NUCLEAR 

NONPROLIFERATION

Further Actions Needed by 

U.S. Agencies to Secure 

Vulnerable Nuclear and 

Radiological Materials 

Statement of Gene Aloise, Director 

Natural Resources and Environment

Testimony 

Before the Subcommittee on Oversight of 

Government Management, the Federal Workforce, 

and the District of Columbia, Committee on 

Homeland Security and Governmental Affairs, 

U.S. Senate

For Release on Delivery 

Expected at 2:30 p.m. EDT

Wednesday, March 14, 2012

GAO-12-512T

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-512T, a testimony 

before the Subcommittee on Oversight of 

Government Management, the Federal 

Workforce, and the District of Columbia, 

Committee on Homeland Security and 

Governmental Affairs, U.S. Senate 

March 14, 2012 

NUCLEAR NONPROLIFERATION 

Further Actions Needed by U.S. Agencies to Secure 

Vulnerable Nuclear and Radiological Materials

Why GAO Did This Study

In 2009, President Obama announced 

an international initiative to secure all 

vulnerable nuclear material worldwide

within 4 years. Leaders of 47 nations 

endorsed this effort at the 2010 

Nuclear Security Summit and will meet 

again in March 2012 to evaluate their 

work and set new goals for nuclear 

security. The United States has been

a leader in promoting nuclear 

nonproliferation efforts worldwide. 

GAO has issued numerous reports on 

U.S. nonproliferation programs 

administered by several agencies, 

including the departments of Energy

(DOE), State, and Defense (DOD); and 

the Nuclear Regulatory Commission

(NRC). This testimony, which is based

primarily on previously issued reports, 

discusses (1) the U.S. strategy to 

secure all vulnerable nuclear material 

within 4 years, (2) U.S. agencies’ 

ability to track and evaluate the 

security of U.S. nuclear materials 

transferred to foreign countries, 

(3) challenges coordinating federal 

nuclear nonproliferation efforts, and 

(4) preliminary observations regarding

GAO’s ongoing work on federal efforts 

to secure radiological sources in U.S. 

hospitals and medical facilities. To 

conduct its ongoing work, GAO visited 

25 hospitals and medical facilities in 7 

states and the District of Columbia. 

GAO is making no new 

recommendations, but continues to 

believe that implementation of the 

recommendations made in its recent 

reports complements and supports the 

administration’s goal of securing 

vulnerable nuclear material in a timely 

fashion. 

What GAO Found

The President’s 4-year initiative is a worthwhile effort designed to accelerate U.S. 

and international efforts to secure nuclear material worldwide. However, as GAO 

reported in December 2010, the governmentwide strategy approved by the 

National Security Council (NSC) for the initiative lacked specific details regarding 

how the initiative will be implemented. As a result, key details associated with the 

initiative are unclear, including its overall estimated cost, time frame for 

completion of work, and scope of planned work. In its 2010 report, GAO 

recommended, among other things, that NSC lead the interagency development 

of a more detailed implementation plan for the President’s 4-year initiative. NSC 

did not comment on GAO’s recommendations.

The United States also faces challenges accounting for and evaluating the 

security of U.S. nuclear material overseas. As GAO reported in September 

2011, federal agencies are not able to fully account for U.S. nuclear material 

overseas that is subject to nuclear cooperation agreements. GAO also found that 

the agreements do not contain specific access rights that enable agencies to 

monitor and evaluate the physical security of U.S. nuclear material overseas. 

GAO found that the agencies responsible for reviewing foreign partners’ security 

are not doing so systematically. GAO suggested that Congress consider 

directing DOE and NRC to fully account for U.S. weapon-usable nuclear 

materials overseas and consider amending the Atomic Energy Act to require 

access rights allowing the United States to verify adequate protection of U.S. 

nuclear materials if future agreements cannot be negotiated to include such

rights. 

GAO also reported in December 2011 on the challenges in coordinating U.S. 

governmentwide nonproliferation efforts. Specifically, GAO identified potential 

fragmentation and overlap among some U.S. programs that played a role in 

preventing and detecting the smuggling of nuclear materials overseas. GAO also 

found that no single federal agency had the lead responsibility to direct these 

efforts. GAO recommended, among other things, that NSC review U.S. 

programs working to prevent nuclear smuggling overseas to reduce 

fragmentation and potential overlap. NSC declined to comment on the 

recommendations.

In addition to nuclear materials, the Summit plans to address the security of 

radiological sources—material that could be used to make a dirty bomb. Based 

on preliminary results from ongoing work on federal efforts to secure radiological 

sources in U.S. hospitals and medical facilities, GAO found that NRC’s security 

controls for hospitals and medical facilities do not prescribe the specific steps 

that must be taken to protect their radiological sources. GAO also found that

medical facilities have implemented the controls in various ways. This has 

created a mix of security measures at the locations GAO visited that could leave 

some facilities more vulnerable than others. DOE’s National Nuclear Security 

Administration (NNSA) has established a voluntary program to upgrade the 

security of domestic facilities that have radiological sources. NNSA has made 

progress in securing domestic radiological sources, but some facilities have 

declined NNSA’s assistance, including hospitals located in high-risk urban areas.

View GAO-12-512T or key components.

For more information, contact Gene Aloise at 

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

Page 1 GAO-12-512T 

Chairman Akaka, Ranking Member Johnson, and Members of the 

Subcommittee:

I am pleased to participate in this hearing in advance of the Nuclear 

Security Summit in South Korea. As you know, in 2009, President Obama 

announced an international initiative to secure all vulnerable nuclear 

materials around the world within 4 years, and leaders of 47 nations 

endorsed this initiative at the 2010 Nuclear Security Summit here in 

Washington. The leaders pledged to work together toward this end and 

also reaffirmed the fundamental responsibility of nations to maintain 

effective security of the nuclear materials and facilities under their control.

At the conclusion of the summit, the leaders agreed to meet again in 

South Korea in March 2012 to evaluate their work and set new goals for 

nuclear security, including the security of radiological material. We 

recognize the importance of the Summit as a way to galvanize 

international support for reducing the risks posed by the proliferation of 

these dangerous materials and are pleased to see that radiological 

material security will be given greater attention. This could provide a more 

comprehensive and balanced approach to risk reduction efforts by the 

international community.

One of the most serious threats facing the United States and other 

countries is the possibility that other nations or terrorist organizations 

could steal a nuclear warhead or nuclear weapon-usable materials from 

poorly secured stockpiles around the world,1

 

1

Weapon-usable nuclear materials are highly enriched uranium, uranium-233, and any 

plutonium containing less than 80 percent of the isotope plutonium-238. Such materials 

are also often referred to as fissile materials or strategic special nuclear materials.

or that nations could divert 

nuclear material intended for peaceful purposes to the development of 

nuclear weapons. Terrorists or countries seeking nuclear weapons could 

use as little as 25 kilograms (Kg) of weapon-grade highly enriched 

uranium (HEU) or 8 Kg of plutonium to construct a nuclear weapon. Of 

great concern is that terrorists could fashion a crude nuclear bomb made 

from either HEU or plutonium into an improvised nuclear device (IND). An 

IND would create an explosion producing extreme heat, powerful 

shockwaves and intense radiation that would be immediately lethal to 

individuals within miles of the explosion, as well as radioactive fallout over 

thousands of square miles. Nonproliferation experts estimate that a 

successful IND could produce the same force as the equivalent yield of 

the bomb that destroyed Nagasaki, Japan, in 1945; it could devastate the 

 
 

Page 2 GAO-12-512T 

heart of a medium-sized U.S. city. The explosion could cause hundreds of 

thousands of deaths and injuries, as well as pose long-term cancer risks 

to those exposed to the radioactive fallout.

Radiological material also poses a significant security threat to the United 

States and the international community. Radiological material, such as 

cobalt-60, cesium-137, and strontium-90, is encapsulated or sealed in 

metal—such as stainless steel, titanium, or platinum—to prevent its 

dispersal and is commonly called a sealed radiological source. Sealed 

radiological sources are used worldwide for many legitimate purposes, 

such as medical, industrial, and agricultural applications. The total 

number of these sources in use worldwide is unknown because many 

countries do not systematically account for them. If certain types of these 

sources were obtained by terrorists, they could be used to produce a 

simple and crude but potentially dangerous weapon—known as a 

radiological dispersion device, or dirty bomb. Although experts believe 

that a dirty bomb could result in a limited number of deaths, it could have 

severe economic consequences. Depending on the type, amount, and 

form, the dispersed radiological material could cause radiation sickness 

for people nearby and produce serious economic, psychological and 

social disruption associated with the evacuation and subsequent cleanup 

of the contaminated area. The economic consequences resulting from the 

improper use of radiological materials is not theoretical. Some actual 

incidents involving sources can provide a measure of understanding of 

what could happen in the case of a dirty bomb attack. For example, in 

1987, an accident involving a medical device containing about 1,400 

curies of cesium-137,2

To address these threats, respond to the President’s goal of securing 

vulnerable nuclear material worldwide within 4 years, and meet the 

objectives of the Nuclear Security Summit, U.S. agencies have 

undertaken a number of nuclear nonproliferation efforts. Specifically, the 

killed four people in Brazil’s Goiania region and 

injured many more. The accident and its aftermath caused about $36 

million in damages to the region. The decontamination process required 

the demolition of homes and other buildings and generated 3,500 cubic 

meters of radioactive waste.

 

2

A curie is a unit of measurement of radioactivity. In modern nuclear physics, it is defined 

as the amount of substance in which 37 billion atoms per second undergo radiological 

disintegration. In the international system of units, the becquerel is the preferred unit of 

radioactivity. One curie equals 3.7 x 1010 becquerels.
 

Page 3 GAO-12-512T 

National Nuclear Security Administration (NNSA), a separately organized 

agency within the Department of Energy (DOE) has more than 20 

programs that are intended to, among other things, secure nuclear 

warheads; reduce the risk of nuclear smuggling; and protect, consolidate, 

and dispose of weapon-usable nuclear material and radiological sources.

The two other U.S. agencies that conduct major nuclear nonproliferation 

programs and activities overseas are the departments of Defense (DOD) 

and State. DOD administers the Cooperative Threat Reduction program, 

which has facilitated the removal of nuclear weapons from Ukraine, 

Belarus, and Kazakhstan and has helped Russia and Ukraine meet their 

arms control commitments by assisting in the elimination of strategic 

delivery systems. State manages its own nonproliferation programs, such 

as the Export Control and Related Border Security program,3

My statement today is based primarily on reports we issued from 

September 2010 to December 2011 that assess various U.S. nuclear 

nonproliferation programs and activities that support both the President’s 

4-year initiative and, more broadly, the goals of the Summit. Specifically, 

I will focus my testimony on (1) the U.S. governmentwide strategy for 

supporting the President’s goal of securing all vulnerable nuclear 

materials worldwide within 4 years, (2) U.S. agencies’ ability to track and 

provides 

support to NNSA and other U.S. agencies’ nuclear nonproliferation 

programs working overseas, and conducts bilateral and multilateral 

diplomacy to address proliferation threats around the world under its 

Bureau of International Security and Nonproliferation. The Department of 

Homeland Security is responsible for, among other things, developing 

and deploying technologies to detect, prevent and interdict nuclear 

materials smuggled into the United States. National Security Council 

(NSC) staff have the principal role in coordinating the implementation of 

NNSA, DOD, State, and other agencies’ nonproliferation programs. NSC 

oversees development of general policy and establishes guidelines for 

U.S. nonproliferation programs, but it does not implement programs or 

control their budgets. In addition, the Nuclear Regulatory Commission 

(NRC) and NNSA are involved in regulating and/or securing radiological 

sources within the United States and in foreign countries.

 

3

The Export Control and Related Border Security program seeks to prevent the 

proliferation of weapons of mass destruction and advanced conventional weapons by 

helping to build effective national export control systems in countries that possess, 

produce, or supply strategic items as well as in countries through which such items are 

most likely to transit.
 

Page 4 GAO-12-512T 

evaluate the security of U.S. nuclear materials transferred to foreign 

countries, (3) challenges in coordinating federal nuclear nonproliferation 

efforts, and (4) ongoing work on federal efforts to secure radiological 

sources in U.S. hospitals and medical facilities. Detailed information on 

our scope and methodology for our prior work can be found in these 

reports. To develop our preliminary observations on efforts to secure 

radiological sources in U.S. medical facilities, we visited 25 hospitals and 

medical facilities in seven states and the District of Columbia, interviewed 

regulatory officials from 20 states, and interviewed agency officials at 

DOD, DOE, NRC, and the Department of Veterans Affairs (VA).4

We obtained the views of DOE, DOD, VA and NRC for new information in 

our statement concerning radiological source security at U.S. hospitals 

and medical facilities. We incorporated the agencies’ technical comments 

where appropriate.

We also 

reviewed relevant laws, regulations, and guidance for overseeing 

commercial radiological sources. We are conducting our ongoing work in 

accordance with 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 on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The 2010 Nuclear Security Summit highlighted the global threat posed by 

nuclear terrorism and the need for countries to work in a comprehensive 

and concerted fashion to ensure that nuclear materials are not stolen or 

diverted for weapons use. The Summit produced a communiqué, a highlevel political statement by the leaders of the 47 participating countries.

The communiqué identified several measures that countries planned to 

take to strengthen their nonproliferation efforts. These efforts included, 

among other things, (1) focusing on improving security; (2) accounting for 

and consolidating HEU and plutonium; and (3) ensuring that the 

 

4

We conducted site visits at hospitals and medical facilities in California, Maryland, New 

York, Pennsylvania, Tennessee, Texas, Virginia, and the District of Columbia. We also 

interviewed regulatory officials from Alabama, Arizona, Arkansas, California, Colorado, 

Florida, Kentucky, Maryland, Massachusetts, Mississippi, New Mexico, New York, North 

Carolina, Pennsylvania, Rhode Island, Tennessee, Texas, Virginia, Washington, and 

Wisconsin.

Background
 

Page 5 GAO-12-512T 

International Atomic Energy Agency (IAEA) has the necessary resources 

to carry out its nuclear security activities.5

The 2010 Summit produced results. For example, Ukraine announced at 

the Summit that it would ship approximately 236 pounds of HEU and 123 

pounds of spent nuclear fuel to Russia by the end of 2012.6 During the 

Summit, the United States, Canada, and Mexico announced a new 

agreement that calls for the conversion of HEU fuel at Mexico’s nuclear 

research reactor to low enriched uranium. Malaysia, Egypt, and Armenia 

planned to enact new export control laws to limit nuclear trafficking.

Malaysia, an important hub in the A.Q. Khan illicit nuclear trafficking 

network, approved a new export law curbing transfers of nuclear 

weapons-related materials. Many other nations expressed their support to 

funding efforts for international nuclear safety organizations. For example, 

Belgium, Japan, the United Kingdom, Norway, and New Zealand all 

pledged funding efforts towards IAEA’s Nuclear Security Fund.7

 

5

The International Atomic Energy Agency is an independent organization based in Vienna, 

Austria, that is affiliated with the United Nations and has the dual mission of promoting the 

peaceful uses of nuclear energy and verifying that nuclear technologies and materials 

intended for peaceful purposes are not diverted to weapons development efforts. As of 

February 2012, the agency had 153 member states. We have recently begun a review of 

IAEA programs and activities at the request of this subcommittee.

6

In February 2012, NNSA officials told us that the Summit process has accelerated U.S. 

efforts to remove HEU from several countries. Specifically, since the 2010 Summit, NNSA 

has worked with international partners to remove 380 Kg of HEU from civilian sites in 

seven countries: Belarus, the Czech Republic, Kazakhstan, Poland, Serbia, South Africa, 

and Ukraine. 

7

IAEA’s Nuclear Security Fund supports the agency’s efforts to assist countries in 

protecting their nuclear and radiological materials and facilities. For more information, see 

GAO, Nuclear Nonproliferation: IAEA Has Strengthened Its Safeguards and Nuclear 

Security Programs, but Weaknesses Need to Be Addressed, GAO-06-93 (Washington, 

D.C.: Oct. 7, 2005). 
 

Page 6 GAO-12-512T 

In December 2010, we reported on aspects of U.S. planning and 

strategies to secure all vulnerable nuclear materials worldwide within a 4-

year period.8 Following President Obama’s announcement of the 4-year 

initiative, NSC took the lead in coordinating efforts among different federal 

agencies that will contribute to the initiative. NSC officials approved a 

U.S. governmentwide strategy entitled “Interagency Efforts to Improve the 

Security of Nuclear Weapons and Fissile Materials,” which, among other 

things, described the scope and objectives of the interagency effort and 

identified the main activities by agencies and programs in support of the 

President’s initiative. U.S. agencies—including NNSA, DOD, and State—

had identified individual plans describing how they intend to contribute to 

the 4-year initiative. NNSA, for example, had developed a formal written 

plan with specific details regarding how it intends to contribute to the 4-

year nuclear material security goal. The NNSA plan details a prioritized 

five-part effort, including (1) continuing nuclear security cooperation, 

especially nuclear material protection, control and accounting (MPC&A) 

upgrades and efforts to transition responsibility for sustaining MPC&A 

systems;9

Despite individual agency efforts to implement the 4-year initiative, we 

found that the overarching interagency strategy coordinated by NSC 

lacked specific details concerning how the initiative would be 

implemented, including the identity of, and details regarding, vulnerable 

foreign nuclear material sites and facilities to be addressed, agencies and 

programs responsible for addressing each site, planned activities at each 

site, potential challenges and strategies for overcoming these challenges, 

anticipated timelines, and cost estimates. NSC officials told us that 

developing a single, integrated cross-agency plan that incorporates all 

these elements could take years. However, we found that, absent such 

(2) expanding nuclear security cooperation with other 

countries; (3) accelerating nuclear material removal with other countries; 

(4) strengthening nuclear security standards, practices, and nextgeneration nuclear safeguards; and (5) building international capabilities 

to prevent illicit nuclear trafficking and smuggling.

 

8

GAO, Nuclear Nonproliferation: Comprehensive U.S. Planning and Better Foreign 

Cooperation Needed to Secure Vulnerable Nuclear Materials Worldwide, GAO-11-227

(Washington, D.C.: Dec. 15, 2010).

9

NNSA’s MPC&A program works to improve the security of nuclear warheads and 

materials in Russia and at nuclear sites in other countries, consolidate and convert 

weapon-usable nuclear material stocks, and enable Russia and other countries to sustain 

MPC&A upgrades over the long term without continued U.S. support. 

Governmentwide 

Strategy to Implement 

the President’s 4-Year 

Global Nuclear 

Material Security 

Initiative Lacked 

Important Details
 

Page 7 GAO-12-512T 

an implementation plan, essential details associated with the 4-year 

initiative were unclear, including the initiative’s overall estimated costs, 

time frames, and scope of work. For instance, we reported that the costs 

of implementing the initiative were unknown. Among other things, NSC 

officials told us that estimating the costs associated with the President’s 

goal is impossible because the initiative is predicated on having other 

countries provide assistance and share costs, and it is impossible to 

forecast cooperation that may occur with other countries, including the 

resumption of denuclearization efforts in North Korea.

We also found that the time frames for the initiative are uncertain because 

NSC officials did not consider the 4-year time frame to be a hard and fast 

deadline. Rather than achieving a specific level of nuclear material 

security around the world within the 4-year time frame, the President’s 

proposal has value in broader terms, according to NSC officials. They 

described the value of the President’s proposal as a “forcing function” to 

(1) accelerate ongoing U.S. nuclear nonproliferation programs, (2) drive 

closer integration of nuclear nonproliferation programs across the federal 

government, and (3) mobilize greater international responsibility for and 

commitment to nuclear material security. Furthermore, we reported that 

other details relating to the overall scope of the 4-year initiative were 

vague. For example, we were unable to identify the scope of nuclear 

material worldwide that would be addressed under the initiative, because 

such details were not included in the interagency strategy document. We 

also identified concerns with how the initiative intends to address sites 

with potentially vulnerable nuclear materials located in countries that may 

impose access limitations that could complicate or preclude U.S. security 

assistance.

We recommended that NSC lead and coordinate the development of a 

comprehensive plan for implementing this initiative. Such a plan, in our 

view, should clearly identify the specific foreign countries, sites, and 

facilities, where materials have been determined to be poorly secured, 

and include information specifying the agencies and programs 

responsible for addressing each location; planned activities, potential 

implementation challenges, and steps needed to overcome those 

challenges at each location; and estimated time frames and costs 

associated with achieving the 4-year goal. NSC did not comment on our 

recommendation.
 

Page 8 GAO-12-512T 

Improving the U.S. government’s management of nuclear cooperation 

agreements could contribute to the administration achieving its goal of 

securing all vulnerable nuclear material worldwide in 4 years.10 The 

United States has exported special nuclear material, including enriched 

uranium, and source material such as natural uranium under these 

framework agreements for many years. These agreements must contain 

certain obligations that govern, among other things, the U.S. rights of 

approval over the transfer, retransfer, enrichment, and reprocessing of 

certain kinds of nuclear materials transferred from the United States and, 

in some cases, produced overseas. Partners are required to guarantee 

the physical protection of U.S. nuclear materials. In September 2011, we 

issued a report that (1) assessed U.S. agency efforts to account for U.S. 

nuclear material overseas, (2) assessed DOE and U.S. agencies’ efforts 

to evaluate the security of these materials, and (3) described DOE’s 

activities to secure or remove potentially vulnerable U.S. nuclear material 

at partner facilities.11

We found that U.S. agencies—DOE, NRC, and State—are not able to 

fully account for U.S. nuclear material overseas that is subject to the 

terms of nuclear cooperation agreements because (1) the agreements do 

not stipulate systematic reporting of such information, and (2) there is no 

policy to pursue or obtain such information. These agreements generally 

require that partners report inventory information upon request. However, 

the agencies have not systematically sought such information.

Specifically, DOE and NRC do not have a comprehensive, detailed 

current inventory of U.S. nuclear material—including weapon-usable 

material—that is located overseas. In addition, NRC and DOE could not 

fully account for the location and disposition of U.S. HEU overseas in 

 

10The United States has 27 nuclear cooperation agreements in force for peaceful civilian 

cooperation with partners, including foreign countries, the European Atomic Energy 

Community (EURATOM), IAEA, and Taiwan. Governmental relations between the United 

States and Taiwan were terminated on January 1, 1979. All agreements concluded with 

the authorities on Taiwan prior to January 1, 1979, are administered for the United States 

by the American Institute in Taiwan, a nonprofit corporation based in Washington, D.C.

The United States has two nuclear cooperation agreements with Australia, including one 

for Separation of Uranium Isotopes by Laser Excitation technology, bringing the total 

number of agreements to 27. 

11GAO, Nuclear Nonproliferation: U.S. Agencies Have Limited Ability to Account for, 

Monitor, and Evaluate the Security of U.S. Nuclear Material Overseas, GAO-11-920

(Washington, D.C.: Sept. 8, 2011).

U.S. Agencies Have 

Limited Ability to 

Account for, Monitor, 

and Evaluate the 

Security of U.S. 

Nuclear Material 

Overseas
 

Page 9 GAO-12-512T 

response to a 1992 congressional mandate.12

Nuclear cooperation agreements do not contain specific access rights 

that enable U.S. agencies to monitor and evaluate the physical security of 

U.S. nuclear material overseas, and the United States relies on its 

partners to maintain adequate security. In the absence of access rights, 

DOE, NRC, and State have conducted physical protection visits, when 

permitted, to monitor and evaluate physical security conditions of U.S. 

nuclear materials at overseas facilities. However, we found that the 

agencies have not systematically visited countries believed to be holding 

the most sensitive material or systematically revisited facilities not 

meeting international physical security standards in a timely manner. U.S. 

interagency teams made 55 visits from 1994 through 2010 and found that 

countries met IAEA security guidelines approximately half of the time.

The January 1993 report 

that NRC produced in response to the mandate stated that it was not 

possible to reconcile this information from available U.S. sources of data 

with all foreign holders of U.S. HEU within the 90-day period specified in 

the act. Our analysis of other documentation associated with the report 

shows that NRC, in consultation with U.S. agencies, was able to verify the 

location of 1,160 kilograms out of 17,500 kilograms of U.S. HEU 

remaining overseas as of January 1993. According to DOE and NRC 

officials, no further update to the 1993 report was issued, and the U.S. 

government has not subsequently attempted to develop such a 

comprehensive estimate of the location and status of U.S. HEU overseas.

There are several countries that have U.S. nuclear material that are 

particularly problematic and represent special cases for concern. 

Specifically, U.S. nuclear material has remained at sites in three countries 

where physical protection measures are unknown or the sites have not 

been visited by an interagency physical protection team in decades. 

DOE’s Global Threat Reduction Initiative (GTRI) removed a large quantity 

of U.S.-spent HEU recently from one of those countries. However, 

according to NRC and State officials, U.S. transfers to these three 

countries were made prior to 1978, when a requirement that the partner 

countries guarantee that they will maintain adequate physical security for 

transferred nuclear material was added to the U.S. Atomic Energy Act of 

1954. Therefore, these countries have not made the same commitments 

 

12Energy Policy Act of 1992, Pub. L. No. 102-486, § 903(b), 106 Stat. 2776, 2945-46.
 

Page 10 GAO-12-512T 

regarding the physical security of U.S.-transferred material as the United 

States’ other nuclear cooperation agreement partner countries.

We also found that physical security concerns are not confined to 

countries that have limited infrastructure and resources. The potential 

vulnerability of nuclear material at certain facilities in high-income 

countries was raised to us by NSC officials.13

In our September 2011 report, we found that DOE has taken steps to 

improve security at a number of facilities overseas that hold U.S. nuclear 

material but faces constraints. DOE’s GTRI program removes U.S. 

material from vulnerable facilities but can only repatriate materials that 

have an approved disposition pathway and meet the program’s eligibility 

criteria. GTRI officials told us that of the approximately 17,500 kilograms 

of HEU exported from the United States, 12,400 kilograms are currently 

not eligible for return to the United States. The vast majority of this 

amount—about 10,000 kilograms—is currently not eligible for return 

because the material does not have an acceptable disposition pathway, 

such as permanent disposal or potential reuse. Another 2,000 kilograms 

of material is located primarily in the European Atomic Energy Community 

(EURATOM) member countries and is in use or adequately protected, 

according to GTRI officials.

Specifically, we reported 

that there may be security vulnerabilities in certain high-income countries, 

including three specific high-income countries. For sites in these 

countries, GTRI officials told us the U.S. government’s strategy is to work 

bilaterally with the countries, provide recommendations to improve 

physical protection, and follow up as needed.

14

As a result, we made several suggestions and recommendations to 

improve oversight and accountability. For example, we suggested that 

Congress consider directing DOE and NRC to compile an inventory of 

U.S. weapon-usable nuclear materials overseas. As a separate matter, 

we also suggested that Congress consider amending the Atomic Energy 

Act if State, working with other U.S. agencies, does not include enhanced 

measures regarding physical protection access rights in future and 

renewed agreements, so that U.S. interagency physical protection teams 

may obtain access when necessary to verify that U.S. nuclear materials 

 

13GAO-11-227. 

14EURATOM is composed of the 27 countries of the European Union.
 

Page 11 GAO-12-512T 

have adequate physical protection. We also recommended that the 

Secretary of State, working with the Secretary of Energy and the 

Chairman of the NRC, establish better inventory reporting and 

reconciliation procedures, particularly when it comes to foreign facilities 

holding U.S. weapon-usable material.

DOE, NRC, and State generally disagreed with our recommendations 

when commenting on our draft report, including the need to reconcile 

inventories with partner countries, stating that these reconciliations were 

unnecessary. State believes that implementing the recommendations, 

generally, would adversely impact U.S. commercial competitiveness in 

overseas markets and diminish U.S. influence to advance our 

nonproliferation objectives and cost jobs at home. DOE, however, now 

agrees in principle with several recommendations we directed to that 

agency according to a January 24, 2012, letter to us. For example, we 

recommended, among other things, that DOE, working with its 

interagency partners, develop formal goals and a systematic process to 

determine which foreign facilities to visit for future interagency physical 

protection visits. DOE informed us in the January 2012 letter that it is 

working with NRC, State, and other agencies to develop a new 

methodology and improve their efforts to set priorities for U.S. interagency 

physical protection visits. To that end, DOE has established regular 

interagency conference calls to coordinate upcoming visits and directed a 

national laboratory to establish a repository of information regarding past 

physical protection visits to assist in determining which sites to visit in the 

future and in what time frame to do so. 

Reducing the risks posed by vulnerable nuclear material worldwide 

requires a layered approach to protecting such material. As a first layer of 

defense, the United States has helped countries secure nuclear materials 

in place at civilian and defense facilities. As a second line of defense, the 

United States has also helped countries improve their border security to 

address the threat posed by nuclear smuggling. According to IAEA, there 

were 2,164 confirmed cases of illicit trafficking in nuclear and radiological 

materials worldwide from 1993 through 2011.

Agencies Face 

Challenges in 

Coordinating U.S. 

Efforts to Combat 

Nuclear Smuggling 

Overseas
 

Page 12 GAO-12-512T 

In December 2011, we reported on issues relating to the coordination of 

U.S. programs involved in combating nuclear smuggling overseas.15

However, we found impediments to the coordination of U.S. efforts to 

combat nuclear smuggling overseas. Specifically, we found that none of 

the existing strategies and plans for coordinating federal efforts to prevent 

and detect nuclear smuggling and illicit nuclear transfers overseas 

incorporate all of the desirable characteristics of national strategies, such 

as identifying the financial resources needed and monitoring mechanisms 

to be used to determine progress and make improvements. For example, 

the 2010 Global Nuclear Detection Architecture Strategic Plan—developed 

jointly by DHS, DOD, Energy, State, Justice, the intelligence community, 

and NRC—did not identify the financial resources needed to achieve the 

strategic plan’s objectives or the monitoring mechanisms that could be 

used to determine programmatic progress and needed improvements.

 We 

reviewed 21 federal programs and offices under five federal agencies—

NNSA, DOD, State, DHS, and the Department of Justice. These 

programs (1) conduct research and development on radiation detection 

technologies, (2) deploy radiation detection equipment along foreign 

borders and points of transit, (3) train and equip foreign customs and 

border security officials to identify and interdict illicit nuclear materials or 

technology transfers, (4) assist foreign governments in the development 

of export control systems, (5) enhance and coordinate with foreign 

antismuggling law enforcement and prosecutorial capabilities, and (6) 

analyze potential foreign nuclear smuggling cases and incidents.

We also identified potential fragmentation and overlapping functions

among some programs. Specifically, we identified six programs that 

provide training to improve the capabilities of foreign border security and 

customs officials to prevent smuggling and illicit nuclear shipments: (1) 

NNSA’s Second Line of Defense program, (2) International 

Nonproliferation Export Control Program, and (3) Cooperative Border 

Security Program,16

 

15GAO, Nuclear Nonproliferation: Action Needed to Address NNSA’s Program 

Management and Coordination Challenges, 

(4) State’s Export Control and Related Border 

GAO-12-71 (Washington D.C.:

Dec. 14, 2011).

16The Cooperative Border Security Program was an independent program at the time of 

our review on the coordination of federal programs involved in combating nuclear 

smuggling overseas. However, the program is no longer an independent program, and its 

functions were merged into the International Nonproliferation Export Control Program in 

June 2010.
 

Page 13 GAO-12-512T 

Security program, (5) DOD’s Weapons of Mass Destruction-Proliferation 

Prevention Program, and (6) International Counterproliferation Program. 

Similarly, we identified four programs that are involved in providing 

equipment to foreign governments to enhance the ability of their customs 

and border security organizations to detect nuclear smuggling: (1) 

NNSA’s Second Line of Defense program, (2) State’s Export Control and 

Related Border Security program, (3) DOD’s Weapons of Mass 

Destruction-Proliferation Prevention Program, and (4) DOD’s International 

Counterproliferation Program. In prior reports on nuclear nonproliferation 

programs, we have found that consolidating programs that share common 

goals and implement similar projects can maximize limited resources and 

may achieve potential cost savings or other programmatic and 

administrative efficiencies.

Agency officials representing these programs told us that not all of them 

have the same focus, that some concentrate on specialized niches, and 

that many are complementary. For instance, regarding the provision of 

equipment, NNSA, State, and DOD officials noted that the Second Line of 

Defense program tends to provide larger equipment, such as radiation 

portal monitors and cargo scanning equipment, while the Export Control 

and Related Border Security Program and International 

Counterproliferation Program provide smaller-scale equipment, such as 

hand-held radiation detection pagers, hazardous materials kits, and 

investigative suits to foreign customs and border security organizations. 

Nevertheless, in our view, the fragmented and overlapping nature of the 

programs raise questions as to whether greater efficiency could be 

obtained through possible consolidation of such efforts.

Furthermore, we found that no single federal agency has lead 

responsibility to direct federal efforts to prevent and detect nuclear 

smuggling overseas. In the past, we have reported that interagency 

undertakings can benefit from the leadership of a single entity with 

sufficient time, responsibility, authority, and resources needed to ensure 

that federal programs are based upon a coherent strategy and are well 

coordinated, and that gaps and duplication in capabilities are avoided.17

 

17See GAO, Combating Terrorism: Selected Challenges and Related Recommendations, 

For instance, State and DOD officials told us that neither State nor any 

GAO-01-822 (Washington, D.C.: Sept. 20, 2001); and Biosurveillance: Efforts to Develop 

a National Biosurveillance Capability Need a National Strategy and Designated Leader, 

GAO-10-645 (Washington, D.C.: June 30, 2010).
 

Page 14 GAO-12-512T 

other federal agency has the authority to direct the activities or coordinate 

the implementation of programs administered by other agencies involved 

in preventing or detecting nuclear smuggling overseas.

Regarding interagency coordinating mechanisms, NSC has established 

mechanisms to coordinate efforts in this area, including a Countering 

Nuclear Threats Interagency Policy Committee (IPC) and a sub-IPC for 

international nuclear and radiological border security efforts. NSC officials 

declined our request to discuss various aspects of the IPC structure and 

how it coordinates U.S. efforts to combat nuclear smuggling overseas. 

However, some officials from other agencies expressed doubts about the 

value of NSC’s coordinating role. Notably, DOD officials told us that they 

believed NSC has played a negligible role in coordinating programs to 

counter nuclear smuggling.

We made two recommendations to NSC to streamline and eliminate the 

potential for fragmentation and overlap among U.S. government 

programs involved in preventing and detecting the smuggling of nuclear 

materials overseas. Specifically, we recommended that NSC undertake or 

direct an appropriate agency or agencies to conduct a comprehensive 

review of the structure, scope, and composition of agencies and 

programs across the federal government involved in such efforts. Such a 

review should include, among other things, (1) the level of overlap and 

duplication among agencies and programs and (2) potential for 

consolidation to fewer programs and agencies. Following this review, new 

guidance should be issued that incorporates the elements of effective 

strategic plans, including clearly delineating the roles and missions of 

relevant programs, specific priorities, performance measures, overall 

program costs, and projected time frames for program completion. NSC 

did not respond to these recommendations.
 

Page 15 GAO-12-512T 

In 2007, we issued a report at the Subcommittee’s request focusing on the 

security of radiological sources overseas.18 In the course of that work we 

visited a number of hospitals and medical facilities in foreign countries and 

identified weaknesses in security. For example, in one country the security 

cable used to secure a teletherapy machine’s cobalt-60 source had been 

broken for almost a month. In another country, we observed that a storage 

facility containing devices with thousands of curies of cesium-137 had 

several unsecured large openings in the roof. Based on the findings in this 

report, the Subcommittee subsequently asked us to review the security of 

hospitals and medical facilities in the United States that use radiological 

sources. Hospitals and medical facilities in the United States are significant 

users of radiological sources contained in medical devices used primarily 

for cancer treatment and research. The amount of radiation emitted by the 

sources in these devices varies according to the size and type of source. 

For example, teletherapy machines contain a single cobalt-60 source 

ranging from about 1,000 to 10,000 curies, while irradiators can 

occasionally contain up to 27,000 curies or more of cesium-137. The 

following section provides our preliminary findings on our ongoing work.

 

18GAO, Nuclear Nonproliferation: DOE’s International Radiological Threat Reduction 

Program Needs to Focus Future Efforts on Securing the Highest Priority Radiological 

Sources, GAO-07-282 (Washington, D.C.: Jan. 31, 2007).

Agencies Have Taken 

Steps to Secure 

Domestic 

Radiological 

Materials, but Gaps 

Remain
 

Page 16 GAO-12-512T 

NRC, which is responsible for regulating the security of radiological 

sources in U.S. hospitals and medical facilities, issued a security order in 

2005 that directed licensees possessing radiological sources of concern 

to implement increased controls for access, detection and assessment, 

material shipments, physical barriers, information protection, and 

sensitive information.19

NRC’s security order and implementation guidance are broadly written 

and do not prescribe the specific steps that licensees must take to secure 

their sources. Rather, they provide a general framework for what 

constitutes adequate security practices. According to NRC, the intent of 

the increased controls is not to provide absolute security from theft or 

unauthorized access. Rather, the intent is to develop a combination of 

people, procedures, and equipment that will delay and detect an intruder, 

and initiate a response to the intrusion. In addition, the controls provide 

minimum requirements that a licensee must implement, and licensees 

may go beyond the minimum requirements. However, the ultimate 

responsibility for securing radiological materials in the United States rests 

with the licensees that possess these materials.

 NRC has relinquished jurisdiction for licensing 

and regulating radiological sources to 37 states called Agreement States, 

whose offices are typically administered by state health or environment 

departments, and which inspect licensees to ensure compliance with 

state regulations that are generally compatible with NRC regulations. The 

Department of Veterans Affairs and DOD, which maintain a network of 

hospitals and medical facilities in the United States, are also required to 

meet the NRC security order for radiological sources of concern at their 

facilities. 

 

19A licensee is a company, organization, institution, or other entity to which the NRC or an 

Agreement State has granted a general license or specific license to construct or operate 

a nuclear facility, or to receive, possess, use, transfer, or dispose of source material, 

byproduct material, or special nuclear material. Security orders contain requirements for 

licensees to implement, including interim compensatory security measures beyond that 

currently required by NRC regulations or licenses. Some of the requirements formalize a 

series of security measures that licensees took in response to advisories NRC issued in 

the aftermath of the September 11 terrorist attacks. NRC’s regulations impose 

requirements that licensees must meet in order to use nuclear materials or operate a 

nuclear facility. NRC has undertaken a rulemaking to promulgate regulations addressing 

the physical protection of byproduct materials. That rulemaking is currently under review 

by the Commission.

NRC’s Security 

Requirements Do Not 

Prescribe Specific 

Measures for Protecting 

Radiological Sources at 

Hospitals and Medical 

Facilities
 

Page 17 GAO-12-512T 

The security order directs that licensees limit access to radiological 

sources and develop a documented program to detect, assess, and 

respond to unauthorized access. The controls do not prescribe the types 

of physical security needed. It is up to the licensee to determine, for 

example, if security cameras are necessary or what types of locks or 

alarms are needed to secure doors or windows. For some locations, such 

as blood banks, requirements for access control can be met if the room 

where the medical device is located is staffed 24 hours a day, 7 days a 

week by an individual, or individuals, who are determined to be 

trustworthy and reliable. As long as the room is staffed at all times, the 

facility is not required to have any additional physical security, such as 

cameras or motion detection equipment. As a result, the only access 

control in place could be one or more staff members.

NRC also requires that hospitals and medical facilities verify the 

trustworthiness and reliability of individuals who are granted unescorted 

access to the medical devices containing radiological sources. The 

trustworthiness and reliability process requires that hospitals conduct a 

background check using information such as employment history, 

academic records, and other relevant information. It is ultimately the 

responsibility of the licensee to decide whether to grant the employee 

unescorted access. In 2007, NRC issued an additional security order 

requiring individuals employed at facilities containing highly radioactive 

sources to undergo fingerprinting with verification through the Federal 

Bureau of Investigation.

According to NRC officials, the requirements are intentionally broad to 

allow licensees flexibility to tailor security upgrades to their specific facility 

and operations. The ability to tailor security to a facility’s needs and 

resources is particularly important for commercial facilities with limited 

resources. For example, officials from smaller medical facilities told us 

that implementing specific security requirements—such as cameras and 

other surveillance equipment—could jeopardize their continued 

operations because of the costs associated with this equipment. NRC 

officials told us that given factors such as diverse economic conditions, 

facility type, layout, and operations of facilities, a “one size fits all” 

approach is neither practical nor desirable.

We found that the NRC controls have been implemented in a variety of 

ways in the hospitals and medical facilities we visited in seven states and 

District of Columbia. These approaches have created a mix of security 

controls and procedures that could leave some facilities’ radiological 

sources more vulnerable than others to possible tampering, sabotage, or 
 

Page 18 GAO-12-512T 

outright theft. At some locations, the controls resulted in significant 

security upgrades, such as the addition of surveillance cameras, 

upgrades to locks on doors, and alarms. In contrast, we observed minimal 

security in other facilities. Moreover, law enforcement personnel from 

states with significant amounts of high-activity radioactive sources at 

hospitals and medical facilities told us that the NRC controls have an 

inherent weakness: the controls do not specify what the facility is 

protecting against and are not linked to a design basis threat.20

All of the 25 medical facilities we visited have implemented the controls 

and undergone inspections by either NRC or Agreement State inspectors, 

but we observed a number of potential security weaknesses.

Typically, 

a design basis threat characterizes the elements of a potential attack, 

including the number of attackers, their training, and the weapons and 

tactics they are capable of employing. Although NNSA does not use a 

design basis threat for its security assessments of hospitals and medical 

facilities, it does employ a threat scenario (known as potential adversary 

capability) as the basis for its recommendations for security 

enhancements. According to a VA official, VA initially developed a generic 

threat scenario for use at its facilities with larger activity sealed 

radiological sources since NRC did not provide a design basis threat as 

part of the increased controls. Later, VA partnered with NNSA to 

implement security enhancements based on the NNSA threat scenario.

21

• At a hospital in one state, two cesium-137 research irradiators using 

approximately 2,000 curies and 6,000 curies, respectively, are housed 

in the basement of a building that is open to the public. The hallway 

leading to the irradiator room has a camera, but it is pointed away 

For 

example:

 

20NRC noted that, according to IAEA’s Nuclear Security Series Implementation Guide No. 

11, “Security of Radioactive Sources,” the design and evaluation of a security system 

should take into account the current national threat assessment and may include the 

development and application of a design basis threat, although it is not required.

According to IAEA, a design basis threat includes the attributes and characteristics of a 

potential insider and/or external adversaries, who might attempt unauthorized removal or 

sabotage, against which a physical protection system is designed and evaluated. 

21The 25 sites we visited are a non-generalizable sample, selected on the basis of the 

number of radiological devices in the state and the total number of cumulative curies 

contained in these devices in each state. In addition, we also considered if the site had 

undergone security upgrades funded by NNSA, and if the site is located in a large urban 

area. 
 

Page 19 GAO-12-512T 

from the room. The door to the room is opened by a swipe card lock, 

and there are no cameras or other security measures inside the room. 

We observed that one of the irradiators was sitting on a wheeled 

pallet. When we asked the radiation safety officer (RSO)—the 

designated hospital official responsible for the security of radiological 

sources—if he had considered removing the wheels, he said no. This 

response was given even though the irradiator room is located in 

close proximity to an external loading dock, and the cameras along 

the corridor to the loading dock are displayed on a single monitor. 

This facility had passed its most recent NRC security inspection 

because access to the room where the irradiators were located was 

restricted through use of a swipe card. However, it could be 

vulnerable because of the limited security we observed and the 

potential mobility of the device.

• At a hospital in a major U.S. city, we observed that the interior door to 

the hospital blood bank, which had a cesium-137 blood irradiator of 

approximately 1,500 curies, had the combination to the lock written on 

the door frame. The door is in a busy hallway with heavy traffic, and 

the security administrator for the hospital said that he often walks 

around erasing door combinations that are written next to the locks. 

According to NRC, a single lock is not necessarily a security 

weakness, however, they noted that writing combinations on the door 

is a weakness.

• The RSO at a university hospital in another state told us that he did 

not know the exact number of individuals with unescorted access to 

the hospital’s radiological sources, although he said that there were at 

least 500 people—the current data system does not allow for entering 

records of individuals beyond 500. In the past, he said, the hospital 

had as many as 800 people with unescorted access to sources. In 

contrast, at a major medical research facility at a military installation 

we visited, access was limited to 4 safety and security personnel.

• At a blood center in a third state we visited, we observed a cesium137 blood irradiator of approximately 1,400 curies in a room that was 

secured by a conventional key lock. The irradiator was located in the 

middle of the room and not secured to the floor. The room had an 

exterior wall with a bank of unalarmed and unsecured windows that 

looked out onto a loading dock. The blood center officials said that 

while they met the controls, they acknowledged that the center is 

highly vulnerable to theft or sabotage of their radiological sources. 

According to NRC, an irradiator sitting in the middle of the floor not 

bolted down is not necessarily vulnerable.
 

Page 20 GAO-12-512T 

Licensees are responsible for implementing the security requirements, 

including designing a security plan and implementing it. Implementation 

includes procuring and installing surveillance and alarm equipment that 

the licensees believe is adequate to protect the radiological materials in 

their facilities. However, many of the officials at the 25 hospitals and 

medical facilities we visited told us that they have backgrounds in 

radiological safety and facilities management and have limited security 

experience. Furthermore, none of these officials has been trained in how 

to implement the controls. For example:

• At another hospital we visited, the RSO said that when the controls 

were instituted in 2005, his new responsibilities included ensuring the 

security of a cobalt-60 gamma knife of approximately 2,600 curies and 

a cesium-137 blood irradiator of about 2,400 curies. He told us that he 

was not comfortable with his security role because his training was as 

a health physicist.22

• One facility manager who oversees the security for an approximately 

1,700 curie cesium-137 blood irradiator at a blood bank told us that he 

has a background in construction, not security. He said that it would 

have been helpful if NRC’s controls were more specific so that he 

would be in a better position to determine what security measures 

were necessary to adequately protect the device.

According to NRC, NRC and Agreement State inspectors receive training 

in security inspections. They also noted that only qualified inspectors can 

conduct security inspections. Qualification includes training and 

inspection accompaniments with qualified inspectors. However, some 

inspectors from NRC and Agreement States we interviewed told us that 

they do not feel comfortable conducting security inspections at hospitals 

and medical facilities, despite having received this training. For example, 

an NRC inspector said that security inspections were particularly difficult 

for her because she is trained as a physicist. She said that the controls 

were confusing, and she did not understand the nuances of security. An 

Agreement State inspector from another state we visited also told us that 

he was not qualified to do security inspections. However, he said that he 

 

22Health physics is a science concerned with recognizing and evaluating the effects of 

radiation on the health and safety of people and the environment, monitoring radiation 

exposure, and controlling the associated health risks and environmental hazards to permit 

the safe use of technologies that produce radiation.
 

Page 21 GAO-12-512T 

was doing the best he could to interpret the controls and help the 

licensees implement the requirements. Other inspectors from this state 

told us that they were placed in the awkward situation of having to 

enforce regulations that they did not believe they were fully qualified to 

interpret.

We also found that Agreement States lacked sufficient staff and adequate 

training to ensure the security of radiological sources, according to recent 

NRC reviews of two Agreement States’ inspection programs.23 For 

example, NRC’s review of one of the state’s radioactive materials 

program found that the program experienced significant turnover and that 

inspectors did not have an adequate understanding of the controls.

According to a state official, high staff turnover and the resulting lack of 

security experience affected the quality of their oversight. As a result, 

inspectors had difficulty assessing licensee compliance with the security 

requirements. According to NRC’s review of the other state’s radioactive 

materials program, the state’s newer inspectors would have benefitted 

from additional training on NRC’s security requirements. A state inspector 

told NRC that he did not understand the meaning of some of the 

documentation he was reviewing. Another state official stated that he was 

authorized to inspect a radiological device independently (without being 

accompanied by a more experienced inspector) before he was ready to 

do so. Furthermore, according to state officials, staff turnover has 

significantly affected the state’s timely follow-up of increased controls 

violations. NRC told us that they plan, based on the findings of these 

reviews, to take action in future reviews to remedy these problems.

According to NNSA, there are approximately 1,500 hospital and medical 

buildings in the United States —that they have identified—that contain 

high-activity radiological sources. NNSA also estimates that these 

buildings cumulatively contain about 22 million curies of radioactive 

material.24

 

23NRC’s Integrated Materials Performance Evaluation Program reviews Agreement State 

programs to ensure that they meet NRC’s standards. Since 2006, NRC has conducted 41 

reviews that contained reports on state’s performance regarding the inspection and 

licensing of the increased controls. Of the 41 reviews, 4 noted problems with how the state 

was implementing the increased controls.

One of GTRI’s components is the Domestic Material Protection 

24According to NNSA, this estimate reflects the amount of curies for the licensed 

maximum for each device. It does not reflect what the actual amount of curies may be, 

because curie levels diminish as the device is utilized.

NNSA Has Secured 

Radiological Sources at 

U.S. Hospitals and Medical 

Facilities
 

Page 22 GAO-12-512T 

program, which further improves security beyond NRC and Agreement 

State regulatory requirements at U.S. facilities with high-activity 

radiological sources, including hospitals and medical facilities.25

According to NNSA officials, as of December 2011, the program spent an 

estimated $96 million to secure radiological sources at 302 U.S. hospitals 

and medical facilities. The program plans to complete voluntary security 

upgrades at all 1,503 hospital and medical buildings it has identified as 

high-risk by 2025, at a projected cost of $608 million. NNSA officials told 

us that they estimate the average cost to upgrade a medical building has 

been $317,800.

This 

voluntary program provides, among other things, U.S. hospitals with 

security upgrades to the devices that contain high-activity radiological 

sources. It also provides training for hospital personnel and local police 

departments through its Alarm Response Training program at the Y-12 

National Security Complex in Oak Ridge, Tennessee. This training is 

designed to teach facility personnel and local law enforcement officials 

how to protect themselves and their communities when responding to 

alarms indicating the possible theft or sabotage of nuclear or radioactive 

materials. NNSA funds the cost of the security upgrades and training. 

However, the licensee is responsible for maintaining the security systems 

once the 3-to-5-year warranty period established by NNSA expires. 

NNSA officials told us that they estimated the average cost of maintaining 

the upgrades at each hospital was typically less than $10,000 per year. 

26 We plan to analyze these expenditures more fully 

during the course of our review.27

Of the 25 hospital and medical facilities that we visited in seven states 

and the District of Columbia, 13 have received GTRI upgrades and three 

were in the process of receiving the upgrades. Officials from most of the 

16 hospitals and medical facilities told us that GTRI’s program enhanced 

the security of their facilities. We observed a number of security upgrades 

at the facilities we visited, including remote monitoring systems, 

surveillance cameras, hardened doors, iris scanners, motion detectors, 

and tamper-proof alarms. NNSA has established criteria for determining 

 

25The upgrading of hospitals and medical facilities is one component of GTRI’s Domestic 

Material Protection program, which also secures high-activity radiological sources in other 

commercial facilities and sites.

26According to NNSA officials, training costs were excluded from the data. 

27These cost estimates are of undetermined reliability.
 

Page 23 GAO-12-512T 

which hospitals are eligible for assistance; it ranks facilities to be 

upgraded based on the relative risk of the radiological sources and 

expected risk reduction resulting from the planned GTRI activity. The 

criteria NNSA uses include the following: the attractiveness for theft or 

diversion of nuclear and radiological materials; existing site security 

conditions; threat environment; and location to a potential target, such as 

a large population center.

Some hospital officials and police department personnel told us that the 

GTRI program is limited because it is a voluntary program and because of 

the potential financial burden placed on hospitals and medical facilities to 

maintain the upgrades beyond the 3- to 5-year warranty period. We found 

that some hospitals have declined the upgrades, including hospitals 

located in high-risk urban areas. For example:

• At a blood bank in one of the states we visited with a cesium-137 

blood irradiator of approximately 1,400 curies, staff told us that NNSA 

was prepared to upgrade the bank’s security, but the blood bank 

decided not to participate because senior management wanted to wait 

until the blood bank moved to a new location, which it planned to do 

within the next 3 years. We observed that the blood irradiator 

appeared vulnerable—it was visible through an unalarmed and 

unsecured bank of windows overlooking an exterior loading dock. In 

February 2012, we contacted NNSA officials about this matter. As a 

result, NNSA and national laboratory officials met with the facility and 

developed a plan to secure the irradiator before the end of the fiscal 

year.

• According to police department officials from one major U.S. city, one 

hospital with a blood irradiator of approximately 1,700 curies has 

declined the GTRI upgrades, even though the police department 

considers it a high-risk facility. The hospital officials told us in 

February 2012 that they decided not to implement the GTRI upgrades 

because of concerns about maintenance costs associated with the 

security equipment after the NNSA-funded warranty period expired. 

The RSO said that the security the hospital has in place is adequate. 

Furthermore, the hospital is under serious budget pressure that 

makes it difficult to justify spending more money on protecting the 

sources.
 

Page 24 GAO-12-512T 

Under the GTRI program, NNSA also upgrades some smaller sources, 

such as those contained in brachytherapy devices.28

We are continuing to conduct our audit and plan to visit some additional 

medical facilities in the United States. We plan to issue our report later 

this year.

Typically, these 

devices contain between 10 and 15 curies of iridium-192. The curie level 

is not considered high enough to be subject to NRC’s security controls, 

but NNSA officials told us that the devices’ portability makes them a 

potential target for theft. NNSA officials stated that GTRI completed 

security upgrades at some sites before they considered including 

brachytherapy devices. GTRI is in the process of revisiting these sites 

and implementing security enhancements. We observed GTRI upgrades 

for brachytherapy devices at some hospitals, including a device that was 

put in a locked closet. However, we did visit one GTRI-upgraded facility 

where the security of the brachytherapy device had not been upgraded. In 

this facility, there were no security cameras monitoring the area, and in 

particular, there were no cameras in the room where the device was

located. Furthermore, access to the room was controlled by a wooden 

door with a padlock, and we observed a hospital official retrieve the key to 

the padlock from an unlocked desk immediately outside the door. Upon 

entering the room, we observed that the device was not secured to the 

floor, as required by the hospital’s own security protocol.

Chairman Akaka, Ranking Member Johnson, and Members of the 

Subcommittee, this completes my prepared statement. I would be 

pleased to respond to any questions you may have at this time.

If you or your staff have any questions about this testimony, 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 statement. GAO staff who made key contributions to 

this testimony are Glen Levis, Assistant Director; Jeffrey Barron; Alysia 

Davis; William Hoehn; Will Horton; and Michelle Munn.

 

28A brachytherapy device typically involves inserting radioactive material into the body 

near the treatment site.

GAO Contact and 

Staff 

Acknowledgements

(361387)
This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding decisions. 

GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO’s website (www.gao.gov). Each weekday afternoon, 

GAO posts on its website newly released reports, testimony, and 

correspondence. To have GAO e-mail you a list of newly posted products, 

go to www.gao.gov and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO’s website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, Twitter, and YouTube. 

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts. 

Visit GAO on the web at www.gao.gov. 

Contact:

Website: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-

4400, U.S. Government Accountability Office, 441 G Street NW, Room 

7125, Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations 

Public Affairs

Please Print on Recycled Paper.