a

GAO

United States Government Accountability Office

Report to Congressional Committees

September 2005 RADIOLOGICAL 

SOURCES IN IRAQ

DOD Should Evaluate 

Its Source Recovery 

Effort and Apply 

Lessons Learned to 

Future Recovery 

Missions

GAO-05-672
www.gao.gov/cgi-bin/getrpt?GAO-05-672.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Gene Aloise at 

(202) 512-3841 or aloisee@gao.gov. 

Highlights of GAO-05-672, a report to the 

Senate and House Committees on Armed 

Services 

September 2005

RADIOLOGICAL SOURCES IN IRAQ

DOD Should Evaluate Its Source 

Recovery Effort and Apply Lessons 

Learned to Future Recovery Missions 

DOD was not ready to collect and secure radiological sources when the war 

began in March 2003 and for about 6 months thereafter. Before DOD could 

collect radiological sources, it had to specify criteria for which sources 

should be collected and how to safely collect them, coordinate within DOD, 

coordinate assistance from the Department of Energy (DOE), and resolve 

contract issues. DOD did not issue guidance for collecting and securing 

sources until July 2003 and did not finalize the terms of the contract to 

collect sources until September 2003. Until radiological sources could be 

collected, some sources were looted and scattered, and some troops were 

diverted from their regular combat duties to guard sources in diverse places.

In June 2004, DOD removed about 1,000 of the 1,400 radiological sources 

collected in Iraq and sent them to the United States for disposal. DOD left in 

place approximately 700 additional sources that it had judged were 

adequately secured and being used properly by Iraqis. According to DOD 

and Department of State officials, however, the total number of radiological 

sources in Iraq remains unknown. 

The United States assisted in establishing an Iraqi agency to regulate 

radiological sources. Since June 2004, State and DOE have helped this new 

agency develop an action plan with assistance from the International Atomic 

Energy Agency. However, according to State officials, because of 

uncertainties associated with the continuing formation of the Iraqi 

government, State will have to monitor Iraqi efforts to ensure the continued 

growth and success of an independent, competent, and sustainable 

regulatory authority for the control of radioactive sources and materials. 

Both DOD and DOE are considering improvements based on their Iraq 

experiences. A 2004 study of lessons learned, requested by DOD, 

recommended that DOD develop the capability to quickly eliminate weapons 

of mass destruction in hostile environments, but it did not focus on the 

narrower radiological source mission. In contrast, DOE has contracted for a 

study to examine lessons from its role in removing radiological sources from 

Iraq. 

Bunker Where DOD Secured Radiological Sources, Tuwaitha, Iraq 

Source: DTRA.

Following the invasion of Iraq in 

March 2003, concerns were raised 

about the security of Iraq’s 

radiological sources. Such sources 

are used in medicine, industry, and 

research, but unsecured sources 

could pose risks of radiation 

exposure, and terrorists could use 

them to make “dirty bombs.” This 

report provides information on (1) 

the readiness of the Department of 

Defense (DOD) to collect and 

secure sources, (2) the number of 

sources DOD collected and 

secured, (3) U.S. assistance to help 

regulate sources in Iraq, and (4) the 

lessons DOD and the Department 

of Energy learned. 

GAO recommends, among other 

things, that DOD (1) assess lessons 

learned from securing sources in 

Iraq and (2) ensure that advanced 

planning occurs prior to any future 

missions. DOD concurred or 

partially concurred with most of 

our recommendations and did not 

concur with two of them, stating 

that our report focused on the later 

phase of source recovery and that 

it accepted our recommendations 

for that phase. Our 

recommendations apply to all 

phases of the effort and we revised 

some to clarify this. The 

Department of State provided 

clarifications regarding U.S. 

assistance to Iraq and reasons for a 

delay in approval of export 

licensing. DOE had no written 

comments but stated it would work 

with DOD to help define sources of 

greatest risk. 
Page i GAO-05-672 Securing Iraqi Radiological Sources

Contents

Letter 1

Results in Brief 3

Background 6

DOD Was Not Ready to Collect and Secure Radiological Sources in 

Iraq at the Start of the Hostilities in March 2003 8

DTRA Recovered or Left Secure in Place about 2,100 Radiological 

Sources, but the Number of Unsecured Sources Remaining in Iraq 

Is Unknown 14

The United States Helped Create an Iraqi Agency to Regulate 

Sources, but Future Assistance Is Uncertain 24

DOD Has Not Assessed Its Source Recovery Effort, but DOE Is 

Considering Lessons Learned 29

Conclusions 31

Recommendations for Executive Action 32

Agency Comments and Our Evaluation 33

Appendixes

Appendix I: Scope and Methodology 37

Appendix II: The National Defense University Study 41

Appendix III: Comments from the Department of Defense 44

Appendix IV: Comments from the Department of State 48

Appendix V: GAO Contact and Staff Acknowledgments 51

Figures Figure 1: An Intact Pillar and a Looted Metal Pillar That Contained 

Cobalt Sources 8

Figure 2: Sites from Which Unsecured Sources Were Collected 16

Figure 3: Bunker Where DTRA Secured Radiological Sources, 

Tuwaitha, Iraq 17

Figure 4: Number of DTRA Contractor Missions and Number of 

Insurgent Attacks throughout Iraq, June 2003 to May 

2004 19

Figure 5: Protected Living Area for DOE Experts at the Tuwaitha 

Nuclear Research Center 22
Contents

Page ii GAO-05-672 Securing Iraqi Radiological Sources

Abbreviations

DOD Department of Defense

DOE Department of Energy

DTRA Defense Threat Reduction Agency

IAEA International Atomic Energy Agency

IRSRA Iraqi Radiological Source Regulatory Authority 

MOST Ministry of Science and Technology (Iraq)

NDU National Defense University

WMD weapons of mass destruction

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Page 1 GAO-05-672 Securing Iraqi Radiological Sources

United States Government Accountability Office

Washington, D.C. 20548

A

September 7, 2005 Letr

The Honorable John Warner

Chairman

The Honorable Carl Levin

Ranking Minority Member

Committee on Armed Services

United States Senate 

The Honorable Duncan Hunter

Chairman

The Honorable Ike Skelton

Ranking Minority Member

Committee on Armed Services 

House of Representatives

In March 2003, citing the failure of Iraq to live up to agreements to disarm 

itself of weapons of mass destruction (WMD), and other concerns, the 

United States and its coalition allies invaded Iraq. This conflict is known as 

Operation Iraqi Freedom. During late 2002 and early 2003, the U.S. 

Department of Defense (DOD) had made plans to find and eliminate the 

suspected WMD. DOD’s Defense Threat Reduction Agency (DTRA) was to 

be responsible for hiring a contractor to dispose of WMD and their 

component materials, such as biological agents, chemicals, and radioactive 

materials.1

 The radioactive materials included (1) nuclear materials, such 

as processed uranium, which could be used in a nuclear weapon, and (2) 

radiological sources, which are widely used throughout the world in 

medicine, agriculture, research, and industry and could be combined with 

conventional explosives to create a radiological dispersion device, a 

weapon known as a “dirty bomb.” Thus, DOD’s plan to eliminate WMD 

included the removal of radiological sources, which are not weapons but 

could be improvised by terrorists into dirty bombs.

The Department of Energy (DOE) and Department of State also had 

responsibilities in the mission to secure radiological sources in Iraq. By 

early 2003, DOD was planning for DOE to be involved in both removing and 

1

For information on DTRA’s broader mission to address the threat of WMD, see GAO,

Weapons of Mass Destruction: Defense Threat Reduction Agency Addresses Broad Range 

of Threats, but Performance Reporting Can Be Improved, GAO-04-330 (Washington, D.C.: 

Feb. 13, 2004).
Page 2 GAO-05-672 Securing Iraqi Radiological Sources

disposing of sources from Iraq. After the transfer of power from the 

Coalition Provisional Authority2

 to the interim Iraqi government in June 

2004, State had lead responsibility for helping Iraq regulate the radiological 

sources remaining in the country.

Although the United States did not find stockpiles of WMD in Iraq, U.S. 

forces found partially processed uranium and radiological sources that the 

International Atomic Energy Agency (IAEA) had previously secured at 

nuclear facilities. In addition, U.S. forces found radiological sources 

throughout Iraq, many of which were unsecured and in danger of being 

looted. Citing media reports of looting at nuclear sites, IAEA and Members 

of the Congress raised concerns about the security of nuclear materials and 

radiological sources. Reflecting these concerns, during a July 2003 Senate 

Armed Services hearing, the Ranking Minority Member of the Readiness 

and Management Support Subcommittee asked the Secretary of Defense 

about the security of radiological sources in Iraq. DOD replied in a January 

2004 letter that numerous sources had been collected and that efforts were 

under way to identify and secure others. 

Shortly thereafter, the Ranking Minority Member’s office asked us for an 

update on the security of radiological sources in Iraq, and we initiated a 

review of the effort to collect and secure these sources. Because of the 

broad interest in this issue, we conducted this work under the authority of 

the Comptroller General and are issuing this report to the Senate and 

House Committees on Armed Services. This report (1) assesses DOD 

readiness to collect and secure radiological sources in Iraq from the start of 

the 2003 war; (2) presents information on the number of radiological 

sources DTRA had secured by the time of the June 2004 transition to the 

interim Iraqi government; (3) describes the assistance the United States has 

provided, and plans to provide in the future, to the Iraqi government to help 

regulate radiological sources in Iraq; and (4) examines DOD and DOE 

actions to assess their experiences in Iraq and apply any lessons learned to 

possible future radiological source collection missions.

To assess DOD’s readiness to collect and secure radiological sources, we 

reviewed available policy guidance and reports on individual missions to 

collect sources and interviewed DOD and contractor officials. To present 

information on the number of radiological sources secured, we reviewed 

2

The Coalition Provisional Authority, led by the United States and the United Kingdom, was 

responsible for temporarily governing Iraq. 
Page 3 GAO-05-672 Securing Iraqi Radiological Sources

DOD inventories of sources left in Iraq and sources collected, interviewed 

officials about the reliability of these inventories, and reviewed available 

mission guidance and other documents. We assessed the reliability of 

DTRA’s inventories of radiological sources, including independently 

corroborating the information when possible, based on discussions with 

those responsible for the inventories. With one exception, we determined 

that the data were sufficiently reliable for the purposes of this report. To 

describe U.S. efforts to help the interim Iraqi government regulate sources, 

we examined the Department of State’s planning documents and a 

Coalition Provisional Authority order to establish an Iraqi agency to 

regulate radiological sources. We also discussed plans for assistance with 

State and DOE officials as well as with Iraqi officials visiting the United 

States. Finally, to describe what DOD and DOE have done to learn from 

their experience in Iraq, and how such lessons might be applied in the 

future, we interviewed DOD and DOE officials about their efforts to 

identify and document lessons learned and examined draft and published 

documents on the mission to dispose of Iraqi WMD. Because of the 

continuing hostilities, we did not travel to Iraq. We performed our work 

from May 2004 through August 2005 in accordance with generally accepted 

government auditing standards. Details of our methodology are provided in 

appendix I.

Results in Brief DOD was not ready to collect and secure radiological sources when the 

war began in March 2003 and for about 6 months thereafter. Although 

DOD’s prewar plan included removing radiological sources from Iraq, DOD 

did not issue guidance for collecting and securing them until July 2003 and 

did not finalize the terms of the contract that would allow the radiological 

sources to be collected and secured until September 2003, 6 months after 

the beginning of the war. During this 6-month period, individual military 

commanders, who possessed limited equipment to handle the radiological 

sources they were finding, had to make decisions regarding which 

radiological sources should be secured and how to safely collect them. 

Illustrating the readiness problems, one commander, lacking the proper 

equipment, had to move highly radioactive sources with an ice cooler that 

was lined with lead bricks. In other instances, troops were diverted from 

their regular combat duties to guard unsecured radiological sources at 

various places around the country until the sources could be properly 

packaged and removed. According to one officer, field commanders were 

concerned that their troops guarding sources in some places were placed at 

greater risk for enemy attack. In addition, the scattering of radiological 

sources by looters complicated their collection. DTRA was responsible for 
Page 4 GAO-05-672 Securing Iraqi Radiological Sources

collecting radiological sources in Iraq. However, DTRA officials explained 

that collecting these sources only gradually became a mission focus as it 

became clear that the broader hunt for WMD was unsuccessful. 

Furthermore, before DTRA could collect radiological sources, it had to 

specify criteria regarding which sources should be collected and how to 

safely collect them, coordinate within DOD for armed protection for 

DTRA’s contractor as they sought radiological sources, coordinate 

assistance from DOE, and resolve legal liability issues regarding potential 

damages resulting from its contractor’s work to collect the radioactive 

sources. 

By the end of June 2004, DTRA had removed about 1,000 of 1,400 collected 

radiological sources from Iraq and sent them to the United States. DTRA 

left in place approximately 700 additional sources that it had judged were 

adequately secured and being used properly by Iraqis—for example, for 

industrial and medical purposes. According to DOD and State officials, 

however, the total number of unsecured radiological sources in Iraq 

remains unknown. For instance, even after DTRA completed collecting and 

securing sources, according to Department of State officials, a neighboring 

country twice detected trucks leaving Iraq with unsecured radiological 

sources. Despite the difficulties encountered in collecting and securing 

radiological sources in Iraq during ongoing hostilities, according to DOD 

officials, DTRA and its contractor successfully carried out about 140 

collection missions without fatalities or severe exposure to radiation. 

However, for the removal of sources from Iraq, DOE had difficulty 

obtaining accurate information from DOD regarding the type and 

radioactivity of the sources. DOE needed this information to determine the 

type and number of transportation containers needed to remove the 

sources. According to DOE officials, the final disposition of the radiological 

materials removed from Iraq may take longer and cost more than estimated 

because a legal determination is needed regarding whether the United 

States government owns the material or is merely serving as its custodian. 

According to these officials, they raised this issue of ownership when the 

removal mission was being planned, but it was never resolved.

The United States assisted in establishing an Iraqi agency to regulate 

radiological sources. The Department of State worked with the Coalition 

Provisional Authority and later with the interim government to create an 

Iraqi agency to regulate radiological sources, the Iraqi Radiological Source 

Regulatory Agency. In addition, State developed budget and organizational 

plans for the regulatory agency and shared them with Iraqi officials 

appointed by the Coalition Provisional Authority. Since the political 
Page 5 GAO-05-672 Securing Iraqi Radiological Sources

transition to the interim Iraqi government in June 2004, State has helped to 

firmly establish the agency by facilitating the transfer of DTRA equipment 

to the new government and, with funding support from DOE, coordinating 

meetings between Iraqi officials and the IAEA to create an action plan. 

Further, State, DOE, and IAEA have agreed to offer additional technical 

and financial support in such areas as regulation writing, border control, 

and security upgrades. However, according to State officials, because of 

uncertainties associated with the continuing formation of the Iraqi 

government, State will have to monitor Iraqi efforts to ensure the continued 

growth and success of an independent, competent, and sustainable 

regulatory authority for the control of radioactive sources and materials.

Both DOD and DOE are considering improvements based on their Iraq 

experiences. However, DOD’s assessment focuses on its intended WMD 

mission rather than on the radiological source mission. DOD requested a 

study from its National Defense University to assess lessons learned from 

the WMD mission in Iraq and to recommend improvements for possible 

future missions. The resulting report did not offer any observations or 

recommendations regarding the mission to collect and secure radiological 

sources in Iraq. However, it stated that DOD had not sufficiently planned 

and prepared for the WMD mission; had shortfalls in the needed 

transportation, military security, and logistics resources; and had 

operational difficulties because of the extensive looting, public disorder, 

and hostile security environment. The report recommended that DOD 

develop the capability to quickly eliminate WMD in hostile environments 

and develop a permanent organization to eliminate WMD. Consistent with 

this recommendation, DOD assigned its Strategic Command responsibility 

for planning and ensuring the capacity for possible future missions to 

eliminate WMD, which a DOD Joint Staff officer told us would include the 

elimination of radiological sealed sources. In contrast to DOD’s focus on 

the WMD mission, DOE has contracted for a study to examine lessons from 

its radiological source removal mission. DOE considered establishing a 

reserve of equipment to handle and package radiological material to ensure 

rapid action in the future but decided that it could not proceed because of 

current budget constraints.

To ensure that problems experienced with collecting and securing 

radiological sources in Iraq are avoided to the extent possible in future 

missions, we are recommending that the Secretary of Defense, among 

other things, ensure that planning for such missions is completed prior to 

their initiation. Such planning should include developing specific guidance 

for collecting and securing radiological sources and coordinating any 
Page 6 GAO-05-672 Securing Iraqi Radiological Sources

needed assistance with DOE. Furthermore, we are recommending that the 

Secretary of Defense comprehensively review DOD’s experience with 

collecting and securing radiological sources in Iraq for lessons learned to 

apply to possible future missions. 

We provided the Departments of Defense, State, and Energy with draft 

copies of this report for their review and comment. DOD concurred or 

partially concurred with most of our recommendations and did not concur 

with two of them, stating that our report focused on the later phase of 

source recovery and that it accepted our recommendations for that phase. 

Our recommendations apply to all phases of the effort and we revised some 

recommendations to clarify this. We also incorporated into the report 

State’s clarifications of (1) its current outlook for U.S. assistance to Iraq on 

radioactive source regulation and (2) the reason for the delay in State’s 

approval of export licensing. DOE had no written comments on the report 

but did state that it will work with DOD to determine criteria to define 

which radiological sources are of greatest risk. 

Background Widespread looting—including looting of radiological sources—became a 

major problem in Iraq after the March 2003 coalition forces invasion, 

complicating U.S. efforts to secure and collect radiological sources. Media 

reports of the looting at Iraq’s Tuwaitha Nuclear Research Center, for 

example, brought public attention to the scattering of radioactive materials 

throughout populated areas, posing health and safety risks to Iraqis. In May 

2003, the IAEA, which had inventoried nuclear and radiological materials at 

Tuwaitha, raised concerns about Iraqi citizens’ exposure to radiation and 

publicly asked the United States to secure these materials. 

Given the extensive looting, DOD could not assume that facilities and items 

within them, including radiological sources, would remain intact or in place 

for later collection without being secured. Many facilities that were no 

longer under the control of Iraqis, such as abandoned government research 

facilities and industrial complexes, were looted. For example, a 2004 

government report on the search for WMD stated that looters often 

destroyed sites after a coalition military unit moved through an area, since 

the coalition did not have the forces available to secure the various sites 

thought to be associated with WMD. According to one DTRA official, the 

looting was more extensive than he had ever seen before. The looting was 

reported to have included removing wiring and pipes from walls and from 

the ground; stealing desks, windows, sinks, and floors; and even 

dismantling and removing whole buildings. While some looting may have 
Page 7 GAO-05-672 Securing Iraqi Radiological Sources

been done to thwart the U.S. mission, according to DTRA officials, most of 

it seemed to be related to selling or reusing common materials such as 

scrap metal rather than seeking radiological or nuclear materials. At the 

Tuwaitha facility, for example, looters dumped partially processed uranium 

ore from large containers onto the floor and took the containers. 

DOD found that fully securing sources from looters was challenging 

because of their persistence. According to a DTRA official’s personal 

assessment, no amount of forces could have controlled the rampant 

looting. At the Tuwaitha Nuclear Research Center, DOD concentrated 

security in those areas where radiological and nuclear materials were 

stored, but looters continued to penetrate the less secure areas of 

Tuwaitha, a large complex of over 90 buildings.

The scattering of radiological sources by looters complicated the later 

collection of those sources. In one dramatic instance, looters stole large 

cobalt sources from an Iraqi radiological test site in early September 2003, 

when U.S. troops were guarding the site. The large, open site, which was 

apparently designed for carrying out radiation exposure experiments in the 

surrounding areas, contained eight metal pillars, each with a pulley system 

to raise a cobalt source from a concrete storage pit to the pillar’s top. 

Looters tore down and removed three of these pillars and also took the 

cobalt sources from two of them. (See fig. 1.) After several days of 

extensive searches in the area, DTRA recovered both stolen sources. 

According to a DTRA official, the metal pillars were probably the looters’ 

intended target, and the sources may have been taken unintentionally when 

they became caught in the pulley mechanisms.
Page 8 GAO-05-672 Securing Iraqi Radiological Sources

Figure 1: An Intact Pillar and a Looted Metal Pillar That Contained Cobalt Sources

DOD Was Not Ready to 

Collect and Secure 

Radiological Sources in 

Iraq at the Start of the 

Hostilities in March 

2003

For about the first 6 months after the war began in March 2003, military 

commanders had insufficient guidance and equipment appropriate for 

collecting and securing radiological sources that they discovered. As a 

result, they were forced to make ad hoc decisions about recovering and 

securing these sources. During this time, DTRA—the agency DOD had 

assigned to the WMD elimination mission 12 days before the war 

began—was working to fill gaps in preparations for the mission to collect 

and secure radiological sources. It was not until September 2003 that DTRA 

finalized the terms of the contract for collecting the radiological sources 

and collections began throughout Iraq. 

Source: DTRA.
Page 9 GAO-05-672 Securing Iraqi Radiological Sources

Insufficient Guidance and 

Equipment Left Military 

Commanders to Make Ad 

Hoc Decisions about 

Collecting Radiological 

Sources from March to 

September 2003

Military commanders in Iraq initially had no policy guidance on which 

radiological sources to collect, and what to do with them once they were 

collected. DOD did have some specialized teams with radiological 

expertise, such as the 11-person Nuclear Disablement Team, which had 

been set up to disable WMD and associated production facilities in Iraq. 

This team had the expertise to move radiological sources, including 

packaging radioactive material and designing safety procedures to 

minimize radiation exposure. However, military commanders lacked 

sufficient equipment appropriate for safely collecting and moving 

radiological sources.

Without adequate official guidance and equipment to handle the 

radiological sources they encountered in Iraq, military commanders were 

left to make ad hoc decisions about recovering and securing the sources. 

They acted because they were concerned about the inherent health and 

safety risks of radiological sources to coalition soldiers and the Iraqi 

populace, as well as the potential for enemy or terrorist forces to use the 

sources to construct dirty bombs. For example, lacking the proper 

radiation shielding equipment, the Nuclear Disablement Team moved a 

radiological source to Tuwaitha with improvised shielding because an 

officer judged that the unshielded source posed the risk of radiation 

exposure to Iraqis working in the vicinity. The team created what was 

described as “field expedient” packaging by lining an ice chest with lead 

bricks that were brought from the Tuwaitha Nuclear Research Center. 

However, the container did not sufficiently shield the driver of the military 

vehicle carrying the source from radiation exposure. Therefore, the team 

further improvised shielding by placing metal sheets salvaged at the site 

between the driver and the container in the back of the vehicle. This 

additional shielding reduced the radiation at the driver’s seat to a level that 

just met the team’s safety standard for exposure. However, the radiation in 

the back of the vehicle still exceeded that standard. Consequently, a second 

military vehicle followed the loaded vehicle at a safe distance to prevent 

occupants of any other vehicles from following so closely that they would 

be exposed to unsafe levels of radiation. On the basis of his assessment of 

the team’s experience with moving the source described above, the 

commander of the Nuclear Disablement Team decided it was too risky to 

allow his troops to move any more sources without proper handling 

equipment and containers.

Because some military officers were reluctant to move radiological sources 

to a single consolidation site without adequate handling and packaging 

equipment or official guidance, coalition forces had their troops guarding 
Page 10 GAO-05-672 Securing Iraqi Radiological Sources

sources around Iraq. In some cases this posed health risks—for example, 

some sources were secured in bases where U.S. troops were already 

stationed, creating the need to protect the troops from accidental exposure 

to radiation. When sources were secured outside controlled areas, 

however, security risks resulted. For example, according to a DTRA 

official, field commanders complained to him after he arrived in July 2003 

that protecting radiological sources in some field locations exposed their 

troops to increased risks of attacks. Estimates of how many soldiers were 

removed from their military duties to guard sources were not available, but 

we were told of instances in which troops were left guarding sources for 

several months. According to a DOE expert involved in DTRA’s later 

collections, for example, a small group of troops had guarded sources at an 

oil drilling operation from May until early September 2003.

While Military Commanders 

Improvised, DTRA Worked 

to Complete Preparations 

for Collecting Radiological 

Sources

Between March and September 2003, as individual military commanders 

acted independently to collect or secure radiological sources when they 

discovered them, DTRA was working to fill gaps in preparations for the 

mission to collect and secure radiological sources. According to DTRA 

officials, they only gradually became concentrated on radiological sources 

as their initial focus on eliminating WMD diminished because stockpiles of 

chemical, biological, and nuclear weapons were not found. First, DTRA 

tried to establish much-needed guidance on which radiological sources to 

collect and where to consolidate them. According to a DTRA official, these 

and other issues had been discussed in prewar planning in late 2002, but 

guidance had not been issued. In July 2003, the DOD Office of Policy issued 

guidance on collecting and securing radiological sources for field 

commanders, which a DTRA official told us was all the policy guidance that 

DTRA needed. However, DTRA still needed to specify standards for health 

and safety as well as for transportation for its collection missions. 

According to the DTRA commander who set up collection operations in 

Iraq, DTRA used U.S. standards to ensure safety, but these standards were 

modified for the Iraq situation. For example, instead of using radioactive 

cargo placards on vehicles, which would be required by U.S. standards but 

might attract an insurgent attack, DTRA notified local military 

commanders along the route of its cargo when moving sources.

In addition, DTRA engaged in extensive, and ultimately unsuccessful, 

coordination within DOD to provide protection for its contractor at the 

Tuwaitha storage site through a contracted security force, but eventually 

obtained protection for its collection mission through coalition forces 

headquarters. This security force stood by for deployment to Iraq while the 
Page 11 GAO-05-672 Securing Iraqi Radiological Sources

Department of Defense General Counsel, DOD’s Central Command, and 

coalition military headquarters considered DTRA’s request to arm this 

force. When this request was denied, DTRA decided in late 2003 that 

sufficient protection could be provided by military forces. For each 

collection mission, DTRA coordinated protection through the coalition 

forces headquarters, and could draw upon a military police platoon for a 

security escort.

Also, starting in March 2003, DTRA worked to coordinate arrangements 

with DOE for its assistance with collecting radiological sources. DOE was 

to send both technical experts from one of its national laboratories and 

shipping containers to Iraq for the collection effort. However, the 

arrangements were complicated by DOE’s concerns about potential 

disposal of collected sources at its U.S. facilities and about the safety of 

DOE experts working in Iraq, as well as by communication difficulties. 

DOE had concerns about potential lawsuits arising from disposing of 

sources at its U.S. facilities. A DOE official told us that mislabeled or 

improperly packaged containers could lead to lawsuits if, for example, a 

source in a container was mislabeled and turned out to be a source that 

DOE’s U.S. site was not licensed to possess, or if poor packaging led to 

radiation leakage in the United States. Consequently, DOE insisted that its 

technical experts be present when the sources were collected to identify 

and package them in Iraq, before they were transported to DOE’s U.S. 

facilities, and DTRA agreed. When collections began, however, the danger 

of packaging sources in a hostile environment led DTRA to instead use 

temporary packaging in the field, followed by interim packaging at the 

Tuwaitha facility. The final packaging of the sources did not occur until 

May 2004 when DOE experts packaged them for shipment to the United 

States. 

DOE also had concerns about the safety of its experts while overseeing the 

packaging of the sources in Iraq. Consequently, DOE proposed a contract 

provision that required DTRA to make every reasonable effort to evacuate 

DOE experts to a safe area if hostilities broke out. DTRA initially said it 

could not accept this contract provision because it did not control the 

troops who could provide such protection. Eventually the contract said 

that the DOE experts would not be exposed to unreasonable risks, but, 

according to a DOE official, the discussion about a military protection 

clause held up the contract for a couple of weeks.
Page 12 GAO-05-672 Securing Iraqi Radiological Sources

Unclear communications also affected the negotiations between DTRA and 

DOE. For example, according to a DOE official, at one meeting DTRA told 

DOE that DTRA either had shipping containers or could get them. But a 

few weeks later, DTRA asked DOE to provide the containers. Then 

communication about the number of containers needed became an issue 

because DTRA could not know the number or type of radiological sources 

that would need to be transported. Finally, the DOE expert preparing a 

contract proposal had difficulty defining the scope of services to be 

provided to DTRA because DTRA’s plan was not clear to him. For example, 

he was not initially aware that the DOE experts would have only an 

oversight role and that DTRA was planning to use a contractor to do the 

collection work. 

In addition, between March and September 2003, DTRA was also 

negotiating with its contractor to collect sources. This process was delayed 

in large part by the contractor’s refusal to begin work until it obtained 

protection from legal claims for damages that could result from their 

work—that is, until they were given indemnification. Resolving this legal 

indemnification issue was delayed, in part, because DTRA contracting 

officials, who were uncertain about the infrequently used procedures for 

granting indemnification for work done under potentially hostile 

conditions, asked the contractor to provide what turned out to be 

unnecessary detail on the various damage scenarios that indemnification 

would cover. For example, one concern was that a convoy truck loaded 

with radiological sources would be fired upon, resulting in the radiological 

contamination of the area. In the end, DTRA decided that the 

indemnification language would be general and provided the contractor 

with indemnification in September 2003. Getting DOE experts working in 

Iraq was also delayed by indemnification issues, but their indemnification 

was settled earlier.

The contractor’s acquisition of equipment, such as helmets and body armor, 

was also delayed, although not as long as the indemnification. The State 

Department approves the export of such U.S.-origin defense products to 

other countries under the International Traffic in Arms Regulations; 

approval took over 50 days in the case of one request by the DTRA 

contractor. According to a State official, this delay occurred despite 

procedures to expedite approval of export applications for Operation Iraqi 

Freedom because this particular approval required congressional 

notification, a requirement State could not meet until Congress returned to 

session. As a result of these delays, according to a DTRA official, DTRA’s 

contractor wore helmets obtained from other countries because the 
Page 13 GAO-05-672 Securing Iraqi Radiological Sources

helmets could be obtained sooner. In addition, the contractor, which was 

responsible for obtaining all needed equipment for the collection mission, 

initially lacked some equipment. According to a DTRA official, in one 

instance, the contractor did not allow its workers to perform a mission 

because of concerns that heat at the work site exceeded safety standards 

even though the contractor lacked the monitoring equipment to make that 

determination. According to the contractor’s project manager, some 

necessary items were forgotten because the contractor team, which was 

being created for the first time, did not have an established standard 

equipment list for this mission.

Finally, DTRA’s efforts to subcontract with Iraqis to help with collections 

also took time. In July 2003, because of security concerns, DOD’s Office of 

Policy stopped Iraqis from the former Iraqi Atomic Energy Commission 

from independently collecting sources and rescinded their access to the 

secured bunker at Tuwaitha. By October 2003, DOD had decided to 

authorize, and encourage the use of, experienced Iraqis to locate sources, 

leave them secured in place when possible, and move unsecured sources to 

Tuwaitha, but this was an unsuccessful strategy for quickly increasing 

collection efforts. According to a DTRA official, DTRA tried unsuccessfully 

to get Iraq’s Coalition Provisional Authority to fund Iraqis from the Ministry 

of Science and Technology to collect sources, but restrictions on the 

Coalition Provisional Authority’s funds did not allow this. Eventually, 

DTRA arranged for its contractor that was collecting sources to 

subcontract some tasks to these Iraqis, but it took time to work out hiring, 

training, and procedures. For example, DTRA told us that subcontracting 

with the Iraqis was challenging because of difficulties with establishing 

banking procedures to ensure they got paid. By the time procedures were 

developed, training was finished, and the Iraqis began collection missions, 

it was February 2004, and DTRA’s collection mission was in its final 

months.
Page 14 GAO-05-672 Securing Iraqi Radiological Sources

DTRA Recovered or 

Left Secure in Place 

about 2,100 

Radiological Sources, 

but the Number of 

Unsecured Sources 

Remaining in Iraq Is 

Unknown

Between September 2003 and May 2004, DTRA collected and secured about 

1,400 radiological sources from sites throughout Iraq and left in place 

another 700 that it deemed secure. To further secure the most dangerous 

sources it had collected, in June 2004, DTRA and DOE together removed 

about 1,000 of the 1,400 previously collected sources from Iraq. Despite 

DTRA’s efforts, however, the total number of radiological sources in Iraq 

remains unknown.

DTRA Collected and 

Secured about 1,400 

Radiological Sources and 

Left about 700 Sources in 

Place after Judging Them to 

Be Secure 

During approximately 140 collection missions conducted between 

September 2003 and May 2004, DTRA and its contractor collected about 

1,400 unsecured radiological sources and inventoried and left in place 

about 700 sources that DTRA deemed secure.3

 To collect the 1,400 sources, 

DTRA identified their locations, traveled to those locations and found the 

sources, determined which sources to remove, transported those selected 

for removal to Tuwaitha, and secured them in a bunker there. According to 

DTRA officials, the collection missions were conducted safely, despite 

increasing insurgent hostilities and exposure risks associated with 

handling radioactive material. 

About 450 of the 1,400 sources ultimately collected were removed from 

radioactive lightning arrestors. Unlike conventional lightning arrestors, 

radioactive ones use radiological sources to enhance the attraction of 

lightning. One or more sources sat in a metal cylinder at the top of each of 

the metal arrestor poles. Iraq had located these arrestors around its 

munitions dumps, military bases, and industrial complexes to protect them 

from lightning strikes. If these facilities were abandoned, the lightning 

arrestors—including the radiological sources—would have been easily 

accessible to looters. Coalition forces also found sources used in 

commercial activities, such as oil exploration, agriculture, and scientific 

3

The count of approximately 700 sources left in place may be an undercount because 

devices with radiological sources, such as medical equipment, were counted as one source 

in DTRA’s inventory, but could possibly include more than one source inside. Appendix I 

includes a discussion of the reliability of the data on sources.
Page 15 GAO-05-672 Securing Iraqi Radiological Sources

research. The uses of many other unsecured sources DTRA collected were 

unknown.

As figure 2 shows, DTRA collected unsecured radiological sources from 

locations across Iraq, from the north at the Turkish border to the south 

near Al Basrah. However, many of the sources were collected at the 

Tuwaitha Nuclear Research Center, located about 25 miles from DTRA’s 

base camp near Baghdad International Airport. 
Page 16 GAO-05-672 Securing Iraqi Radiological Sources

Figure 2: Sites from Which Unsecured Sources Were Collected

Upon arrival at locations, the radiological sources were sometimes not 

where DTRA and its contractor expected to find them. For example, on one 

mission, a radiological source from a lightning arrestor was found outside 

its metal cylinder under about 2 inches of debris. A DTRA official told us 

Tigris River

Iraq

Turkey

Syria

Jordan

Saudi Arabia

Kuwait

Iran

Al

Basrah

Mosul

Euphrates

River

Collection sites

Baghdad

Sources: GAO analysis of DTRA data; MapArt.
Page 17 GAO-05-672 Securing Iraqi Radiological Sources

that looters apparently valued the metal lightning arrestor poles and copper 

wire inside them more than the radiological sources. At other times, DTRA 

and its contractor did not find the expected sources at all, which the 

contractor’s mission reports sometimes attributed to faulty intelligence or 

looting. 

If the radiological sources DTRA found were at an abandoned site or 

otherwise not under legitimate control of the Iraqis, DTRA collected them. 

For example, DTRA collected two large cesium sources from a factory that 

was largely abandoned. Similarly, if a lightning arrestor was damaged and 

the radiological source potentially subject to looting, DTRA would collect 

the source, according to a DTRA commander. 

After collecting and packaging the radiological sources, DTRA secured 

them by transporting them to a protected bunker at Tuwaitha. According to 

DTRA officials, DTRA had found a bunker at Tuwaitha that had blast-proof 

doors. DTRA further improved the bunker’s security, investing over $1 

million in improvements such as a chain link fence, gate, and security 

system. In addition, DTRA placed an armored unit outside the bunker to 

guard it. Figure 3 shows the protected bunker, under a mound of earth at 

the Tuwaitha Nuclear Research Center.

Figure 3: Bunker Where DTRA Secured Radiological Sources, Tuwaitha, Iraq

In addition to the about 1,400 radiological sources DTRA collected during 

its mission, DTRA left about 700 sources or source devices in place after it 

determined that they were properly secured and in the custody of 

Source: DTRA.
Page 18 GAO-05-672 Securing Iraqi Radiological Sources

responsible personnel. According to DOD’s guidance, coalition forces and 

DTRA could leave sources in place if they 

• had medical, agricultural, industrial, or other peaceful uses;

• were properly contained and adequately secured; and 

• were in the custody of trained personnel acting in a professional 

capacity, such as hospital staff or agricultural ministry personnel. 

DTRA relied on this guidance to determine whether radiological sources it 

found could be left in place. In line with the guidance, when DTRA left 

sources in place, it recorded information such as location, use, and 

responsible institution or individual. Although the guidance did not 

elaborate on the standard for adequate security, a DTRA commander told 

us that the guidance was sufficient for DTRA to decide which sources were 

secure enough to be left in place. 

 DTRA’s initial planning had assumed that the war would be over when its 

contractor went to work and, therefore, it would be collecting sources in a 

peaceful environment. Instead, with insurgent attacks continuing after 

major combat operations were declared over, the contractor’s staff was 

consistently exposed to danger. In fact, insurgent attacks throughout Iraq 

significantly increased during the collection period and generally became 

more sophisticated, widespread, and effective (see fig. 4). 
Page 19 GAO-05-672 Securing Iraqi Radiological Sources

Figure 4: Number of DTRA Contractor Missions and Number of Insurgent Attacks 

throughout Iraq, June 2003 to May 2004

Notes: Attacks were against infrastructure, Iraqi Security Forces, civilians, or coalition forces.

The initial August 2003 missions were done only at Tuwaitha, as contractor staff waited for indemnity to 

be granted.

Although some areas were known as particularly dangerous for travel, 

attacks were unpredictable and occurred in many places. For example, 

according to a DTRA commander, during the first day of a mission in the 

Sunni triangle, the DTRA team came under mortar and sniper attack; 

during the second day, a helicopter involved in the mission experienced a 

rocket-propelled grenade attack. On another occasion, a DTRA convoy 

traveling through Baghdad was delayed by an explosion that left a burning 

vehicle in the road. Even within the relative security of the Tuwaitha 

Nuclear Research Center, DTRA’s contractor reported hearing shots fired 

and found an improvised bomb on the road.

0

5

10

15

20

25

Iraqi subcontractor missions

U.S. contractor missions

Monthly attacks

Number of missions

Source: GAO analysis of DOD data.

Year

0

500

1,000

1,500

2,000

June July Aug. Sept. Oct. Nov. Dec. Jan. Feb. Mar. Apr. May

2003 2004

Number of attacks
Page 20 GAO-05-672 Securing Iraqi Radiological Sources

To help decrease the danger, DTRA planned armed security for each of its 

missions. DTRA officers told us they assessed the potential danger 

associated with a particular mission and, if the anticipated security risk 

was higher than usual, they increased the size of the security force. For 

example, the number of vehicles with mounted weapons might be 

increased from two to four. When the risks seemed particularly high, 

missions were at times postponed. DTRA’s security plan also specified the 

route of the convoy, so its location could be tracked with a communication 

system and a quick-response military team could be sent if needed. In 

addition, military troops sometimes secured the area around the source 

before the arrival of DTRA’s contractor staff.4

Despite the attacks and the risk of exposure to radiation when collecting 

radiological sources, DTRA officials reported that the agency’s missions to 

collect and secure radiological sources from September 2003 to May 2004 

were conducted safely. According to DTRA officials, although the risks 

from hostilities were often greater than the risks from handling the 

radiological sources, DTRA’s team did not sustain casualties during its 

collection missions. However, two contractor staff were injured—one 

seriously—in a mortar attack at DTRA’s home base near Baghdad 

International Airport, but not during a collection mission. With regard to 

radiation exposure, the contractor’s plan called for keeping the effect of 

individual exposures on a person as low as reasonably achievable and 

cumulative exposures over the mission below specified limits. Although six 

team members’ hands or feet were contaminated with radioactive powder 

in one instance, according to DTRA and contractor officials, DTRA 

personnel and contractor staff remained under the cumulative standard 

throughout the overall mission.

DOE and DTRA Removed 

about 1,000 of the Most 

Dangerous Sources from 

Iraq

In March 2004, a National Security Council interagency policy committee 

that included DOD and DOE made the final decision to remove the most 

dangerous radiological sources from Iraq before the Coalition Provisional 

Authority handed power over to the interim Iraqi government at the end of 

June 2004. In the case of Iraq, DOE selected radiological sources for 

removal based on its criteria for determining which radioactive material 

posed a significant risk as dirty bomb material. Normally, DOE applies its 

criteria to individual sources in determining the risk. In this case, DOE 

4

Iraqi subcontractors provided their own armed security during their missions to collect 

sources or document sources left in place.
Page 21 GAO-05-672 Securing Iraqi Radiological Sources

consolidated some of these sources that, individually would not have met 

the risk criteria, but did meet the criteria once they were consolidated into 

waste shipment containers. According to a DOE official, using the criteria 

this way was warranted because the consolidation of the sources in the 

storage bunker created a potential public health risk or a target for theft, 

and Iraq had ongoing hostilities. As a result of applying its criteria in this 

way, DOE removed from Iraq about 1,000 of the 1,400 collected sources, 

accounting for a total of almost 2,000 curies, or over 99 percent of the 

radioactivity of the collected sources. The remaining radiological sources 

were generally small, accounting for a few curies of radioactivity in total.

After the National Security Council approved the removal mission in March 

2004, final preparations for the mission were completed in about 2-1/2 

months and the mission was finished in about 1 month. In late May 2004, 

DOE sent a team of 20 experts to Iraq to identify the type and radioactive 

strength of each collected source and package the sources for shipment to 

the United States. Given the escalating hostilities, DTRA hired a contractor 

to create a protected living area for the DOE team at the Tuwaitha site to 

reduce the exposure to attacks that would have resulted from traveling 

daily from a base camp to work at Tuwaitha. Figure 5 shows this living area 

and the concrete barriers placed at the perimeter. 
Page 22 GAO-05-672 Securing Iraqi Radiological Sources

Figure 5: Protected Living Area for DOE Experts at the Tuwaitha Nuclear Research 

Center

DOE had difficulties coordinating with DTRA to get all the information 

needed to determine the number and types of shipping containers for the 

source recovery mission. DTRA constructed its inventory information on 

radiological sources collected at the Tuwaitha bunker to try to meet DOE’s 

needs. However, DOE experts told us DTRA’s information never fully met 

DOE’s expectations. Specifically, DOE wanted comprehensive information 

on the type of isotope and radioactivity of the sources to determine the 

number and types of containers needed to safely ship the sources to the 

United States, as well as to do other planning tasks, such as an 

environmental impact assessment. According to DOE experts, DTRA could 

never provide, for example, complete and accurate information on 

radioactivity. Deciding that full information would not be forthcoming, the 

DOE experts overestimated radioactivity to ensure that DOE would bring 

enough containers from the United States to ship the radiological sources 

back safely. 

Ultimately, DTRA and DOE were able to complete the task of analyzing, 

packaging, and loading the containers into trucks in about 25 days. DTRA 

and DOE successfully removed about 1,000 radiological sources and about 

1.7 metric tons of low-enriched uranium from Iraq on June 23, 2004, 5 days 

Source: DOE.
Page 23 GAO-05-672 Securing Iraqi Radiological Sources

before the transfer of power from the Coalition Provisional Authority to the 

interim Iraqi government. DTRA and DOE transported the sources in a 

heavily guarded convoy to a military airfield, and then departed from Iraq 

by military air transport. These materials were taken to a DOE site within 

the United States and are being evaluated for either reuse or permanent 

disposal. The disposal activities, funded by both DTRA and DOE at an 

estimated $4.2 million, are expected to continue through late fiscal year 

2006.

According to DOE officials, the final disposition of the radiological 

materials removed from Iraq may take longer and cost more than estimated 

because a legal determination is needed regarding whether the United 

States government owns the material or is merely serving as its custodian. 

Currently, DOE is storing the sources temporarily at one of its sites, but it is 

waiting for an interagency determination before deciding on how to 

dispose of the material. According to DOE officials, they raised this issue of 

ownership when the removal mission was being planned, but it was never 

resolved. As of mid-April 2005, DOE was prepared to start shipping sources 

to disposal facilities, but DOE disposal facilities are unwilling to take 

possession of the sources until ownership has been determined. Thus, DOE 

will hold the sources in temporary storage longer than anticipated, leading 

to increased storage costs.

An Unknown Number of 

Radiological Sources 

Remain Unsecured In Iraq

Although DTRA’s effort to collect unsecured sources and leave secured 

sources in place identified about 2,100 radiological sources in Iraq, it is 

likely that other sources remain unsecured in Iraq for three reasons. First, 

the number and location of all sources in Iraq before the war were not 

known. Second, DOD did not search in all places in Iraq where sources 

might be found. Third, since the end of DTRA’s mission in June 2004, other 

unsecured sources have been found, including at Iraq’s borders. 

The number of sources in Iraq prior to Operation Iraqi Freedom was not 

precisely known because the former government of Iraq did not maintain 

an inventory of radiological sources around the country. Around the time 

that major combat operations were declared over in May 2003, DOD 

received information on radiological sources in Iraq, but DOD and State 

officials told us that this information was not reliable for the purpose of 

locating and securing sources. For instance, DTRA officials told us that the 

information on sources and their locations was not precise because the 

names of locations were not clear, some sources were reported twice at the 

same location, and the information was sometimes outdated. However, 
Page 24 GAO-05-672 Securing Iraqi Radiological Sources

DTRA used this information as a general guide to where sources might be 

found. Lacking more reliable information about the number and location of 

sources in Iraq at the beginning of the war, DTRA first collected sources 

discovered by coalition forces and then searched for other sources. 

Because DOD and DTRA did not search all locations where radiological 

sources might be found, it is likely that unknown sources remain 

unsecured in Iraq. One DTRA official told us that DTRA was not tasked to 

search all locations where sources might be found. In addition, DTRA 

found evidence that sources had been taken from some locations before 

DTRA arrived. According to State officials, neighboring countries detected 

elevated radiation readings from cargo on trucks leaving Iraq starting at 

least by September 2003, and some of these trucks were turned back at the 

border. Although many of these incidents involved radioactively 

contaminated scrap metal, some cargo included sources. State officials 

said they did not know where the trucks and their cargo went after 

returning to Iraq, but the State Department sought to improve coordination 

with neighboring countries to manage these border incidents. Because of 

the lack of a complete search for sources in Iraq, officials of the interim 

Iraqi government told us that it intended to perform a more comprehensive 

search. 

Finally, sources continued to be found in Iraq and at its border after DTRA 

completed its collection and removal mission in June 2004. In addition, 

according to State officials, radioactive materials, primarily contaminated 

scrap metal but also some sources, continued to be detected on trucks 

leaving Iraq after that time. Separately, in August and September 2004, for 

example, a country bordering Iraq found radioactive sources on trucks 

leaving Iraq. Also, a U.S. Army officer responsible for nuclear, biological, 

chemical, and radiological issues in Iraq told us that, in at least one case, an 

unsecured source or sources from lightning arrestors had been discovered 

by U.S. troops since the end of DTRA’s mission in Iraq. 

The United States 

Helped Create an Iraqi 

Agency to Regulate 

Sources, but Future 

Assistance Is Uncertain

The Department of State supported the Coalition Provisional Authority in 

creating an independent Iraqi agency, the Iraqi Radiological Source 

Regulatory Authority (IRSRA), to regulate sources, and State and DOE are 

assisting the new agency by providing equipment, technical assistance, and 

funding. However, the evolving Iraqi government—including the 

transitional government formed after the January 2005 election and the 

permanent government to be formed through an upcoming election—and 
Page 25 GAO-05-672 Securing Iraqi Radiological Sources

the ongoing insurgency are creating uncertainties for both IRSRA and U.S. 

assistance. 

State Facilitated the 

Creation of an Iraqi 

Radiological Source 

Regulatory Agency 

Before the transition to the interim Iraqi government in June 2004, State’s 

Bureau of Nonproliferation encouraged the creation of IRSRA. It saw this 

effort as an extension of U.S. support for international standards for safe 

and secure management of radiological sources, such as those coordinated 

and administered by IAEA. Specifically, IRSRA will further several U.S. 

foreign policy goals. First, an Iraqi agency that controls radiological 

materials will promote the health and safety of Iraqis, as well as provide the 

capability for Iraq to meet international commitments for the safe and 

secure management of radiological sources. Second, an effective Iraqi 

agency for regulating sources will promote U.S. national security goals by 

decreasing the likelihood of terrorists trafficking in or deliberately 

releasing radioactive material. Third, the new agency will employ former 

Iraqi scientists who might otherwise seek employment with terrorists or 

countries seeking WMD expertise.

State officials enlisted Iraqi officials within the Coalition Provisional 

Authority to support the formation of IRSRA. In particular, State negotiated 

with the Minister of the Ministry of Science and Technology (MOST), who 

played a leading part in supporting the creation of IRSRA. The Minister 

agreed to allow IRSRA to regulate Iraq’s radiological sources, while MOST 

will retain ownership and control of secured nuclear and radiological 

materials at research facilities. The Minister also agreed to continue 

DTRA’s efforts to find and collect unsecured radioactive sources, but under 

contract with IRSRA. The Minister further agreed that IRSRA would be 

legally and financially independent—a key element in State’s plan for 

IRSRA. According to State officials, IRSRA was designed as an independent 

agency to avoid conflicts of interest. While Iraqi ministries, such as the 

Ministry of Health, the Ministry of Oil, and MOST, own or track many of the 

radiological sources in Iraq, their activities will be subject to the regulation 

of IRSRA, which will inspect, inventory, and regulate all sources in Iraq.

In addition, through discussions with Iraqi and Coalition Provisional 

Authority officials, State helped draft the 2004 budget plan and the 

organizational structure of IRSRA. The plan included providing $7.5 million 

to the new agency within the Iraqi Government Budget developed by the 

Coalition Provisional Authority for fiscal year 2004. These funds are to be 

spent on salaries, the search for sources, assistance from U.S. experts, 

office space, and facility security. State’s organizational plans for IRSRA 
Page 26 GAO-05-672 Securing Iraqi Radiological Sources

identified the departments and staffing needed to accomplish agency tasks, 

such as regulating radiological sources in use, managing unwanted 

radiological sources, and creating regulations in cooperation with IAEA 

and other experts. In addition, to further State’s efforts, DTRA trained 

Iraqis to collect, store, and secure radiological sources during its own 

collection operations and subsequently provided Iraqis with an upgraded 

secure storage facility and its inventories of sources removed from the 

country, left at the facility, or identified around Iraq.

In June 2004, the Coalition Provisional Authority issued an order 

establishing IRSRA.5

 According to the order, IRSRA will promulgate and 

enforce regulations to allow for beneficial uses of radioactive sources, 

provide for adequate protection of humans against the harmful effects of 

radiation, and ensure the safety and security of radiological sources. For 

example, it will require hospitals, universities, oil production facilities, and 

others to obtain licenses to possess radiological sources, which will enable 

the agency to maintain records on radiological sources in the country. 

Licensees will be obliged to follow procedures and regulations that define 

how they will secure, inventory, and work with their licensed radiological 

sources. In addition, IRSRA is responsible for collecting unsecured sources 

when they are found, creating radiation health and safety criteria, and 

researching the possibility of constructing a low-level radioactive waste 

disposal facility in Iraq. The Coalition Provisional Authority disbanded 

shortly after it created IRSRA, but its order will continue to have legal 

authority in Iraq until it is amended or changed by the Iraqi government, 

according to State officials.

By the summer of 2005, State officials told us, they perceived signs that 

IRSRA was beginning to function and was becoming more established as 

part of the Iraqi government. For example, IRSRA had started drafting 

regulations and was requiring ministries to notify it about their radiological 

sources. Moreover, it had an appointed chairman, developed a budget, and 

obtained its own building and office space, as well as about 50 staff. 

5

Coalition Provisional Authority Order Number 72, “Iraqi Radioactive Source Regulatory 

Authority,” CPA/ORD/10 June 2004/72 (June 10, 2004).
Page 27 GAO-05-672 Securing Iraqi Radiological Sources

State and DOE Are 

Providing Assistance to the 

New Regulatory Agency

In addition, State and DOE are assisting IRSRA by providing equipment, 

facilitating technical assistance, and providing funding. First, to help the 

Iraqis collect unsecured sources under the direction of IRSRA, State has 

initiated an effort to transfer to Iraqi agencies equipment that had been 

purchased by DTRA to collect sources. This equipment includes 

radiological handling, measurement, and protective equipment, such as 

radiation meters, respirators, and protective clothing. According to State 

officials, preparations for the transfer of this equipment began in mid-2004; 

as of early 2005, State and DOD were discussing how this equipment would 

be transferred to the Iraqis. In the meantime, this equipment has been made 

available to MOST for collecting radiological materials. 

State is also facilitating technical assistance. With funding and logistical 

support from DOE, State coordinated several meetings in Amman, Jordan, 

in December 2004 to provide IRSRA personnel training by IAEA staff and to 

help them draft an action plan for regulating radiological sources. IRSRA’s 

action plan is based on the IAEA Model Project program, through which 

IAEA is helping about 100 developing countries establish effective 

regulatory controls for radioactive sources. Under the Model Project 

program, developing countries adopt action plans to help them establish or 

strengthen radiation protection infrastructures in order to meet 

international standards and to follow the guidance in the IAEA Code of 

Conduct on the Safety and Security of Radioactive Sources. 

Under the action plan, which was finalized in March 2005 meetings in 

Washington, D.C., IRSRA will establish a regulatory framework; work to 

control radiation exposure in occupational, medical, and public settings; 

and set up emergency preparedness and response capabilities. IAEA plans 

to provide expert assistance to help IRSRA meet these goals. In addition, to 

help IRSRA find unsecured sources, IAEA will offer radiation detection 

equipment and training in border control. To complement the action plan, 

IAEA is sharing with IRSRA a computer program designed to track 

information about radiological sources’ locations, radioactive strengths, 

licensing, and responsible parties. IRSRA intends to use this program to 

manage information it gathers on Iraqi radiological sources.

In addition, in coordination with IRSRA’s action plan, DOE is offering 

IRSRA technical assistance to help ensure the security of radiological 

sources. For example, DOE plans to provide experts to review draft Iraqi 

laws and regulations for their relevance to security. DOE also plans to 

assist IRSRA with facility upgrades to address security vulnerabilities of 

sources used for medical, industrial, or other peaceful purposes. Moreover, 
Page 28 GAO-05-672 Securing Iraqi Radiological Sources

in conjunction with IAEA, DOE may also offer field equipment and training 

workshops for inspecting the security of sources. 

Finally, to financially support IRSRA’s action plan, State intends to use 

$1.25 million from its Nonproliferation and Disarmament Fund, which 

provides funding for projects to prevent the spread of WMD. State plans to 

provide part of these funds to IAEA for training and other assistance to 

IRSRA, including an IAEA review of Iraq’s draft laws and regulations. State 

plans to also use the funds to purchase a specially equipped vehicle that 

can be driven through neighborhoods to detect unsecured radiological 

sources. In addition, State plans to hire a contractor to coordinate security 

matters with coalition forces to minimize the risk of attacks, while the 

Iraqis are working to control sources.

Iraq’s Political Transition 

and Continuing Hostilities 

Are Creating Uncertainties 

for IRSRA and U.S. 

Assistance

According to State officials, because of uncertainties associated with the 

continuing formation of the Iraqi government, State will have to monitor 

Iraqi efforts to ensure the continued growth and success of an independent, 

competent, and sustainable regulatory authority for the control of 

radioactive sources and materials. According to these officials, the ongoing 

formation of the Iraqi government could affect the future of IRSRA in 

several ways. First, potential changes to the government’s organization or 

personnel could affect IRSRA’s funding and enforcement powers. For 

example, the transitional government formed from the January 2005 

election chose new government ministers—including replacing the 

Minister of Science and Technology, who had aided the formation of 

IRSRA. In addition, according to State and Iraqi officials, in early 2005, the 

Iraqi government froze all new expenditures until the transitional 

government takes action on the budget. Therefore, the funds for the IRSRA 

contract with the ministry to search and recover sources were not 

available. However, State officials told us the collection missions are 

important for public safety and would go forward in anticipation of later 

payment. Finally, the Iraqi government will have to enact the laws and 

regulations that IRSRA will be drafting under its action plan. 

In addition, State officials told us that the evolving relationship of the 

northern Kurdish-controlled territories with the rest of Iraq could affect 

IRSRA’s operation. Before Operation Iraqi Freedom, the Kurds enjoyed 

some independence from the former Iraqi regime, and State officials told us 

that this partial independence has continued. IRSRA and Kurdish officials 

will be discussing whether and how IRSRA will operate in 

Kurdish-controlled territory. According to the Chairman of IRSRA, Kurdish 
Page 29 GAO-05-672 Securing Iraqi Radiological Sources

officials are likely to accept a proposal to create a branch office of IRSRA 

in Kurdish territory. This proposed office would be staffed by Kurds, but 

IRSRA would provide equipment, training, and protocols. 

Finally, the continuing insurgency is hindering IRSRA’s ability to find and 

collect unsecured radiological sources as well as the ability of the United 

States to provide assistance. Iraqi and State officials are concerned that 

insurgents will target Iraqis who are seen associating with coalition forces 

on their official duties. For example, a MOST official told us that Iraqi 

workers entering a U.S. military base to collect sources would likely be 

ambushed by insurgents upon leaving the military base. The hostile 

environment also impairs the ability of the United States to provide certain 

kinds of assistance. For example, DOE has decided not to send its experts 

into Iraq because of the ongoing hostilities, according to a DOE official. 

However, State and DOE are devising ways to assist without going to Iraq, 

such as organizing training for Iraqis at sites outside of the country. 

DOD Has Not Assessed 

Its Source Recovery 

Effort, but DOE Is 

Considering Lessons 

Learned

Although DOD has assessed its overall WMD mission in Iraq, the agency 

has not assessed its narrower mission to collect and secure radiological 

sources. In contrast, DOE has considered actions to address specific 

lessons learned from its experience in removing radiological sources from 

Iraq.

DOD Has Assessed Its 

Broader WMD Mission but 

Has Not Focused on the 

Radiological Sources Effort

DOD asked its National Defense University (NDU) to study DOD’s overall 

mission to find and eliminate WMD in Iraq, determine what lessons could 

be learned from it, and recommend improvements. The resulting report 

stated that DOD had not sufficiently planned and prepared for the WMD 

mission; had shortfalls in the needed transportation, military security, and 

logistics resources; and had operational difficulties arising from the 

extensive looting, public disorder, and hostile security environment. The 

report recommended that DOD develop the capability to quickly eliminate 

WMD in hostile environments and establish a permanent organization for 

eliminating WMD. (See app. II for more information on the report.) DOD is 

responding to the report, in part, by seeking stronger planning and capacity 

for eliminating WMD, which a DOD Joint Staff officer told us would include 

the elimination of radiological materials. Specifically, DOD’s Strategic 

Command, which was assigned responsibility for this planning in January 
Page 30 GAO-05-672 Securing Iraqi Radiological Sources

2005 by the Secretary of Defense, will first determine the needed 

capacities.

The NDU report did not, however, offer any observations or 

recommendations regarding the narrower mission to collect and secure 

radiological sources in Iraq, in part because this was not the main focus of 

the original WMD mission in Iraq. Nevertheless, the author of the NDU 

report and a DOD Joint Staff officer told us that DOD’s efforts to solve 

overarching issues with its preparation for eliminating WMD will also 

address problems experienced with the mission to collect and dispose of 

radiological sources.

DOE Is Considering Lessons 

Learned from Removal of 

Iraqi Radiological Sources

DOE asked its contractor at one of its national laboratories to analyze the 

removal mission to identify lessons learned and recommend 

improvements. The resulting analysis highlights the lessons that timing of 

funds and availability of equipment hindered rapid preparation for the 

mission.6

 First, the contractor noted that the short amount of time between 

when the project was funded and when the team left for Iraq meant that 

almost every preparation task had to be conducted in emergency mode. 

DTRA funding became available in March 2004 after the National Security 

Council approved the mission, leaving less than 2-1/2 months for the team 

of DOE experts to complete all preparations in the United States. Needed 

preparations included establishing a liaison with DTRA in Iraq; determining 

the list of sources to be removed based on DTRA’s inventory; developing 

safety and handling procedures for those specific sources; completing 

safety assessments for those procedures; determining the need for, and 

obtaining, a National Security Exemption to bring some of the radioactive 

sources to the United States; recruiting the remainder of the team 

members; cross training team members to be able to complete another 

member’s work if necessary; getting the DOD training and authority 

necessary for the team to enter Iraq; obtaining contractor indemnification 

for the mission; preparing a U.S. staging facility for equipment; and 

procuring, testing, and packaging such equipment as protective clothing, 

tents, and communication equipment. 

In addition, according to the contractor, preparation for the mission was 

almost critically delayed by difficulties in acquiring containers for 

6

The analysis does not address DTRA’s contracting of DOE experts for the collection 

mission, which was conducted before the joint DOE and DTRA removal mission.
Page 31 GAO-05-672 Securing Iraqi Radiological Sources

transporting the radiological sources. DOE and its laboratories did not 

have a sufficient number and variety to meet the projected needs of the 

removal mission—a shortfall that proved challenging to overcome in time 

to successfully conduct the mission. Specifically, certain special containers 

could not be procured in time from U.S. domestic suppliers as a result of 

shortages. Consequently, DOE arranged to lease four of these special 

containers from a foreign company by agreeing to provide the company 

blanket indemnity with up to approximately $1 billion in liability coverage 

in case of an accident involving the containers. The containers arrived a 

few days before the team and its equipment were to leave for Iraq. 

According to the contractor, if DOE’s negotiations to get the special 

containers had failed, the removal mission would have been delayed, and it 

is likely that many radiological sources with high radiation levels would not 

have been able to be removed.

To support timely action in future removal operations, the contractor 

recommended that DOE seek ways to ensure the existence of advanced 

funding and maintain a small fleet of versatile containers. DOE officials 

told us they saw merit in having a way to quickly fund future missions, 

although their agency’s funding—used solely for the disposal rather than 

the removal of the sources—was available early enough in the case of Iraq. 

With regard to maintaining a reserve of containers and other equipment, 

the officials solicited proposals and cost estimates from their national 

laboratories and have determined they cannot pursue this option given 

current budget constraints.

Conclusions Because DOD has not comprehensively reviewed its experiences in 

collecting and securing radiological sources in Iraq, its current efforts to 

improve its preparations to secure or destroy WMD in future missions will 

not benefit from important lessons learned from its radiological source 

mission. Reviewing such experiences and identifying lessons learned 

would help prepare for any future missions involving similar 

circumstances.

In addition, DOD’s lack of readiness to quickly collect and secure sources 

after the war began indicates that additional planning and preparation 

could have been completed in advance of the mission. Specifically, DOD 

had not
Page 32 GAO-05-672 Securing Iraqi Radiological Sources

• planned to collect sources in a hostile environment and thus had to act 

during the operation to integrate the objective of collecting and securing 

sources with military combat objectives;

• established criteria to determine which radiological sources needed to 

be collected, which were being properly used and thus could be left in 

place, and which posed minimal threat and thus did not need to be 

collected;

• specified health and safety standards for handling, securing, 

transporting, and disposing of sources;

• specified the organization responsible for collecting and securing 

sources in Iraq until shortly before the invasion of Iraq, nor established 

agreements within DOD regarding issues such as using armed private 

security forces to protect contractors involved in collecting and 

securing sources;

• established agreements or points of contact with DOE to determine the 

support that DOE could provide, including the type of expertise, 

equipment, and disposal facilities;

• identified and addressed the legal and contractual issues associated 

with using private contractors to assist in collecting and securing 

sources, including using such contractors in hostile environments; and 

• established guidelines to utilize the skills and address security concerns 

associated with the use of Iraqi radiological experts. 

Recommendations for 

Executive Action

To ensure that the types of problems experienced with the planning and 

preparing for securing Iraqi radiological sources do not recur, we 

recommend that the Secretary of Defense comprehensively review DOD’s 

experience for lessons learned for potential future missions. 

In addition, to ensure that planning and preparing for potential future 

missions is carried out in advance, we recommend that the Secretary of 

Defense provide specific guidance for collecting and securing radiological 

sources, including 

• integrating the objective of collecting and securing radiological sources 

with military combat objectives, including specifying how security 
Page 33 GAO-05-672 Securing Iraqi Radiological Sources

protection, if needed, would be provided to the organization with 

responsibility for managing radiological sources and whether combat 

troops would be required to secure sources and provide protection for 

operations to collect and secure radiological sources; 

• determining criteria to define which radiological sources (1) are of 

greatest risk and should be collected, (2) are being properly used and 

secured and thus can be left in place, and (3) pose minimal threat and 

thus do not need to be collected; 

• specifying the health and safety standards, after considering how U.S. 

standards for handling, securing, transporting, and disposing of 

radiological sources were modified for use in Iraq;

• officially designating the organization responsible within DOD for 

collecting, securing, and disposing of sources and establishing 

agreements between that organization and other DOD organizations 

that may be involved with these efforts; 

• establishing agreements and points of contact with DOE and other 

federal agencies, as needed, to specify the coordination, technical 

expertise, equipment, and facilities that may be needed to collect and 

secure sources in, or remove them from, a foreign country; 

• identifying under which circumstances and for what purposes DOD will 

contract with private firms to conduct activities to collect and secure 

radiological sources, and address legal and contracting issues to ensure 

the timely use of contractors; and

• establishing guidelines concerning the role of radiological experts from 

the country where sources need to be collected and secured.

Agency Comments and 

Our Evaluation 

We provided the Departments of Defense, State, and Energy with draft 

copies of this report for their review and comment. 

DOD agreed with four of our recommendations, partially concurred with 

two, and did not concur with two. DOD stated that it had previously 

addressed a number of issues identified in the recommendations and is 

currently addressing the others. DOD also stated that the draft report did 

not adequately address those efforts of the Nuclear Disablement Team 

(NDT) during the earlier operations in Operation Iraqi Freedom involving 
Page 34 GAO-05-672 Securing Iraqi Radiological Sources

radiological source recovery operations. DOD stated that the focus of the 

draft report appeared to be largely on the elimination phase of the 

operation and that it accepted our recommendations in that area. Our 

report assessed all phases of DOD’s planning and preparing for this 

mission, including the experiences of the NDT and its decision to forgo 

collecting sources because it lacked the proper equipment. We believe our 

report was appropriately focused on the elimination phase because that 

was when most sources were collected from around Iraq.

DOD partially concurred with our recommendation to develop lessons 

learned, indicating that lessons learned have been developed from the 

NDT’s experiences for the phase of the operation before DTRA began to 

collect sources. That effort is in line with our recommendation, but unless 

DOD completes a more comprehensive review, we are concerned that it 

will miss the experience of all relevant DOD organizations and the full 

range of lessons learned. 

DOD also partially concurred with our recommendation about integrating 

the objective for securing radiological sources with military combat 

objectives, saying that this recommendation applies only to the later phase 

involving DTRA’s work. However, we disagree that our recommendation 

applies only to DTRA’s work. As our report points out, there were problems 

with integrating the mission of collecting and securing sources with 

military combat objectives during the NDT phase of operations as well. 

Specifically, our report notes that during the NDT phase of operations, 

military commanders were left to make ad hoc decisions about recovering 

and securing sources, including using combat troops to guard sources. 

DOD’s response to this recommendation also noted problems DOD 

encountered in obtaining support from DOE. We believe our report 

adequately discusses problems DOD encountered in obtaining DOE 

assistance in collecting radiological sources—these problems stemmed 

from the lack of advanced coordination that our report recommends DOD 

resolve prior to any future missions. DOD also commented that our 

recommendation demonstrated a lack of understanding by suggesting that 

combat troops should be involved in handling radioactive materials. We 

revised our recommendation to more clearly indicate that DOD should 

decide whether combat troops would again be required to secure sources 

and protect missions to collect sources, as they did in Iraq.

DOD did not concur with our recommendation concerning health and 

safety criteria and suggested that our recommendation was too broad and 

ill defined. DOD’s rationale for this response is not clear. First, DOD said 
Page 35 GAO-05-672 Securing Iraqi Radiological Sources

that guidance is and always has been available. Then, DOD said that since 

Operation Iraqi Freedom was the first time in recent history that a 

capability was developed and deployed to counter a WMD threat, no unit 

level standard operating procedures existed. DOD then said that the NDT 

did develop procedures to “address all these issues” and that the NDT 

continues to work to develop changes to existing regulations to “address all 

these particulars.” We have clarified our recommendation to indicate that 

DOD, in specifying health and safety standards, should consider how U.S. 

health and safety standards were modified in Iraq during the mission to 

collect and secure sources. We continue to believe that DOD should fully 

implement our recommendation. 

Finally, DOD did not concur with our recommendation to establish the 

organization responsible within DOD for collecting, securing, and 

disposing of sources. DOD said that it had already identified this 

organization as the NDT and that the Commander of Strategic Command 

has overall responsibility for issues related to WMD, a subset of which is 

collecting, securing, and disposing of sources. However, based on a 

conversation we had in August 2005 with a DOD Joint Staff officer, 

Strategic Command has not yet issued its plan for combating WMD, in 

which the specific organization responsible for collecting, securing, and 

disposing of sources will be officially designated. DOD’s complete 

comments are reprinted in appendix III.

State suggested clarifications of its current outlook for U.S. assistance to 

Iraq for radioactive source regulation and the reason for the delay in State’s 

approval of export licensing, which we have incorporated into this report. 

Separately, State provided technical comments, which we incorporated as 

appropriate. State’s written comments are reproduced in appendix IV.

DOE had no written comments on the report but did state that it will work 

with DOD to determine criteria to define which radiological sources are of 

greatest risk. 

We are sending copies of this report to the Secretary of Defense, the 

Secretary of Energy, the Secretary of State, and interested congressional 

committees. We will also make copies available to others upon request. In 

addition, this report will be available at no charge on the GAO Web site at 

http://www.gao.gov.
Page 36 GAO-05-672 Securing Iraqi Radiological Sources

If you or your staff have any questions about this report, please contact me 

at (202) 512-3841 or aloisee@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix V.

Gene Aloise

Director, Natural Resources

 and Environment
Page 37 GAO-05-672 Securing Iraqi Radiological Sources

Appendix I

Scope and Methodology ApApenednxidexiIs

This report (1) assesses Department of Defense (DOD) readiness to collect 

and secure radiological sources in Iraq from the start of the 2003 war,

(2) presents information on the number of radiological sources the Defense 

Threat Reduction Agency (DTRA) secured by the time of the June 2004 

transition to the interim Iraqi government, (3) describes the assistance the 

United States has provided, and plans to provide in the future, to the Iraqi 

government to help regulate radiological sources in Iraq, and (4) examines 

DOD and Department of Energy (DOE) actions to assess their experiences 

in Iraq and apply any lessons learned to possible future radiological source 

collection missions.

For our first objective, to assess DOD’s readiness to collect and secure 

radiological sources, we reviewed planning efforts before the war began in 

March 2003; concerns and efforts regarding radiological sources before 

DTRA began its collection mission in late 2003; relevant policy guidance; 

and DTRA’s preparations to collect unsecured sources in Iraq. To 

understand DTRA’s prewar plans, we interviewed a division chief of DTRA’s 

Combat Support Directorate, who prepared these plans, and other DOD 

officials involved in planning before the war. For concerns and efforts 

before DTRA began to collect sources, we interviewed the Nuclear 

Disablement Team commander and other team members and reviewed an 

unclassified report on their activities in Iraq. We also interviewed the senior 

chemical officer for the commander of coalition land forces who secured 

radiological sources in Iraq. For policy guidance, we examined two DOD 

policy memorandums on radiological sources in Iraq and interviewed 

DTRA and DOD officials involved with the development of the guidance. 

For specific preparations to collect sources, we interviewed DTRA officials 

who prepared for the mission, including the two commanders who 

sequentially prepared for the mission in Iraq and the DTRA director 

responsible for the mission. We also reviewed the contract between DTRA 

and its contractor, and the contract agreement between DTRA and DOE. 

We interviewed DTRA officials who developed and managed the contract, 

the DOE official who facilitated the development and execution of the 

contracts, and contractor’s project managers and staff. 

For our second objective, to present information on the number of 

radiological sources secured, we assessed the data reliability of five 

inventories of radiological sources in Iraq and summary data about the 

sources’ radioactivity. We asked those responsible for creating or 

maintaining the inventories a series of questions focused on data reliability, 

covering issues such as internal control procedures and the accuracy and 

completeness of the data. Our assessment follows:
Appendix I

Scope and Methodology

Page 38 GAO-05-672 Securing Iraqi Radiological Sources

1. We assessed the reliability of an inventory of the location, number, and 

type of sources in Iraq at the beginning of the war that DTRA received 

during its mission, and based on our work, we determined that these 

data were not sufficiently reliable for the purposes of this report to 

specify the number of sources at the beginning of the war. Because the 

source of this information is sensitive, we did not report its origin. 

DTRA officials told us they found this data to be unreliable, but it did 

match well with sources found at some sites. For our assessment of the 

data, we reviewed the inventory and interviewed key DTRA and 

contractor staff who worked with this information. We found major 

discrepancies, including duplications resulting in multiple counts of the 

same sources and evidence of incomplete data. Therefore, we did not 

use this data in our report.

2. We assessed the reliability of a May 2004 inventory of sources collected 

in Iraq that DTRA had created before the removal mission, and we 

determined that, for the purposes of this report, the inventory was not 

sufficiently reliable to ascertain the number and types of sources, but 

the inventory was reliable enough to identify the general locations of 

places where sources were found. To assess this data, we obtained 

responses to questions regarding data reliability by interviewing key 

DTRA and contractor staff who worked with this information. We also 

corroborated the data whenever possible with DOE experts and DOE’s 

inventories of collected sources taken to the United States and those 

left in Iraq. DTRA’s contractor staff told us they were unable to open 

some containers and counted each of them as one source. However, 

when DOE experts opened these containers, they found that some 

containers held multiple sources, increasing the count of sources from 

about 700 sources to about 1,400 sources. Also in the DTRA inventory, 

the type of radiological material was misidentified for some sources, 

according to DOE experts and documents. Therefore, we reported the 

number of sources based on DOE’s work. 

3. We assessed the reliability of DOE’s inventory of the approximately 

1,000 sources collected in Iraq and taken to the United States, and 

determined that these data were sufficiently reliable for the purposes of 

this report. To assess this data, we obtained responses to questions 

regarding data reliability by interviewing key DOE experts who worked 

with this information. We were told that the number of sources taken to 

the United States may be a close approximation, due to some instances 

where DOE experts relied on counts by DTRA, and therefore we 

reported them approximately. 
Appendix I

Scope and Methodology

Page 39 GAO-05-672 Securing Iraqi Radiological Sources

4. We assessed the reliability of a DOE inventory of the approximately 400 

sources collected in Iraq and remaining in Iraqi custody, and 

determined that these data were sufficiently reliable for the purposes of 

this report. To assess this data, we obtained responses to questions 

regarding data reliability by interviewing key DOE experts who worked 

with this information. They told us that the number is a close 

approximation, and therefore we reported it approximately. 

5. We assessed the reliability of a DTRA inventory of the approximately 

700 sources determined to be secured and in use in Iraq, and 

determined that these data were sufficiently reliable for the purposes of 

this report. To assess this data, we obtained responses to questions 

regarding data reliability by interviewing key DTRA and contractor 

staff who worked with this information. DTRA’s contractor staff told us 

they did not open the devices that contained sources and, therefore, 

depended on the labeling and documentation of the devices, if 

available, to record information about their number, type, and 

radioactive strength. The inventory assumed that there was one source 

per device, but contractor staff told us that some of these devices may 

have had multiple sources, and therefore we reported them 

approximately.

To report the radioactivity of sources collected in Iraq and taken to the 

United States or remaining in Iraq, we depended on information provided 

to us in a DOE summary of the sources removed from Iraq, and determined 

that these data were sufficiently reliable for the purposes of this report. We 

discussed this data with DOE experts who worked with this information. 

They told us that the radioactivity of the sources taken from Iraq was 

accurate to within 10 percent to 20 percent of the total reported, and we 

therefore reported the total approximately. They also told us that the 

radioactivity of the collected sources remaining in Iraq was somewhat 

more accurate because these less-radioactive sources could be handled 

and measured individually, but that the total was an approximation. 

Therefore, we reported the total approximately. 

To present information on the missions performed to collect and remove 

radiological sources, we examined the available contractor reports on the 

approximately 140 missions to find and collect sources in Iraq, as well as 

contractor reports on the mission to remove sources from Iraq. We 

interviewed DTRA officers and staff and DOE experts who accompanied 

these missions. We also interviewed contractor staff who performed this 

mission and the contractor’s project manager for the mission in Iraq. 
Appendix I

Scope and Methodology

Page 40 GAO-05-672 Securing Iraqi Radiological Sources

For our third objective, to describe U.S. efforts to help the new Iraqi 

government regulate sources, we examined Department of State planning 

documents and a Coalition Provisional Authority order to establish an Iraqi 

agency to regulate radiological sources. We discussed assistance, as well as 

uncertainties and challenges for assisting Iraq, with officials from State and 

DOE. In addition, we discussed DTRA’s actions to support State’s effort to 

assist Iraq with DTRA officials. We also discussed efforts to secure 

radiological sources with the Chairman of the Iraqi Radiological Source 

Regulatory Authority during his visit to Washington, D.C., in March 2005; at 

the same meeting, we discussed efforts to search for unsecured sources 

with an Iraqi program director from the Ministry of Science and 

Technology. We interviewed State and DOE officials about their current 

and intended contributions to the action plan drafted in December 2004 

and further discussed in March 2005 meetings. 

For our fourth objective, to describe what DOD and DOE have done to 

learn from their experience in Iraq, and how such lessons might be applied 

in the future, we interviewed DOD and DOE officials about their efforts to 

document lessons learned. We also reviewed a February 2004 National 

Defense University study of lessons learned from the mission to eliminate 

weapons of mass destruction (WMD), and discussed the study with its 

author. We discussed DOD’s work to assess its capability to interdict and 

eliminate WMD materials, including radiological sources, and reviewed the 

DOD memorandum initiating this effort, and held discussions with DOD 

planning officials. We also examined DOE’s preliminary analysis of lessons 

learned with DOE officials and interviewed the DOE expert who prepared 

it. 

Because of the continuing hostilities, we did not travel to Iraq. We 

performed our work from May 2004 through August 2005 in accordance 

with generally accepted government auditing standards. 
Page 41 GAO-05-672 Securing Iraqi Radiological Sources

Appendix II

The National Defense University Study ApendxiI

The Center for the Study of Weapons of Mass Destruction (WMD Center) at 

the National Defense University (NDU) has developed lessons and 

recommendations for WMD elimination operations, as the result of the 

Department of Defense’s (DOD) request for this study in late 2002. The 

WMD Center conducted meetings with DOD and interagency personnel to 

discuss elimination operations, and also examined prewar planning and its 

execution in Iraq. In February 2004, the WMD Center hosted a conference 

with those who had been engaged in the elimination mission in Iraq to 

identify lessons learned and ways to institutionalize WMD elimination 

capacity for the future. Major findings and key recommendations from the 

study were subsequently published in an NDU report.1

The NDU report suggests three wrong lessons from the Iraq experience 

that should be avoided to arrive at the correct lessons. A first wrong lesson 

is that Iraq is a rare situation. According to the report, since most of the 

United States’ potential adversaries have actual or suspected WMD 

capabilities and terrorists appear committed to acquiring WMD from weak, 

poor, or failed states, the U.S. military will likely confront WMD elimination 

missions as often as it engages in war. A second wrong lesson is that the 

failure of intelligence on WMD explains all of the failures of the WMD 

elimination mission. While faulty intelligence contributed to problems, the 

Iraq experience revealed substantial problems with DOD’s ability to 

eliminate WMD, including problems in planning, training and exercises, 

capabilities, and resources. A third wrong lesson is that elimination should 

not be a DOD mission, but rather should mostly be done by civilian or 

international organizations with the proper expertise after the military 

minimally secures WMD sites. Instead, the Iraq experience suggests that 

the U.S. military must quickly attend to finding, securing, and disposing of 

WMD to prevent the loss of information about WMD programs and the 

potential dispersal of WMD occurring in the chaos following an invasion.

Even though WMD was not found, the report suggests that the Iraq 

experience reveals that major improvements must be made if the United 

States is to succeed in a possible future WMD elimination mission. For 

example, according to the study, DOD had not sufficiently planned and 

prepared for the mission to locate, secure, and dispose of WMD, in part, 

because DOD only began to rapidly plan for operations and develop 

1

Rebecca K.C. Hersman, “Eliminating Adversary Weapons of Mass Destruction: What’s at 

Stake?” (occasional paper, National Defense University Press, Washington, D.C., December 

2004).
Appendix II

The National Defense University Study

Page 42 GAO-05-672 Securing Iraqi Radiological Sources

capacities for the elimination mission in late 2002. Before the end of major 

combat operations, the study observed that the teams searching for WMD 

experienced important operational problems. One key problem was that 

operations had to be adjusted because existing intelligence was directing 

teams to suspected sites that proved to have little evidence of WMD 

activity. Operations thus shifted from the expected focus on WMD to a 

more geographically dispersed investigation of potential WMD sites. 

Operations also shifted toward gathering information about WMD 

programs, but most teams lacked sufficient training and expertise for 

retrieving important information contained in documents and computers as 

well as for interviewing Iraqis who might be knowledgeable about WMD 

programs. Further, the organization responsible for searching for WMD 

was dependent on other military commands for capabilities such as 

transportation, logistics, communications, linguists, and security. When 

these other military commands experienced competing priorities for these 

capabilities, shortfalls for these capabilities occurred and the search for 

WMD was delayed. Additionally, the extensive looting, public disorder, and 

uncertain security environment made the search for WMD complex, 

resource intensive, and dangerous.

Based on the Iraq experience, the NDU report recommended that DOD 

develop and maintain the capability to quickly eliminate WMD in hostile 

environments. More specifically, the report included eight key 

recommendations: (1) DOD should institutionalize the WMD elimination 

mission, embedding it into the planning and budget process along with 

other tasks undertaken in combat operations. (2) To have a clear 

organization responsibility, DOD should create a standing military 

organization that is ready to perform the WMD elimination mission, 

including in a combat situation. Although this organization should be 

military, it should develop strong links with interagency and international 

partners, civilian experts, and the private sector. (3) DOD should be 

prepared to conduct this mission in an inhospitable environment and as 

quickly as possibly—concurrently with major combat operations, if 

necessary. (4) Elimination planning must assume imperfect intelligence on 

WMD, operations should be prepared to respond to emerging intelligence, 

and intelligence sharing must be improved. (5) To test plans as well as 

identify and address problems with procedures, the organization with 

WMD elimination responsibility should conduct training and exercises. (6) 

Rather than focusing on WMD sites, as initially occurred in Iraq, future 

elimination missions should target WMD programs, using a balanced 

examination of WMD sites, people, and documentation. (7) DOD should 

seek technical innovations to improve the efficiency, speed, and overall 
Appendix II

The National Defense University Study

Page 43 GAO-05-672 Securing Iraqi Radiological Sources

effectiveness of elimination operations. The objective is to reduce the 

needed manpower because it is in extreme demand before, during, and 

after a war, as shown in Iraq, and to address technical issues in Iraq 

operations, such as false readings on chemical detectors and electronic 

communication limitations. (8) Finally, senior-level government advocates 

are necessary to ensure adequate and sustained funding and prioritization 

to develop a significant WMD elimination capacity.
Page 44 GAO-05-672 Securing Iraqi Radiological Sources

Appendix III

Comments from the Department of Defense ApendxiI
Appendix III

Comments from the Department of Defense

Page 45 GAO-05-672 Securing Iraqi Radiological Sources

Now on p. 32.

Now on pp. 32-33.
Appendix III

Comments from the Department of Defense

Page 46 GAO-05-672 Securing Iraqi Radiological Sources

Now on p. 33.

Now on p. 33.

Now on p. 33.

Now on p. 33.

Now on p. 33.
Appendix III

Comments from the Department of Defense

Page 47 GAO-05-672 Securing Iraqi Radiological Sources

Now on p. 33.
Page 48 GAO-05-672 Securing Iraqi Radiological Sources

Appendix IV

Comments from the Department of State ApendxiIV
Appendix IV

Comments from the Department of State

Page 49 GAO-05-672 Securing Iraqi Radiological Sources

Now on Highlights and on

pp. 5 and 28.

Now on p. 28.

Now on para. 3, p. 12.
Appendix IV

Comments from the Department of State

Page 50 GAO-05-672 Securing Iraqi Radiological Sources
Page 51 GAO-05-672 Securing Iraqi Radiological Sources

Appendix V

GAO Contact and Staff Acknowledgments ApendxiV

GAO Contact Gene Aloise, (202) 512-3841

Staff 

Acknowledgments

In addition to the contact named above, Lee Carroll, Nancy Crothers,

Davi M. D’Agostino, Dan Feehan, Peter Grana, Terry Hanford, Dave Maurer, 

Judy Pagano, and Keith Rhodes (GAO’s Chief Technologist) made key 

contributions to this report.

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