Department of Homeland Security
 

United States Customs and Border Protection’s 


Radiation Portal Monitors at Seaports 


OIG-13-26 January 2013
 
OFFICE 0.1" INSPECrOR GENERAL 

JAN 2 9 Z013 

MEMORANDUM FOR: Kevin K. McAleenan 

Acting Assistant Commissioner 

Office of Field Operations 

U.S. Customs and Border Protection 

Steve Karoly 

Assistant Director 

Product Acquisition and Deployment 

Domestic Nuclear Detection Office 

/.1_ .• ...!/ " ~ FROM: Anne L. Richards ~"'~~ 

Assistant Inspector General for Audits 

SUBJECT: United States Customs and Border Protection's Radiation 

Portal Monitors at Sl!aports 

Attached for your action is our final report, United States Customs and Border 

Protection's Radiation Portal Monitors at Seaports. We incorporated the formal 

comments from the United States Customs and Border Protection and the Domestic 

Nuclear Detection Office in the final report. 

The report contains three recommendations aimed at improving the overall 

effectiveness of the radiation portal monitoring program at seaports. Your offices 

concurred with all recommendations. Based on information provided in your response 

to the draft report, we consider the recommendations resolved. Once your office has 

fully implemented the recommendations, please submit a formal closeout letter to uS 

within 30 days so that we may close the recommendations. The memorandum should 

be accompanied by evidence of completion of agreed-upon corrective actions and of 

the disposition of allY monetary amoullts. 

Consistent with our responsibility ullder the Inspector Generol Art, we are providillg 

copies of our report to appropriate ~Ollgressional committees with oversight and 

appropriation responsibility ove r the Departmellt of Homeland Security. We will post 

the report all our website for public dissemination. 

Please call me with ally questiolls, or your staff may contact Mark Bell, Deputy Assistant 

Inspector General for Audits, at {lOl) 154-4100 

Attachmellt 
Table of Contents 

Executive Summary............................................................................................................. 1 

Background ........................................................................................................................ 2 

Results of Audit .................................................................................................................. 4 

RPM Screening at Seaports .................................................................................... 5 

Recommendations ............................................................................................... 10 

Management Comments and OIG Analysis ......................................................... 10 

Appendixes 

Appendix A: Objectives, Scope, and Methodology ........................................... 13 

Appendix B: Management Comments to the Draft Report .............................. 15 

Appendix C: CBP Process for Resolving RPM Alarms ........................................ 19 

Appendix D: Response to Congressional Mandate to Assess Training ............. 20 

Appendix E: RPM Reconfiguration Process ...................................................... 22 

Appendix F: RPM Program Planning ................................................................ 23 

Appendix G: Major Contributors to This Report ............................................... 24 

Appendix H: Report Distribution ....................................................................... 25 

Abbreviations

CBP United States Customs and Border Protection 

DHS Department of Homeland Security 

DNDO Domestic Nuclear Detection Office 

FY fiscal year 

OIG Office of Inspector General 

PEP Project Execution Plan (2006) 

PNNL Pacific Northwest National Laboratory 

RPM radiation portal monitor 

SAFE Port Act SecurityfandfAccountabilityfforfEveryfPortfActfoff2006

U.S. United States 

 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

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Executive Summary

According to the SecurityfandfAccountabilityfforfEveryfPortfActfoff2006, as amended, all 

containers entering the United States (U.S.) at the 22 ports through which the greatest 

container volume enters the country by vessel must be screened for radiation. To 

secure the Nation’s borders while facilitating legitimate trade and travel, United States 

Customs and Border Protection (CBP) screens incoming shipments for elevated radiation 

levels, using large-scale radiation detectors called radiation portal monitors. In fiscal 

year 2011, CBP screened approximately 24.3 million containers coming through all U.S. 

ports of entry. The Domestic Nuclear Detection Office (DNDO) tests, acquires, deploys, 

and provides maintenance in the first year of operation; CBP provides maintenance 

after the first year. CBP has the lead for commissioning, operating, and maintaining the 

radiation portal monitors. We conducted this audit to determine whether DNDO and 

CBP deploy and use radiation portal monitors to ensure the most efficient cargo 

screening at seaports. Our audit also addressed the congressional mandate in the Coastf

GuardfandfMaritimefTransportationfActfoff2004, as amended, to conduct an annual 

evaluation of the cargo inspection system. 

DNDO reported that there are currently 444 radiation portal monitors operating at 

seaports throughout the U.S., which are meeting the requirement to screen all 

containerized cargo at the 22 seaports with the most container volume. We were 

unable to determine whether DNDO and CBP initially deployed radiation portal 

monitors to ensure operational efficiency because the components did not thoroughly

document deployment decisions and plans. Although all cargo is being screened, we 

identified some radiation portal monitors utilized infrequently or not utilized at all. 

The components do not fully coordinate or centrally manage the radiation portal 

monitor program to ensure effective and efficient operations. Specifically, CBP does not 

consistently gather and review utilization information to ensure that it is fully utilizing all 

radiation portal monitors. CBP does not always monitor and promptly evaluate changes 

in the screening environment at seaports to relocate radiation portal monitors as 

necessary. Finally, DNDO and CBP do not accurately track and monitor their inventory 

of radiation portal monitors. Given the radiation portal monitors’ limited life and the 

lack of funding for new monitors, CBP and DNDO should better coordinate to fully 

utilize, promptly relocate, and properly maintain inventory to best use resources and to 

continue screening of all containerized cargo entering U.S. seaports. The components 

concurred with our three recommendations and will identify a single program office 

responsible for fully coordinating and centrally managing the program; establish 

guidelines to track and report the utilization of monitors at every seaport; and develop 

and document a formal collaborative process to ensure that monitor relocation is 

effectively planned and implemented to meet security needs at seaports. 

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Background 

CBP is responsible for securing the Nation’s borders while facilitating legitimate trade 

and travel. According to the SecurityfandfAccountabilityfforfEveryfPortfActfoff2006f(SAFE 

Port Act), as amended, all containers entering the U.S. by vessel through the 22 seaports 

with the greatest container volume must be scanned, also referred to as screened, for 

radiation. In fiscal year (FY) 2011, CBP screened approximately 24.3 million containers 

through all ports of entry. Ports of entry are responsible for daily port-specific 

operations at locations such as seaports, land borders, mail facilities, and rail crossings. 

CBP uses a multilayered approach of risk-based analysis, intelligence, and high-risk 

shipment examination to manage potential security threats from the large volume of 

maritime cargo. The component screens shipments for elevated radiation levels using 

large-scale radiation detectors called radiation portal monitors (RPM). CBP has 

established protocols to isolate cargo and once detected, determine the level and type 

of radiation. 

The RPM detection system is a passive, nonintrusive means to screen vehicles and containers 

for the presence of nuclear and radiological 

materials. Vehicles and containers pass through 

RPM sensor panels positioned on opposite sides 

of seaport terminal exit lanes. Two panels, 

situated on each side, contain tubes filled with 

helium-3 and polyvinyl toluene plastic to detect 

radiation sources as containers pass through the 

system. Exhibit 1 shows RPM panels in an exit 

lane. 

In addition to radiation sensor panels, the RPM 

system includes other sensors to communicate 

alarms and system problems to CBP officers 

through indicator lights and audio messages. The 

system also includes ancillary components such as traffic lights, booths, and remote 

monitoring stations. The systems can detect various types of radiation emanating from 

nuclear devices, dirty bombs, special nuclear materials, natural sources, and isotopes 

commonly used in medicine and industry. 

Exhibit 1 – RPM System

RPM panels in an exit lane; two panels on 

each side screen containers for radiation 

as vehicles move slowly (5 mph) through. 

Source: DHS OIG 

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Several entities participate in the RPM program, including: 

•	 Department of Homeland Security (DHS) - DNDO tests, acquires, deploys RPMs, 

and provides maintenance during the first year of RPM operation. 

•	 Pacific Northwest National Laboratory (PNNL) - a contractor to DNDO that 

deploys and installs RPMs. 

•	 CBP has the lead for commissioning, operating, and maintaining the RPMs. 

•	 CBP officers at the ports of entry maintain custody of the RPM inventory onsite, 

operate RPMs, and resolve all radiation detection alarms. 

At each port of entry where equipment is deployed, the primary RPM screens a vehicle 

or container for radiation. CBP officers may release containers that do not set off 

alarms. Vehicles or containers that set off radiation detection alarms during the primary 

screening are sent to secondary screening. If the secondary screening continues to 

alarm, officers must determine if the radiation source is an actual threat. If required, 

CBP Laboratories and Scientific Services provide forensic and scientific analysis to assist 

officers in their determination. 

CBP officers must report the specific type of radiation detected during the secondary 

screening to a supervisor or secondary Inspection Officer. Using handheld radiation 

detection equipment, officers must isolate and locate the radiation source, establish a 

safety perimeter, identify the radiation source, and implement the appropriate radiation 

response procedures. Appendix C contains more information on the alarm resolution 

process. 

As of August 2012, DNDO and CBP reported that they had installed 1,459 RPMs at ports 

of entry nationwide, including 444 that were operational at seaports. Initially, DNDO 

and CBP deployed RPMs to fulfill the mandate to screen all incoming containerized 

cargo at the 22 highest container volume seaports in the U.S. At times, RPMs are 

removed or relocated because of changes in the flow of commerce initiated by 

commercial shipping companies or changes in the physical layout of seaports due to 

terminal expansions or closures. 

Since the inception of the RPM program, CBP reports screening more than 679 million 

transported containers for radiological contraband, resulting in more than 2.8 million 

radiation alarms. According to DNDO and CBP’s Project Execution Plan (PEP), 

approximately $623 million was spent on the RPM program between FY 2002 and 

FY 2011. 

Initial estimates of the deployed RPMs showed an average useful life expectancy of 

10 years. Based on the initial estimates, some RPM equipment will become obsolete by 

2014, with no useful RPMs at seaports by 2021. Subsequent studies have shown that 

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the service life can be increased with continued maintenance and improvements. 

However, DNDO has not yet funded or deployed technologies to increase the service life 

of current RPMs or decided on a new technology to replace them. In 2005, DNDO 

began to develop, test, and deploy advanced screening technology through its Advanced 

Spectroscopic Portal Program, but DHS cancelled the program in 2011 because of 

operational and technical challenges. DNDO created the Polyvinyl-Toluene 

Improvement Program intended to increase RPM service life and efficiency. One of 

seven studies created under this program focused on extending service life; the others 

focused on improving detection capabilities and providing a tool to monitor RPM panel 

status. These research and development studies have been funded since FY 2010, but 

implementation will not begin until FY 2014, with very limited funding. 

This audit responds to the congressional mandate in Section 809(g) of the CoastfGuardf

andfMaritimefTransportationfActfoff2004f(Public Law 108-293), as amended. This act 

requires the DHS Office of Inspector General (OIG) to conduct an annual evaluation of 

the cargo inspection system for international intermodal cargo containers. We 

reviewed the sources and quality of information used by the cargo inspection system to 

determine whether it is collected from the best and most credible sources, and we 

evaluated data sources to determine information gaps and weaknesses. We checked 

the system for reporting and analyzing inspection statistics, system operator 

competence and training, whether the system effectively detects potential acts of 

terrorism, and deficiencies that need to be remedied. Appendix A contains our 

objectives, scope, and methodology. Appendix D contains our assessment of operator 

training. 

Results of Audit 

DNDO reported that there are currently 444 RPMs screening all containerized cargo at 

the 22 seaports with the most container volume. We were unable to determine 

whether DNDO and CBP initially deployed RPMs to ensure operational efficiency 

because the components did not thoroughly document deployment decisions and plans. 

Although all cargo is being screened, we identified some RPMs utilized infrequently or 

not utilized at all. 

The components do not fully coordinate or centrally manage the RPM program to 

ensure effective and efficient operations. Specifically: 

•	 CBP does not consistently gather and review utilization information to ensure 

that it is fully utilizing all RPMs. 

•	 CBP does not always monitor and promptly evaluate changes in the screening 

environment at seaports to relocate RPMs as necessary. 

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 Department of Homeland Security 

• DNDO and CBP do not accurately track and monitor their inventory of RPMs. 

Given the RPMs’ limited life and the need for funding for new monitors, CBP and DNDO 

should better coordinate to fully utilize, promptly relocate, and properly maintain 

inventory to best use resources and to continue screening of all containerized cargo 

entering U.S. seaports. 

RPM Screening at Seaports 

According to DNDO, there are currently 444 RPMs screening 99 percent of 

inbound containerized cargo at seaports; the other 1 percent of incoming cargo 

enters the U.S. at low-volume seaports. 

Initial RPM Deployment 

We were unable to determine whether DNDO and CBP initially deployed RPMs 

to ensure operational efficiency because the components did not thoroughly 

document deployment decisions and plans. DNDO and CBP used the PEP to 

guide RPM deployment. The PEP was approved in 2006 and included the 

required scope of work, deployment schedules by location, and costs to deploy 

RPMs to ports of entry. However, the components could not provide complete 

information on the factors used to determine the number of RPMs to deploy at 

each location. Although CBP provided documentation to support initial 

deployment to screen all containerized cargo at the 22 seaports with the most 

container volume, it could not provide evidence to justify placement of RPMs at 

specific seaports. 

During our site visits to seven seaports, we identified RPMs that had been 

deployed but not used for several years. In addition to the 444 RPMs currently 

at seaports, 46 others have been removed since their initial deployment. 

According to CBP, some of these units are being relocated. CBP also plans to 

relocate 23 other RPM systems in the near future. 

Without documentation to support how CBP and DNDO made initial deployment 

decisions, we were unable to determine whether RPMs were unused or being 

removed because they were not properly deployed. It is not clear whether 

DNDO and CBP considered all critical factors needed for deployment. 

Monitoring RPM Utilization 

CBP does not consistently gather and review utilization information to ensure 

that it is fully utilizing all RPMs. CBP receives and reviews monthly utilization 

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reports; however, there was no indication that the reports were used to 

determine how RPMs are utilized or affect deployment decisions. For example, 

CBP’s Data Analysis Center provides the Office of Field Operations reports that 

include monthly primary and secondary screening totals for each seaport 

location and scan data for each RPM lane. The Data Analysis Center can also 

provide more detail for each seaport, such as utilization of each RPM lane. 

CBP established the Port Radiation Inspection Detection and Evaluation system 

to monitor and retrieve data; however, this system is not fully installed at all 

ports. This system connects the network of radiation detection equipment to 

the CBP network. It provides data monitoring and retrieval capabilities so that 

CBP can immediately assess and respond to radiological threats. Additionally, 

the system can be populated with commodity and shipper information by 

connecting to CBP’s system that targets cargo for screening. CBP officers enter 

alarm data into computers, such as information on the commodity, shipper, and 

the type of radiation identified. 

During our review of the monthly Data Analysis Center reports, we tested the 

data and identified that it was incomplete and would need attention if CBP were 

to rely on it. CBP’s policy and training guide provide a standard for 

completeness; however, the data is often incomplete. According to the Data 

Analysis Center, the entry of data is approximately 50 percent complete. 

Further, we identified 11 RPMs at multiple locations that did not have updated 

screening totals, even though the equipment was active at these locations. 

During our review of CBP data and site visits, we identified primary and 

secondary RPMs that were screening very few containers annually. Although 

CBP’s Office of Field Operations obtains a monthly report with screening totals 

by seaport, the office was unaware of an RPM that was rarely used for several 

years. Local CBP personnel at one port could not explain why some RPMs 

remained idle for years. During our site visits to the seven ports selected for 

review, we identified 24 of 185 RPMs infrequently used or not used at all. 

Specifically: 

• 19 of 185 RPMs or 10 percent were not being used. 

- Four of these RPMs at one terminal had not been used since 

February 2011. The RPMs remain inactive while they wait to be 

transferred to another nearby terminal. 

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- Three RPMs were not being used due to seaport reconfiguration 

in January 2011.1

- Two RPM systems had not been used since January 2011. 

•	 Five of 185 RPMs or 3 percent were 

rarely used and screened a minimal 

volume of the containers at the 

location. 

- Four RPMs had multiple tandem 

lanes that unnecessarily 

screened every shipment twice.2

Whether the container alarmed 

or not, it was screened by two 

RPM systems. Exhibit 2 shows 

an RPM set up in a tandem lane. 

Additionally, CBP does not always monitor and 

evaluate changes in the seaport screening environments to promptly relocate 

RPMs as necessary. CBP and DNDO have removed 46 RPMs since their initial 

deployment; however, we could not determine whether these changes resulted 

from insufficient planning for deployment or changes in screening environments. 

According to CBP, some of these units are in the process of being relocated to 

other ports. 

Although CBP and DNDO maintain joint deployment documents, they do not 

include guidance that would help ensure the agencies promptly relocate RPMs 

for operational efficiency. For example, the 2006 PEP, which guided the early 

RPM deployment decisions, does not include a detailed relocation process. The 

PEP does not contain information on the responsible entity or guidance to help 

ensure that RPMs are promptly relocated as seaport screening demands change. 

Instead, when CBP determines that it needs to change the RPM configuration at 

a seaport, CBP port officials submit a request to CBP Headquarters. DNDO 

approves some of these change requests, but others are handled internally by 

CBP. As a result, RPM systems can remain idle for extended periods of time. 

1

 Reconfiguration is the addition, deletion, and/or relocation of RPMs at a previously completed site to 

accommodate changes in a port, crossing terminal, gate, or facility reconfiguration; it may also include 

addition or moving of panels to accommodate updates to detection requirements or changes to cargo

being screened. 

2

 In a tandem lane, the secondary RPM is directly connected to the primary RPM; vehicles must pass 

through both, regardless of alarms. We observed exit gates with one tandem lane and others with 

multiple tandem lanes. 

Exhibit 2

RPM unit configured with tandem 

lanes. 

Source: DHS OIG 

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In addition, CBP does not formally document its process to ensure prompt 

resolution of required changes to RPM operations and locations. According to 

DNDO and CBP, they were to update the PEP to reflect these changes as 

necessary. Instead, approved Baseline Change Requests are recorded outside of 

the document in an Excel spreadsheet. CBP attempted to revise the Joint 

CBP/DNDO Deployment Strategy in 2008, but DNDO did not approve the 

document and could not provide a reason for this decision. Appendix E contains 

details on the RPM relocation process. 

Without a standard to measure RPM utilization or a process to collect and 

analyze detailed utilization information, CBP cannot ensure full utilization of 

RPMs or the best use of funds. Given that there are limited funds to sustain the 

RPM program and that there are no plans to replace the RPMs when they are no 

longer useful, CBP and DNDO need to ensure that they are using their current 

resources most efficiently. 

Inventory Control 

Neither CBP nor DNDO has ensured that the inventory of RPM equipment is 

complete and accurate. Both entities rely on PNNL to inventory the equipment; 

however, a comprehensive audit has never been conducted to account for all of 

the property. According to CBP’s PersonalfPropertyfandfAssetfManagementf

Handbook, port personnel must perform an annual inventory of “capitalized and 

accountable” property, including the RPM systems. We reviewed the FY 2011 

and FY 2012 inventory reports for seaport RPM systems and determined that not 

all systems were reported. In FY 2011 and FY 2012, CBP port personnel did not 

inventory 70 RPM systems and 20 RPM systems, respectively. 

We were unable to reconcile the weekly individual inventory reports PNNL 

provides to CBP and DNDO. Once PNNL deploys an RPM system to a location, 

CBP tracks the system and any transfer of equipment between locations. CBP’s 

Systems, Applications, and Products system reports the equipment as a system, 

without tracking the many different pieces that make up each RPM system such 

as panels, computers, booths, and enunciators. We were also unable to 

reconcile inventory records in the Systems, Applications, and Products system 

with PNNL’s current deployment list, and we noted that a minimum of 10 RPM 

systems were missing among the records. CBP officers at the port of entry 

record the information in the Systems, Applications, and Products system. The 

inventory reports system location, acquisition value, and asset number. DNDO 

only maintains a spreadsheet to track the approved, pending, or unfunded 

reconfigurations of RPM equipment. 

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During our review of the inventory reports, DNDO informed us that PNNL does 

not inventory or track the mobile RPM equipment at port locations.3 PNNL relies 

on CBP to track mobile RPM units through a maintenance database. We 

identified 12 instances in which the number of mobile RPMs at a location could 

not be verified and confirmed. For example: 

•	 At one seaport, the PNNL records showed a total of 24 mobile RPMs; 

however, we could only locate 17 systems. After questioning the 

discrepancy, port personnel explained that the mobile RPMs were relocated 

several years ago. 

•	 At another port, PNNL’s inventory reported eight mobile RPMs. We could 

only locate six systems. CBP port personnel indicated that two mobile RPMs 

had been moved to a different location also under their management. 

Without auditing and verifying all RPM inventory, CBP and DNDO are not 

properly accounting for government property. Further, the components cannot 

be assured that the equipment is being maintained, utilized, and relocated to 

make the best use of its limited life and screening capabilities. 

Sustaining the RPM Program 

To support the PEP, CBP and DNDO developed the JointfDNDO/CBPfDeploymentf

StrategyfForfDomesticfBorderfCrossingfNuclearfDetectionfSystem (joint strategy) 

to define the future RPM program. The joint strategy identified specific actions 

to improve screening efficiency at seaports by implementing Advanced 

Spectroscopic Portal technology and deploying RPMs that used this technology. 

DHS cancelled the program in 2011 because of operational and technical 

failures. However, CBP and DNDO did not update the joint strategy to address 

how seaports would be affected by the cancellation. 

DNDO initially provided the RPM program with $25 million annually and reduced 

the funding to $5 million annually. With greatly reduced projected future 

funding for the RPM program, alternate sources of funding will have to be 

obtained or significant scope and services must be cut. The reduction of 

program services will retain only the most critical functions to support 

deployments and overall project management.

3

 Mobile RPMs are truck-mounted RPM systems designed to detect nuclear materials in cargo containers. 

The mobile RPM is appropriate for seaport, rail, airport, and vehicle cargo applications, but is mostly used 

by CBP at seaports. 

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Neither entity has identified technologies to replace the current RPMs, nor has 

DNDO provided sufficient funding to deploy technologies to increase their 

service life. As a result, it is unclear how screening efficiency will be improved in 

the future. It is also unclear how CBP and DNDO will sustain the current level of 

screening given that fewer RPMs will be in service as they age. 

Recommendations 

We recommend that the United States Customs and Border Protection Acting 

Assistant Commissioner, Office of Field Operations, and the Domestic Nuclear 

Detection Office Assistant Director, Product Acquisition: 

Recommendation #1:

Identify a single program office responsible for fully coordinating and centrally 

managing the radiation portal monitor program to ensure effective and efficient 

operations and future planning. In the office, designate responsible officials to 

ensure overall program performance, accountability, coordination, and inventory 

control for the relocation and utilization of the equipment. 

Recommendation #2: 

Establish guidelines to track and report the utilization of radiation portal 

monitors at every seaport. The guidelines should allow for some exceptions 

based on unique environmental conditions, yet ensure minimally used 

equipment is reported and relocated promptly for more efficient utilization.

Recommendation #3: 

Develop and document a formal collaborative process to ensure that radiation 

portal monitor relocation is effectively planned and implemented to meet 

security needs at seaports. The process should ensure that, in making these 

decisions, all relevant data is reported and analyzed. 

Management Comments and OIG Analysis

CBP and DNDO submitted unified formal comments to our report, and a copy of 

the response in its entirety is included as appendix B. CBP and DNDO also 

provided technical comments and suggested revisions to our report in a separate 

document. We reviewed CBP and DNDO’s technical comments and made 

changes in the report when appropriate. Both CBP and DNDO appreciated our 

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efforts and concurred with all three of our recommendations. A summary of the 

responses and our analysis of those responses are as follows. 

Response to Recommendation #1: CBP and DNDO concurred and will work 

together to ensure a balanced and reasonable approach is taken to implement 

this recommendation. The completion date will be determined no later than 

January 2014. The components explained that multiple options are considered 

when determining the best approach for moving forward. The components will 

work with Headquarters for the best approach to implement the 

recommendation while examining the statutory framework; conducting a legal 

review; defining the organizational components, roles, and responsibilities; and 

estimating the cost. 

OIG Analysis: CBP and DNDO’s planned corrective actions will be responsive to 

the recommendation. This recommendation will remain open and resolved until 

we receive documented support that CBP and DNDO have developed plans and 

identified a single program office responsible for fully coordinating and centrally 

managing the RPM program. The intent of the recommendation is to have a 

single program control point to make any ultimate decisions on the RPM 

program, not necessarily to stand up a new program office. 

Response to Recommendation #2: CBP and DNDO concurred and are taking 

action to implement the recommendation. Expected to be completed by May 

2013, these actions include: initiating a study to investigate the need for 

secondary RPMs and associated cost implications of using handheld systems for 

alarm adjudication; updating the current deployment guidance for primary and 

secondary RPMs, related to initial deployments and configurations; establishing 

a process to periodically assess RPM usage and identify RPMs for potential 

deactivation or decommissioning; and establishing a joint asset team to identify 

efficiencies in internal asset and inventory management. 

OIG Analysis: CBP and DNDO’s planned corrective actions will be responsive to 

the recommendation. The recommendation will remain open and resolved until 

we review documented support on the study to investigate the need for 

secondary RPMs and associated cost implications of using handheld systems, 

updated information for deployment guidance for primary and secondary 

configurations, a documented process to periodically review RPM usage at 

seaports, and documentation on the establishment of a joint asset team and its 

purpose. 

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Response to Recommendation #3: CBP and DNDO concurred and will ensure 

the appropriate offices take the necessary steps to improve the RPM relocation 

processes to oversee systems to meet required standards. CBP and DNDO are 

currently developing a 2013 PEP, documenting current RPM deployment projects 

on the basis of priorities and a long term PEP for the RPM process, and further 

defining roles and responsibilities. The components expect to have these 

changes in place by September 2013. 

OIG Analysis: CBP and DNDO’s planned corrective actions will be responsive to 

the recommendation. The recommendation will remain open and resolved until 

we review documented support that the components have established a formal 

collaborative process to ensure RPM relocations are effectively and 

comprehensively planned and implemented to meet security needs at seaports. 

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Appendix A 

Objectives, Scope, and Methodology 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) was 

established by the HomelandfSecurityfActfoff2002 (Public Law 107-296) by amendment 

to the InspectorfGeneralfActfoff1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the Department. 

We conducted this audit to determine whether DNDO and CBP are deploying and using 

RPMs to ensure the most efficient cargo screening at seaports. To answer our objective, 

we reviewed prior audit reports and the recommendations. We reviewed policies and 

procedures for deployment and use of RPMs, including the GlobalfNuclearfDetectionf

ArchitecturefStrategicfPlanf2010, the 2006 PEP, the JointfDNDOfCBPfStrategyfforf

DomesticfBorderfCrossingfNuclearfDetectionfSystem, Government Accountability Office 

StandardsfforfInternalfControlfinfthefFederalfGovernment, and CBP Directive 5290-015A. 

We reviewed and compared criteria to CBP’s deployment and utilization of RPMs, and 

we analyzed available documentation supporting decisions for the equipment’s 

deployment and use. 

We interviewed officials within CBP, including the Office of Field Operations’ NonIntrusive Inspection; Office of Information and Technology; Office of Administration 

Facilities, Management, and Engineering; Office of Intelligence and Investigative Liaison; 

Office of Operational Field Testing Division; and Enforcement Technology Program. We 

also interviewed CBP lab partners, DNDO officials, and PNNL officials. 

We analyzed relevant information used by CBP and DNDO for the deployment and 

relocation decisions. This included the initial deployment criteria to determine factors 

contributing to deployment decisions, Baseline Change Requests, RPM deployment 

expenditure data, and the process for the reconfiguration and decommissioning of RPM 

equipment. We have limited assurance in the reliability of the RPM expenditure data 

because CBP officials informed us that supporting documentation for specific RPM 

expenditures was outdated and not accessible. 

To select locations to visit we analyzed RPM reports on scan and alarm data to identify 

usage at seven ports of entry. We also asked CBP for a list of RPM activity at ports of

entry. CBP provided a list of the number of RPM scans and alarms for 108 CBP ports of 

entry from key personnel at CBP Headquarters. The data represented FY 2011 and the 

first three quarters of FY 2012. During the review, we determined that some of the CBP 

data was incomplete and may be unreliable. We divided the list into three tiers: 1) 

high-volume locations with scans in the millions; 2) mid-volume locations with scans in 

www.oig.dhs.gov 13 OIG-13-26
 
 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

the 100,000’s; and 3) low-volume locations with scans below 10,000’s. Due to time 

constraints and limited accessibility to some geographical locations, we visited the highvolume seaport terminals. 

We visited terminals at seven seaports where we interviewed port personnel, the port 

director, supervisors, and CBP officers. We reviewed inventory lists and equipment to 

ensure all RPM panels were accounted for, deployed, and used. We also verified 

inventory and the screening procedures applied at each terminal visited. 

As of August 2012, DNDO reported that there were 1,459 RPMs deployed at all ports of 

entry. Of the 1,459 RPMs, there are 444 deployed at 39 different seaports. We 

observed operations selected for review at the seven of the seaports, which included 

185 RPMs and 27 mobile RPMs. 

To evaluate the cargo inspection targeting system for international intermodal cargo 

containers, we reviewed the training curriculum. We assessed the competence and 

training of system operators by confirming the personnel requirements for utilizing RPM 

equipment, analyzing the training curriculum, and verifying officer knowledge through 

onsite observations to ensure the officers were meeting standards. We evaluated the 

process for conducting RPM operations and resolving RPM alarms. We also evaluated 

the process for reporting the resolution of RPM alarms and completeness of the Data 

Analysis Center database and the Cargo Enforcement Reporting Tracking System used 

for reporting the resolution of RPM alarms. We compared these processes to criteria 

and determined whether RPM resolution data is used in future targeting efforts. We 

compared RPM operations conducted by CBP officers at local Ports of Entry with CBP 

Directive 5290-015A. 

We conducted this performance audit between April and November 2012 pursuant to 

the InspectorfGeneralfActfoff1978, as amended, and according to generally accepted 

government auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our

findings and conclusions based upon our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions based upon our 

audit objectives. 

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 O

 

FFICE OF INSPECTOR GENERAL 

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Appendix B 

Management Comments to the Draft Report 

1300 Pennsylvania Avenue ~V 

....... ";J~hingt(') , nc 2.0229 

u.s. Customs and 

Border Protection 

January II , 20 13 

Charles K. Edwards 

Ueputy Inspector General 

I)epartment of Homelimd Security 

245 Murray Drivc, SW, Building 410 

Washington, DC 20528 

Re: Draft Report, " United States Customs and Border Protection's Radiation Portal 

Monitors at Seaports" (OIG Project No. 12-033 -AUD-CBP) 

Dear Mr. Edwards: 

Thank you for the opportunity to review and comment on this draft report. U.S. Customs 

and Border Protection (CBP) and the Domestic Nuclear Detection Office (DNDO) 

appreciate the 0 1 IS Oftice of Inspector General 's (OIG's) work ill planning arid 

conducting its review and issuing this report. 

The Radiation Ilortal Monitor (RPM) Program is an important and signifi cant activity in 

CSP's execution of its mission to interdict illicit radioactive materials and to prevent their 

t!nlry intn the (Jnited Stntc,,_ CBP is pleased to note the OIG's positive recognjtion that 

e BP's execution orthc RPM Program is consistent with the requirements of the Secudl} 

and Accoumability for Every PorI ACl of 1006, as amended, to scan all containerized cargo 

enteri ng the United States at the 22 seaports with the greatest cOlltainer volume. 

·I'he draft report contained three recommendations directed to CBP's Acting Assistant 

Commissioner, Oftice o f Field Operalions, and DNDO's Assistant Directoz', Product 

Acq uisition. CBP nnd ONDO concur with all threc recommendations. Specifically: 

Recommendation 1: Identify a single program oftice responsible fo r fully coordinating 

and centrally managing the RPM program to ensure effective and efficient operations and 

futurc planning. In the ottice. designate responsible officials to ensure overall program 

perfonnance, accountability, coordination, and inventory control ror the relocation and 

utilization of the equipment. 

Response: Concur. CBP and DNDO will work together to ensure a balanced and 

reasonable approach is taken to implement this recommendation, and that multiple options 

are considered when determining the best approach for moving farv./ard with staudiug up a 

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OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

 

program management office (PMO). This wi ll include ensuring thc dcfinjtion and 

establishment of a PMO we ba!;t;(j un slalutmy, operaTional, funding and policy 

considerations, as appropriate. fhe Following actions will be needed fo r designation of the 

PMO, 

I. Explore with Headquarters the best appmach TO implement the recommendation. 

2. Establish a schedule for concluding these actions and initiation of operati ons for the 

PMO, including concurrence from all impacted agencies. 

3. Examine the statuto!), framework for the program office with respect to scope. 

4. Define the critical organizational components, and roles and responsibilities or the 

program office. 

5. COlluucllegal review ortlle proposed designation to ensure consistency with all 

applicable and relevant statutes and appropriations. 

6. Estimate the cost of implementing this UIG audit recommendation. 

Estimated Completion Date (ECD): To be detennined no laterthan January 31, 2014 

Recommendation 2: Establish guidelines to track and report the utilization ofRPMs at 

every seaport. The guidclines should allow for some exceptions based on unique 

envirolUnt:ntal conditions, yet ensure minimally lIsed equipment is reported and relocated 

promptly for more efficient utilization. 

Rt'.sponse: Concur. The followinB actions are underway or wilt be initiated : 

1. CBP/Office of Fie ld Operation/Cargo and Conveyance Security DivisionINonIntrusive inspection Division has initiated a study to ill vt::stigalt:: the need for 

secondary RPMs and associated cost implications of using handheld systems for 

alarm adjudication. ECD: March 31. 2013 

2. Update cUlTent RPM deploymt:nt guidance fo r primary and secondary 

configurations related to initial deployments and reconfigurations. 

ECD: May 31, 2013 

3. Establish a process to periodically assess RPM usage and identify RPMs for 

pOlential deactivation or decommissioning and IO initiate action as follows: 

a. Remove unused RPMs from the maintenance and calihration scnedli le only 

once final status of the lane has been detennined on the basis of pon of entry or 

tenninal operator plans. 

b. Kemove an KPM from a lane only when the lane is no longer uscd for inbound 

comaillerizeu Gafgu or conveyanct!S with any fumre plans for RPM usage. 

2 

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OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

 

c. Develop 0 cost estimate for removru of all unused RPMs after dctctmination of 

mJ potential future use in current locarion. 

ECO: May 31, 2013 

4. CBP has established a joint assct team to identify efficiencies in internal asset and 

inventory management. CBP will establish and implement a separate logistics 

inventory/property accountability system to address any gaps in inventory. 

ECD: Completed. Specifically a joint asset team was fonned in December 2012 to 

address inventory issues and gaps. 

Overall ECD: May31,20 l3 

Rccommendation 3: Develop and document a fonnaJ collaborative process to ensure that 

RPM relocation is effectively planned and implemented to meet security needs at seaports. 

The process should ensure that, in making these decisions, all relevant data is reported and 

analyzed. 

Response: Concur. Sa.feguarding and acco unting of eBP owned and operated equipment 

is a very significant fiducia.ry responsibiUty and 'he will ensure till: appropriah:: uffir.;es lake 

the necessary steps to improve these processes to oversee systems to meet required 

standards_ The foUowing actions are undenNay or will be in.itiated: 

I. CBP and DNDO art; lk\'doping a Prujt:ct Ext:cution Plan (PEP) [or Fi~al Yc:<:Ir 

20 13 for planned RPM deployments and reconfigurations. This new PEP wilt 

document the currt:ut appro"ed RPM dt:ploYIJIt:nt projects 011 the (nlsis ur priurities. 

as previously documented in memoranda to DNDO. 

neD: february 28. 20 13 

2. COP and DNDO are developing a Project Management Plan and long-t.enu PEP to 

further derme the RPM deployment process and roles and responsibilities. 

ECD: SeplemberJO, 2013 

3. CBP Office of Field Operations will conduct recurring teleconferences with each 

Field Office to discuss inspection and detection techno logy needs, issues and future 

requirements. 

ECD: Completed. In itiated December 20 12 and will continue. as needed. 

Ovcntll ECD: September 30, 2013 

J 

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OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

 

Again, thank you for the opportunity to review and comment on this draft repOit. 

Technical COll1lut:uLs wt:n::: pTt!viously prnvided under separate cm:er. Please feel free to 

contact me if you have any questions. Alternatively, a member of your staff can contact 

Kathryn Dapkins, Audit Liaison. Office of lnlt:rnal Affai rs at (202) 325-7732. We look 

forward to working with you in the future. 

Sincerely, 

/&j~dli>/Z 4ru?e:: ~omshcck Assistant Commissioner 

Office of lnternul Affai~ 

4 

 

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 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix C 

CBP Process for Resolving RPM Alarms 

Source: CBPf-fOfficefoffTrainingfandfDevelopmentfRadiationfPortalfMonitorfAttritionfTraining:fReviewfandf

FieldfExercisesfInstructorfGuide, December 2011 

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 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix D 

Response to Congressional Mandate to Assess Training 

We conducted onsite interviews and observations of CBP officers’ compliance with 

established criteria and training, which supported that officers are sufficiently 

competent in operating RPMs to detect illicit radiological sources. We assessed the 

competence and training of employees operating the system to determine whether they 

are sufficiently capable of detecting potential terrorist threats, and to determine 

whether CBP officers are trained and competent to utilize RPM equipment to detect 

illicit radiological sources. We verified that CBP officers must take the Virtual Learning 

Center “RPM Attrition” course as a prerequisite to the “Radiation Portal Monitor 

Training” course provided by the CBP Field Operations Academy. We compared onsite 

RPM operations conducted by CBP officers at local ports of entry with CBP Directive 

5290-015A.

RPM training provides CBP officers with knowledge in the following areas critical to 

using RPM equipment: 

•	 CBP radiation detection requirements 

•	 Sources of radiation that may cause RPM alarms

•	 Types of radiation detection equipment 

•	 RPM terminology 

•	 Types of cargo that cause the majority of alarms at ports of entry 

•	 Identification of RPM components 

•	 Substance resolution and falsified U.S. Nuclear Regulatory Commission 

certificates 

•	 Interpretation of RPM profile graph printouts and the alarm view window 

•	 RPM care and maintenance requirements

•	 Field exercises covering RPM component identification, operation, and alarm 

resolution 

CBP officers are evaluated on their performance and adherence to CBP Radiationf

DetectionfProgramfDirectivef5290-015A and local standard operating procedures (as 

applicable). The tool for this evaluation is the Personnel Qualification Standard. 

CBP officers are certified as having completed the course when they have achieved 70 

percent on the final evaluation and are entered in the Training Records and Enrollment 

Network. If participants do not achieve a score of 70 percent or better, remediation or 

an opportunity to retake the course is provided; those students are then allowed to 

retake the evaluation. 

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 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

A total of eight field exercises are used to give CBP officers the opportunity to 

demonstrate the standard processes associated with RPM operation and to follow the 

requirements for responding to alarms and alerts. After these exercises, CBP officers 

participate in a final classroom exercise. 

www.oig.dhs.gov 21 OIG-13-26
 
 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix E 

RPM Reconfiguration Process

Source: DHS-OIG with input from CBP and DNDO. 

www.oig.dhs.gov 22 OIG-13-26
 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix F 

RPM Program Planning

2006 Project Execution Joint DNDO/CBP Deployment 

Plan (PEP) Strategy For Domestic Border 

Crossing Nuclear Detection 

System

Defines the current According to the Joint 

overall project objectives, Strategy, DNDO has the 

work scope, schedules, charter to develop and 

costs, and required acquire appropriate nuclear 

funding for Pacific detection technologies that 

Northwest National meet user requirements and 

Laboratory (PNNL) to support the deployment of

support DNDO and CBP in those technologies. CBP has 

deploying RPMs at ports the lead for deploying, 

of entry. commissioning, operating, 

and maintaining the nuclear 

detection systems that 

compose the Domestic 

Border Crossing Nuclear 

Detection System. 

The PEP describes the

RPM deployment process 

to be executed by PNNL. 

It also explains Baseline The purpose of this 

Change Requests, which document is to present a 

are deployment changes jointly developed strategy for 

that impact the scope, the deployment of RPMs for

schedule, and cost securing the Nation’s border 

baselines. It also includes crossings from attempts to

key planning assumptions smuggle nuclear devices, 

for program funding, special nuclear materials, or

technology, and threatening radioactive 

deployments. materials.

Planning Shortfalls

The PEP and the Joint 

Strategy do not include RPM 

reconfiguration planning or 

a mitigation strategy for key 

planning assumptions. 

CBP’s and DNDO’s roles and 

responsibilities are included 

in the Joint Strategy, but not

in the PEP. 

No clear and transparent 

joint decision-making. 

No RPM sustainment 

planning.

Source: DHS OIG 

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 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix G 

Major Contributors to This Report 

Patrick O’Malley, Director 

J. Eric Barnett, Audit Manager 

Cheryl Jones, Audit Manager 

LaTrina McCowin, Auditor-in-Charge 

Kevin King, Auditor 

Jeffrey Wilson, Program Analyst 

Thomas Hamlin, Program Analyst 

Brian Smythe, Program Analyst 

Kelly Herberger, Communications Analyst 

Ralleisha Dean, Independent Reference Reviewer 

www.oig.dhs.gov 24 OIG-13-26
 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix H

Report Distribution 

Department of Homeland Security

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs

Assistant Secretary for Office of Legislative Affairs 

Acting Chief Privacy Officer 

Commissioner CBP 

CBP Liaison 

Director, Product Acquisition and Deployment, Domestic Nuclear Detection Office 

DNDO Liaison 

Office of Management and Budget

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress

Congressional Oversight and Appropriations Committees, as appropriate

www.oig.dhs.gov 25 OIG-13-26
 
 

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For additional information, visit our website at: www.oig.dhs.gov, or follow us on Twitter 

at: @dhsoig. 

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