United States Government Accountability Office

Washington, DC 20548 

April 10, 2006 

ERRATA 

Border Security: Investigators Successfully Transported Radioactive Sources 

Across Our Nation’s Borders at Selected Locations (GAO 06-545R, March 28, 2006). 

GAO reposted the Web version of this report on April 10, 2006, to reflect changes in 

the text on pages 2 and 8. The original version of the report, posted on March 28, 

implied that officials from the National Institute of Standards and Technology 

selected the amount of radioactive sources we used in our border testing. The 

reposted version clarifies that GAO determined the amount of radioactive sources 

used in the tests after consulting with an outside expert. 

Gregory D. Kutz 

Managing Director 

Forensic Audits and Special Investigations 
GAO-06-545R Border Security Tests 

United States Government Accountability Office

Washington, DC 20548 

March 28, 2006 

The Honorable Norm Coleman 

Chairman 

Permanent Subcommittee on Investigations 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

Dear Mr. Chairman: 

Subject: Border Security: Investigators Successfully Transported Radioactive 

Sources Across Our Nation’s Borders at Selected Locations 

This report responds to your request that we investigate potential security 

weaknesses related to the installation of radiation detection equipment at U.S. ports 

of entry. Based on discussions with your staff, we focused our efforts on testing 

whether the radiation portal monitors installed at the U.S. ports of entry would detect 

radioactive material transported in vehicles attempting to enter the United States. We 

also agreed to provide our observations regarding the procedures that Department of 

Homeland Security U.S. Customs and Border Protection (CBP) inspectors followed 

when the radiation portal monitors detected such material. 

We have reported on the security of our nation’s northern border in terms of 

detection of illegal transport of radioactive material into the United States in our 

previous work. 

Scope and Methodology 

We selected two land ports of entry that had radiation portal monitors installed: one 

at the U.S.-Canadian border and one at the U.S.-Mexican border. Radiation portal 

monitors are large pieces of stationary equipment that CBP uses as part of its overall 

strategy to thwart radiological terrorism by detecting the presence of radioactive 

materials by screening people, vehicles, and cargo as they pass through ports of 

entry. In order to safely plan and execute our undercover operation, several of our 

investigators attended training at the National Institute of Standards and Technology 

(NIST) in Gaithersburg, Maryland. Our investigators received training on the safe 

handling, storage, and transport of radioactive materials. 
 

When considering the type of radioactive sources to use in our undercover operation, 

we decided to use one of the most common radioisotopes used in industry for its 

strong radioactivity. After consulting with an outside expert, we used an amount of 

radioactive sources that we determined was sufficient to manufacture a dirty bomb.1

 

As part of our investigation, we purchased a small quantity of the radioactive sources 

from a commercial source by posing as an employee of a fictitious company. This 

was to demonstrate that anyone can purchase small quantities of radioactive sources 

for stockpiling because suppliers are not required to exercise any due diligence in 

determining whether the buyer has a legitimate use for the radioactive sources and 

suppliers are not required to ask the buyer to produce a Nuclear Regulatory 

Commission (NRC) document when making purchases in small quantities. We then 

deployed two teams of investigators to the field to make simultaneous border 

crossings at the northern and southern borders in an attempt to transport radioactive 

sources into the United States. 

While making our simultaneous crossings, we focused our investigation on whether 

the radiation portal monitors would detect the radioactive sources we carried and 

whether CBP inspectors exercised due diligence to determine the authenticity of 

paperwork presented by individuals attempting to transport radioactive sources 

across our borders. Although we offer observations on the procedures that CBP 

inspectors followed for our two border crossings, we did not evaluate the adequacy 

of the design or effectiveness of those procedures. Our investigation also tested 

whether an NRC document could be counterfeited using data easily accessible and 

available to the public. We conducted our investigation from July 2005 through 

December 2005 in accordance with quality standards for investigations as set forth by 

the President’s Council on Integrity and Efficiency. 

Summary of Investigation 

For the purposes of this undercover investigation, we purchased a small amount of 

radioactive sources and one container used to store and transport the material from a 

commercial source over the telephone. One of our investigators, posing as an 

employee of a fictitious company located in Washington, D.C., stated that the purpose 

of his purchase was to use the radioactive sources to calibrate personal radiation 

detection pagers. The purchase was not challenged because suppliers are not 

required to determine whether buyers have legitimate uses for the radioactive 

sources, nor are suppliers required to ask the buyer to produce an NRC document 

when making purchases in small quantities. 

 1

According to the Centers for Disease Control and Prevention, a dirty bomb is a mix of explosives, 

such as dynamite, with radioactive powder or pellets. When the dynamite or other explosives are set 

off, the blast carries radioactive material into the surrounding area. 

Page 2 GAO-06-545R Border Security Tests 
The radiation portal monitors properly signaled the presence of radioactive material 

when our two teams of investigators conducted simultaneous border crossings. Our 

investigators’ vehicles were inspected in accordance with most of the CBP policy at 

both the northern and southern borders. However, our investigators were able to 

enter the United States with enough radioactive sources to make two dirty bombs 

using counterfeit documents. Specifically, they were able to successfully represent 

themselves as employees of a fictitious company and present a counterfeit bill of 

lading and a counterfeit NRC document during the secondary inspections at both 

locations. The CBP inspectors never questioned the authenticity of the investigators’ 

counterfeit bill of lading or the counterfeit NRC document authorizing them to 

receive, acquire, possess, and transfer radioactive sources. 

Background 

A dirty bomb, or a radiological dispersal device, combines a conventional explosive 

with radioactive material. In most cases, the conventional explosive would have 

more immediate lethality than the radioactive material. A dirty bomb would most 

likely result in small radiation exposures and would typically not contain enough 

radiation to kill people or cause severe illnesses. However, by scattering the 

radioactive material, the dirty bomb has the effect of contaminating an area. The 

extent of local contamination depends on several factors, including the size of the 

explosive, the amount and type of radioactive material used, and weather conditions. 

While there could be an increase in the cancer risk among those exposed to radiation 

from a dirty bomb, the more significant effect of a dirty bomb could be the closing of 

contaminated areas. The direct costs of cleanup and the indirect losses in trade and 

business in the contaminated areas could be large. Hence, dirty bombs are generally 

considered to be weapons of mass disruption instead of weapons of mass 

destruction.

Many radioactive materials are used in a variety of industrial, scientific, and medical 

applications. For instance, radioactive materials are used in smoke detectors and for 

cancer treatments. However, few of the materials are considered suitable for use in a 

dirty bomb. A Department of Energy and Nuclear Regulatory Commission 

Interagency Working Group identified radioactive materials of highest concern based 

on the potential dose impacts of the materials and the availability of such materials in 

sufficient quantities.2

 

To address the threat of dirty bombs and other nuclear material, the federal 

government has programs in place that regulate the transportation of radioactive 

material and to prevent illegal transport of radioactive material across our nation’s 

borders. CBP uses radiation detection equipment at ports of entry to prevent the 

illicit transport of radioactive material into the United States. The goal of CBP’s 

inspection program is to “...thwart the operations of terrorist organizations by 

 2

 Department of Energy/Nuclear Regulatory Commission Interagency Working Group on Radiological 

Dispersion Devices. Radiological Dispersal Devices: An Initial Study to Identify Radioactive 

Materials of Greatest Concern and Approaches to Their Tracking, Tagging, and Disposition, Report 

to the Nuclear Regulatory Commission and the Secretary of Energy (May 2003).

Page 3 GAO-06-545R Border Security Tests 
detecting, disrupting, and preventing the cross-border travel of terrorists, terrorist 

funding, and terrorist implements, including Weapons of Mass Destruction and their 

precursors.” Deploying radiation detection equipment is part of CBP’s strategy for 

thwarting radiological terrorism and CBP is using a range of such equipment to meet 

its goal of screening all cargo, vehicles, and individuals coming into the United States. 

Most travelers enter the United States through the nation’s 154 land border ports of 

entry. CBP inspectors at ports of entry are responsible for the primary inspection of 

travelers to determine their admissibility into the United States and to enforce laws 

related to preventing the entry of contraband, such as drugs and weapons of mass 

destruction.

Radiation Detection Devices

To help detect the presence of radiation and identify the type of radiation present, 

CBP generally relies on three types of radiation detection devices – radiation portal 

monitors, Personal Radiation Detectors (PRDs), and Radiation Isotope Identifier 

Devices (RIIDs). Radiation portal monitors have the ability to detect the presence of 

gamma radiation, which is emitted by all radioactive materials of greatest concern,3

and neutrons, which are emitted by only a limited number of materials, including 

plutonium. CBP uses PRDs that detect the presence of gamma radiation but not 

neutrons. CBP requires its inspectors to wear PRDs while on duty and ensure that 

the PRDs are activated. PRDs alert inspectors to the presence of harmful levels of 

radiation when they are conducting cargo and vehicle searches. PRDs can detect 

radioactive materials that could be used in a radiological dispersal device, also

known as a dirty bomb. Another type of radiation detection equipment that CBP uses 

are RIIDs, which are handheld devices designed to determine the identity of the 

radioactive material, whether it is a radiological source used in medicine or industry, 

a naturally occurring source of radiation, or weapons-usable nuclear material. 

Radiation Detection Alerts

For the purposes of this report, we focused only on the procedures for gamma 

radiation, the type of radiation used in our tests. To identify the type of radiation 

present, inspectors use a handheld RIID. If the radiation portal monitor and the RIID 

do not detect the presence of neutrons, inspectors follow gamma radiation 

procedures, which require that they first use their PRDs to determine the safe 

distance at which to conduct an inspection. 

If, after reviewing documentation or obtaining advice from Laboratories and 

Scientific Services personnel, the CBP inspectors are satisfied that the radioactive 

source is properly documented or is consistent with innocent radiation sources, the 

vehicle and passengers can be released. If CBP inspectors are not satisfied that the 

 3

 Radioactive materials of greatest concern are those materials that could be used in a nuclear weapon 

such as plutonium and highly enriched uranium. 

Page 4 GAO-06-545R Border Security Tests 
source is documented or innocent, they must obtain guidance from the Laboratory 

and Scientific Services. 

Documentation Was Produced to Support Undercover Investigation 

As part of our undercover investigation, we produced counterfeit documents before 

sending our two teams of investigators out to the field. We found two NRC 

documents and a few examples of the documents by searching the Internet.4

 We 

subsequently used commercial, off-the-shelf computer software to produce two 

counterfeit NRC documents authorizing the individual to receive, acquire, possess, 

and transfer radioactive sources. 

To support our investigators’ purported reason for having radioactive sources in their 

possession when making their simultaneous border crossings, a GAO graphic artist 

designed a logo for our fictitious company and produced a bill of lading using 

computer software. 

With Ease, Investigators Purchased, Received, and Transported Radioactive 

Sources across Both Borders 

Our two teams of investigators each transported an amount of radioactive sources 

sufficient to manufacture a dirty bomb when making their recent, simultaneous 

border crossings. In our earlier work, we had purchased radioactive sources, two 

containers to store and transport the material, and we had obtained a genuine NRC 

document. 

For the purposes of our current undercover investigation, we purchased a small 

amount of radioactive sources and one container for storing and transporting the 

material from a commercial source over the telephone. One of our investigators, 

posing as an employee of a fictitious company, stated that the purpose of his 

purchase was to use the radioactive sources to calibrate personal radiation detectors. 

According to the NRC, suppliers are not required to determine whether the buyer has 

a legitimate use for the radioactive sources, nor are suppliers required to ask the 

buyer to produce an NRC document when making purchases in small quantities. The 

amount of radioactive sources our investigator sought to purchase did not require an 

NRC document. The company mailed the radioactive sources to an address in 

Washington, D.C. We could have purchased all of the radioactive sources used in our 

two undercover border crossings by making multiple purchases from different 

suppliers, using similarly convincing cover stories, using false identities, and had all 

of the radioactive sources conveniently shipped to our nation’s capital. 

 4

 None of these documents were available on NRC’s Web site. 

Page 5 GAO-06-545R Border Security Tests 
We have pointed out the weaknesses in federal and state controls over the security5

of sealed sources in our prior work,6

 noting that it is possible that these materials can 

be obtained for malicious intent. Sealed radioactive sources, radioactive material 

encapsulated in stainless steel or other metal, are used worldwide in medicine, 

industry, and research. We recommended in August 2003 that NRC modify its 

process of issuing specific licenses to ensure that sealed sources cannot be 

purchased before NRC’s verification – through inspection or other means – that the 

materials will be used as intended. NRC has not implemented our licensing 

recommendation to date, more than 2 years later. However, NRC has recently 

established an interagency task force to evaluate the licensing, use, and security of 

radioactive materials. Further delays in implementing our licensing recommendation, 

given today’s security environment, continues to leave NRC’s licensing process 

vulnerable to compromise and inadequate in terms of precluding the smuggling of 

radioactive material across our nation’s borders. 

Two Teams of Investigators Conducted Simultaneous Crossings at the U.S.-

Canadian Border and U.S.-Mexican Border 

Northern Border Crossing 

On December 14, 2005, our investigators placed two containers of radioactive sources 

into the trunk of their rental vehicle. Our investigators – acting in an undercover 

capacity -- drove to an official port of entry between Canada and the United States. 

They also had in their possession a counterfeit bill of lading in the name of a fictitious 

company and a counterfeit NRC document. 

At the primary checkpoint, our investigators were signaled to drive through the 

radiation portal monitors and to meet the CBP inspector at the booth for their 

primary inspection. As our investigators drove past the radiation portal monitors and 

approached the primary checkpoint booth, they observed the CBP inspector look 

down and reach to his right side of his booth. Our investigators assumed that the 

radiation portal monitors had activated and signaled the presence of radioactive 

sources. The CBP inspector asked our investigators for identification and asked 

them where they lived. One of our investigators on the two-man undercover team 

handed the CBP inspector both of their passports and told him that he lived in 

Maryland while the second investigator told the CBP inspector that he lived in 

Virginia. 

The CBP inspector also asked our investigators to identify what they were 

transporting in their vehicle. One of our investigators told the CBP inspector that 

they were transporting specialized equipment back to the United States. A second 

CBP inspector, who had come over to assist the first inspector, asked what else our 

 5

 As used in this report, “security” refers to measures to prevent unauthorized access to, loss, and/or 

theft of sealed sources, or radioactive materials used for medical and industrial purposes. See GAO, 

Nuclear Security: Federal and State Action Needed to Improve Security of Sealed Radioactive 

Sources, GAO-03-804 (Washington, D.C.: August 6, 2003). 

6

 GAO-03-804.

Page 6 GAO-06-545R Border Security Tests 
investigators were transporting. One of our investigators told the CBP inspectors 

that they were transporting radioactive sources for the specialized equipment. The 

CBP inspector in the primary checkpoint booth appeared to be writing down the 

information. Our investigators were then directed to park in a secondary inspection 

zone, while the CBP inspector conducted further inspections of the vehicle. 

During the secondary inspection, our investigators told the CBP inspector that they 

had an NRC document and a bill of lading for the radioactive sources. The CBP 

inspector asked if he could make copies of our investigators’ counterfeit bill of lading 

on letterhead stationery as well as their counterfeit NRC document. Although the 

CBP inspector took the documents to the copier, our investigators did not observe 

him retrieving any copies from the copier. 

Our investigators watched the CBP inspector use a RIID, which he said is used to 

identify the source of radioactive material, to examine the investigators’ vehicle. He 

used the RIID to identify the source of radiation emanating from the investigators’ 

vehicle. He told our investigators that he had to perform additional inspections. 

After determining that the investigators were not transporting additional sources of 

radiation, the CBP inspector made copies of our investigators’ drivers’ licenses, 

returned their drivers’ licenses to them, and our investigators were then allowed to 

enter the United States. At no time did the CBP inspector question the validity of the 

counterfeit bill of lading or the counterfeit NRC document. 

Southern Border Crossing 

On December 14, 2005, our investigators placed two containers of radioactive sources 

into the trunk of their vehicle. Our investigators drove to an official port of entry at 

the southern border. They also had in their possession a counterfeit bill of lading in 

the name of a fictitious company and a counterfeit NRC document. 

At the primary checkpoint, our two-person undercover team was signaled to drive 

through the radiation portal monitors through the use of a traffic light signal and 

stopped at the primary checkpoint for their primary inspection. As our investigators 

drove past the portal monitors and approached the primary checkpoint, they 

observed that the CBP inspector remained in the primary checkpoint for several 

moments prior to approaching our investigators’ vehicle. Our investigators assumed 

that the radiation portal monitors had activated and signaled the presence of 

radioactive sources. 

The CBP inspector asked our investigators for identification and asked them if they 

were American citizens. Our investigators told the CBP inspector that they were both 

American citizens and handed him their state issued driver’s licenses. The CBP 

inspector also asked our investigators about the purpose of their trip to Mexico and 

asked whether they were bringing anything into the United States from Mexico. Our 

investigators told the CBP inspector that they were returning from a business trip in 

Mexico and were not bringing anything into the United States from Mexico. 

While our investigators remained inside their vehicle, the CBP inspector used what 

appeared to be a RIID to scan the outside of the vehicle. One of our investigators told 

Page 7 GAO-06-545R Border Security Tests 
him that they were transporting specialized equipment. The CBP inspector asked one 

of our investigators to open the trunk of the rental vehicle and to show him the 

specialized equipment. Our investigator told the CBP inspector that they were 

transporting radioactive sources in addition to the specialized equipment. The 

primary CBP inspector then directed our investigators to park in a secondary 

inspection zone for further inspection. 

During the secondary inspection, the CBP inspector said he needed to verify the type 

of material our investigators were transporting, and another CBP inspector 

approached with what appeared to be a RIID to scan the cardboard boxes where the 

radioactive sources was placed. The instrumentation confirmed the presence of 

radioactive sources. 

When asked again about the purpose of their visit to Mexico, one of our investigators 

told the CBP inspector that they had used the radioactive sources in a demonstration 

designed to secure additional business for their company. The CBP inspector asked 

for paperwork authorizing them to transport the equipment to Mexico. One of our 

investigators provided the counterfeit bill of lading on letterhead stationery, as well 

as their counterfeit NRC document. The CBP inspector took the paperwork provided 

by our investigators and walked into the CBP station. He returned several minutes 

later and returned the paperwork. At no time did the CBP inspector question the 

validity of the counterfeit bill of lading or the counterfeit NRC document. 

Corrective Action Briefings 

We conducted corrective action briefings with CBP officials and NRC officials shortly 

after completing our undercover operations. On December 21, 2005, we briefed CBP 

officials about the results of our border crossing tests. CBP officials agreed to work 

with the NRC and CBP’s Laboratories and Scientific Services to come up with a way 

to verify the authenticity of NRC materials documents. 

We conducted two corrective action briefings with NRC officials on January 12 and 

January 24, 2006, about the results of our border crossing tests. NRC officials 

disagreed with the amount of radioactive material we determined was needed to 

produce a dirty bomb, noting that NRC’s “concern threshold” is significantly higher. 

We continue to believe that our purchase of radioactive sources and our ability to 

counterfeit an NRC document are matters that NRC should address. Further, we 

believe that the amount of radioactive sources that we were able to transport into the 

United States during our operation would be sufficient to produce two dirty bombs, 

which could be used as weapons of mass disruption. Finally, NRC officials told us 

that they are aware of the potential problems of counterfeiting documents and that 

they are working to resolve these issues. 

As agreed with your office, unless you announce the contents of this report earlier, 

we will not distribute it until 30 days after its issuance date. At that time, we will 

send it to the appropriate congressional committees. We will also provide copies to 

the Department of Homeland Security and the Nuclear Regulatory Commission. If 

you or your staff have any questions regarding this report, please contact me at (202) 

512-7455 (kutzg@gao.gov). Contact points for our Offices of Congressional Relations 

Page 8 GAO-06-545R Border Security Tests 
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 enclosure I. 

Sincerely yours, 

Gregory D. Kutz 

Managing Director 

Forensic Audits 

 and Special Investigations 

Keith A. Rhodes 

Chief Technologist 

Center for Technology 

 and Engineering 

Gene Aloise 

Director 

Natural Resources 

 And Environment 

Enclosure -- 1 

Enclosure I 

Page 9 GAO-06-545R Border Security Tests 
GAO Contact and Staff Acknowledgments 

GAO Contact Gregory D. Kutz (202) 512-7455 

Acknowledgments In addition to the individual named above, Andrew 

O’Connell, Richard Egan, John Cooney, Paul Desaulniers, 

Christine Hodakievic, George Ogilvie, Rich Hung, Jim 

Shafer, Stockton Butler, Kord Basnight, and Renee 

McElveen made key contributions to this report. 

 

(192203) 

Page 10 GAO-06-545R Border Security Tests 
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