight or width restrictions, the VACIS is

optionally suited for the inspection of vehicles that cannot meet the

restrictions of the fixed-site truck x-ray.

The vehicle to be examined will remain stationary as a detector tower

and a radiation source enclosure move in tandem along separate

tracks along the side of the vehicle. Each track is 90 feet long. The

detector track is 6 feet wide and the source track is 4 feet wide.

A command center contains the operator's console.

 VACIS
Appendix 3

Management Comments

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Appendix 3

Management Comments

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Appendix 3

Management Comments

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Appendix 3

Management Comments

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Appendix 3

Management Comments

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Appendix 3

Management Comments

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Appendix 3

Management Comments

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Appendix 3

Management Comments

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Appendix 4

Major Contributors to this Report

Customs Management Action Needed To Ensure Benefits of NII

Technology Are Fully Realized (OIG 01-084) Page 51

Northeastern Region

Donald P. Benson, Regional Inspector General for Audit

Richard B. Tyler, Audit Manager

Maureen F. Barry, Auditor-in-Charge

Mark F. Ossinger, Auditor

Preston J. O'Toole, Auditor

Barry A. Russell, Auditor

May Szeto, Auditor
Appendix 5

Report Distribution

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Technology Are Fully Realized (OIG 01-084) Page 52

The Department of the Treasury

Office of Strategic Planning and Evaluations

Office of Accounting and Internal Control

Office of Budget

U. S. Customs Service

Commissioner

Assistant Commissioner, Field Operations

Director, Evaluation Oversight, Office of Planning

Office of Management and Budget

OIG Budget Examiner