U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON : 

For sale by the Superintendent of Documents, U.S. Government Printing Office

Internet: bookstore.gpo.gov Phone: toll free (866) 512–1800; DC area (202) 512–1800

Fax: (202) 512–2250 Mail: Stop SSOP, Washington, DC 20402–0001

34–410 PDF 2007

S. Hrg. 110–95

A REVIEW OF U.S. INTERNATIONAL EFFORTS

TO SECURE RADIOLOGICAL MATERIALS

HEARING

BEFORE THE

OVERSIGHT OF GOVERNMENT MANAGEMENT, 

THE FEDERAL WORKFORCE, AND THE DISTRICT 

OF COLUMBIA SUBCOMMITTEE

OF THE

COMMITTEE ON 

HOMELAND SECURITY AND 

GOVERNMENTAL AFFAIRS 

UNITED STATES SENATE

ONE HUNDRED TENTH CONGRESS

FIRST SESSION

MARCH 13, 2007

Available via http://www.access.gpo.gov/congress/senate

Printed for the use of the 

Committee on Homeland Security and Governmental Affairs

(

(II)

COMMITTEE ON HOMELAND SECURITY AND GOVERNMENTAL AFFAIRS 

JOSEPH I. LIEBERMAN, Connecticut, Chairman 

CARL LEVIN, Michigan 

DANIEL K. AKAKA, Hawaii 

THOMAS R. CARPER, Delaware 

MARK L. PRYOR, Arkansas 

MARY L. LANDRIEU, Louisiana 

BARACK OBAMA, Illinois 

CLAIRE McCASKILL, Missouri 

JON TESTER, Montana 

SUSAN M. COLLINS, Maine 

TED STEVENS, Alaska 

GEORGE V. VOINOVICH, Ohio 

NORM COLEMAN, Minnesota 

TOM COBURN, Oklahoma 

PETE V. DOMENICI, New Mexico 

JOHN WARNER, Virginia 

JOHN E. SUNUNU, New Hampshire

MICHAEL L. ALEXANDER, Staff Director 

BRANDON L. MILHORN, Minority Staff Director and Chief Counsel 

TRINA DRIESSNACK TYRER, Chief Clerk 

SUBCOMMITTEE ON GOVERNMENT MANAGEMENT, THE FEDERAL 

WORKFORCE, AND THE DISTRICT OF COLUMBIA 

DANIEL K. AKAKA, Hawaii, Chairman 

CARL LEVIN, Michigan 

THOMAS R. CARPER, Delaware 

MARK L. PRYOR, Arkansas 

MARY L. LANDRIEU, Louisiana 

GEORGE V. VOINOVICH, Ohio 

TED STEVENS, Alaska 

TOM COBURN, Oklahoma 

JOHN WARNER, Virginia

RICHARD J. KESSLER, Staff Director 

JENNIFER A. HEMINGWAY, Minority Staff Director 

EMILY MARTHALER, Chief Clerk 

(III)

C O N T E N T S 

Opening statements: Page 

Senator Akaka .................................................................................................. 1

Senator Voinovich ............................................................................................. 2

Senator Carper ................................................................................................. 23

WITNESSES

TUESDAY, MARCH 13, 2007

Richard J.K. Stratford, Director, Office of Nuclear Energy, Safety, and Security, U.S. Department of State ............................................................................ 5

Andrew Bieniawski, Assistant Deputy Administrator, Office of Global Threat 

Reduction, National Nuclear Security Administration, U.S. Department of 

Energy ................................................................................................................... 6

Janice Dunn Lee, Director, Office of International Programs, U.S. Nuclear 

Regulatory Commission ....................................................................................... 8

Gene Aloise, Director, National Resources and Environment, U.S. Government Accountability Office .................................................................................. 9

Brian Dodd, President, Health Physics Society .................................................... 17

Charles D. Ferguson, Fellow for Science and Technology, Council on Foreign 

Relations ............................................................................................................... 19

Joel O. Lubenau, Certified Health Physicist ......................................................... 21

ALPHABETICAL LIST OF WITNESSES

Aloise, Gene: 

Testimony .......................................................................................................... 9

Prepared statement .......................................................................................... 54

Bieniawski, Andrew: 

Testimony .......................................................................................................... 6

Prepared statement .......................................................................................... 38

Dodd, Brian: 

Testimony .......................................................................................................... 17

Prepared statement .......................................................................................... 69

Dunn Lee, Janice: 

Testimony .......................................................................................................... 8

Prepared statement .......................................................................................... 45

Ferguson, Charles D.: 

Testimony .......................................................................................................... 19

Prepared statement .......................................................................................... 74

Lubenau, Joel O.: 

Testimony .......................................................................................................... 21

Prepared statement .......................................................................................... 80

Stratford, Richard J.K.: 

Testimony .......................................................................................................... 5

Prepared statement .......................................................................................... 29

APPENDIX

Briefing Memorandum ............................................................................................ 89

International Atomic Energy Agency, prepared statement .................................. 99

Responses to questions submitted for the Record from: 

Mr. Stratford ..................................................................................................... 138

Mr. Bieniawski .................................................................................................. 143

Ms. Dunn Lee ................................................................................................... 150

Mr. Aloise .......................................................................................................... 153

Mr. Dodd ........................................................................................................... 155

Mr. Ferguson ..................................................................................................... 156

(1)

1The information from IAEA submitted by Senator Akaka appears in the Appendix on page 

101. 

A REVIEW OF U.S. INTERNATIONAL EFFORTS 

TO SECURE RADIOLOGICAL MATERIALS 

TUESDAY, MARCH 13, 2007

U.S. SENATE,

SUBCOMMITTEE ON OVERSIGHT OF GOVERNMENT

MANAGEMENT, THE FEDERAL WORKFORCE,

AND THE DISTRICT OF COLUMBIA,

OF THE COMMITTEE ON HOMELAND SECURITY

AND GOVERNMENTAL AFFAIRS,

Washington, DC. 

The Subcommittee met, pursuant to notice, at 2:36 p.m., in room 

SD–342, Dirksen Senate Office Building, Hon. Daniel K. Akaka, 

Chairman of the Subcommittee, presiding. 

Present: Senators Akaka, Carper, and Voinovich. 

OPENING STATEMENT OF CHAIRMAN AKAKA 

Chairman AKAKA. The Subcommittee on Oversight of Government Management, the Federal Workforce, and the District of Columbia will come to order. 

I called this hearing of the Subcommittee on Oversight of Government Management, the Federal Workforce, and the District of 

Columbia to review the U.S. international efforts to secure radiological materials, and we look forward to examining activities by 

the Department of Energy and the Nuclear Regulatory Commission 

to help secure high-risk radioactive sources worldwide, both bilaterally and in cooperation with the International Atomic Energy 

Agency (IAEA). We will also hear from the Health Physics Society 

about its work under the Radiation Safety Without Borders program. I would like to request unanimous consent to submit my 

written statement into the record, and I would also like unanimous 

consent to submit a written statement provided by the IAEA and 

an article by the former head of the IAEA’s program to secure radioactive sources, Dr. Abel Gonzalez, into the record.1

Our hearing seeks to address why funds to control high-risk radioactive sources are being cut out while interest by al Qaeda and 

other terrorist organizations in stealing them and making them 

into radiological dispersion devices, commonly known as ‘‘dirty 

bombs,’’ is increasing, not decreasing. I would like to lay out a scenario that illustrates my deep concern about these cuts. On March 

28, 2006, the Government Accountability Office testified before the 

Permanent Subcommittee on Investigations that GAO had conVerDate 0ct 09 2002 08:20 Jul 25, 2007 Jkt 034410 PO 00000 Frm 00005 Fmt 6633 Sfmt 6633 C:\DOCS\34410.TXT SAFFAIRS PsN: PAT
2

ducted an undercover operation to purchase two radioactive sources 

and transport them across two U.S. borders. I was disturbed to 

learn that GAO was able to use counterfeit documentation modeled 

after those found on the Internet and counterfeit bills of lading to 

purchase over the phone one of the most common radioisotopes 

used in industry. 

It was easy for GAO to get enough radioactive source material 

to manufacture a dirty bomb. These radioactive sources should concern all Americans, but what worries me more is how easy it is and 

it would be to conduct the very same operation in another country, 

one with fewer resources than we have to adequately control radioactive sources. What if this was an al Qaeda operative or Chechen 

rebel trying to obtain a source to use in a dirty bomb in the United 

States rather than a GAO investigation? 

Unfortunately, this is a very real possibility. There are documented efforts of terrorists trying to get these sources. Osama bin 

Laden has explicitly stated that acquisition of a nuclear weapon is 

a ‘‘religious duty.’’ The IAEA has documented 516 confirmed cases 

of trafficking or loss of highly radioactive sources. In contrast, the 

IAEA has documented 224 incidents involving nuclear materials, 

most of which involve natural or depleted uranium. 

A terrorist has three choice targets: 

First on the terrorist wish list is plutonium or highly enriched 

uranium; with this, a terrorist can make a nuclear bomb. Second 

on his wish list is nuclear material for an improvised nuclear device, or IND. Third is a radioactive source. 

The first two are hard to obtain; the third is widely available. It 

can be found in every hospital in the world with an X-ray machine. 

This is why I have convened this hearing today, and this is why 

I have asked GAO to examine this issue four times over the last 

4 years. The threat that an al Qaeda operative could steal a radioactive source from a hospital, for example, is very real. This is the 

bottom line: It is far easier to get a radioactive source than it is 

to steal highly enriched uranium or plutonium and detonate it in 

a nuclear weapon or improvised nuclear device. Detection equipment, as the GAO undercover operation revealed, does not deter 

anyone from acquiring material and transporting it. But detection 

is the last line of defense, not the first. 

And that is why I oppose the Administration’s proposed funding 

cuts to DOE to help ensure that these high-risk sources do not find 

their way into the United States. Nor has the Administration given 

the NRC enough funding to help strengthen regulatory control of 

these sources in other countries. The job is not finished and the 

threat is growing. Yet funding is being cut. The question is why? 

The purpose of this hearing is to answer that critical question. 

I want to thank our witnesses for being here today to discuss this 

critical issue. 

I will now turn to my good friend, Senator Voinovich, for his 

statement. 

OPENING STATEMENT OF SENATOR VOINOVICH 

Senator VOINOVICH. Thank you, Senator Akaka. I thank the witnesses for being here. 

3

Since 2002, over $143 million has been appropriated for the Department of Energy’s (DOE’s) International Radiological Threat Reduction Program to help other countries, including the Soviet 

Union, Indonesia, Iraq, and Mexico, secure dangerous radiological 

sources. 

Today we are holding this hearing to ensure that DOE and the 

other key responsible agencies, including the State Department 

and the NRC, are adequately performing their roles. 

In a tight Federal budget with demands for homeland security 

funding that far exceed the capacity of this Nation to furnish it, it 

is discouraging to learn that coordination, both within DOE and 

with other key agencies, is lacking. Also, it is frustrating to learn 

that DOE has consistently carried over a large balance of unspent 

and unobligated funds—that is something that you all ought to be 

concerned about—while the NRC’s biggest challenge has been identifying adequate and reliable funding support from other agencies. 

In a report being released at today’s hearing, the Government Accountability Office found that DOE did not transfer $5 million 

from its fiscal year 2004 appropriation to the NRC for strengthening international regulatory controls over radiological sources, 

despite a Senate Appropriations Committee report directing DOE 

to get that done. 

Now, Senator Akaka and I know that the Nuclear Regulatory 

Commission is paid for 10 percent by the Federal Government and 

90 percent by the people that are in the nuclear industry. So this 

is an extra task beyond what is in their budget, so this money has 

got to come over from the DOE. 

In addition, gaps in information sharing between DOE and the 

International Atomic Energy Agency have impeded DOE’s ability to 

target the most vulnerable sites in the International Atomic Energy Agency member States for security improvements. We have to 

work with the International Atomic Energy Agency. 

One of the chief concerns identified by GAO is that many dangerous radiological sources remain unsecured worldwide and that 

DOE may have focused limited program funding and resources on 

securing lower-risk, lower-priority facilities. DOE has not given sufficient attention to developing long-term sustainability plans to 

protect investments in security upgrades, and without such plans, 

investments to improve the security of radiological sources in many 

countries may be ineffective. 

We have been fortunate that no dirty bombs have been detonated 

by terrorists to date. However, confirmed reports of illicit trafficking in radiological materials has increased in recent years, as 

Senator Akaka outlined. Concerns have been raised about the potential for illicit use. 

My colleagues know that I have been a consistent advocate for 

managing risk and setting priorities in our homeland security policy. I have often warned that we cannot secure everything, and we 

would bankrupt our country if we tried. However, I believe the scenario of terrorist use of a dirty bomb has a sufficiently grave combination of threat, vulnerability, and consequences to justify a serious focus on this issue. 

A radiological dirty bomb could result in fatalities and serious 

health consequences as well as significant economic, psychological, 

4

and social disruption associated with the evacuation and subsequent cleanup of the contaminated area. The consequences resulting from a dirty bomb would be no less than that of an anthrax 

attack like we had 5 years ago that took five lives nationwide, requiring the testing of thousands of mailroom employees throughout 

the United States, and shuttered buildings around the city for 

months. Have we forgotten that? It is like it never happened. I remember it well because I was out of my office for about 3 months. 

Concerns about Federal agencies having to do a better job of 

prioritizing and coordinating with each other and securing domestic 

radiological materials arose soon after the terrorist attacks of September 11. That is why Senator Carper and I, as Chairman and 

Ranking Member of the Clean Air and Nuclear Safety Subcommittee of the Environment and Public Works Committee, sponsored the nuclear security provisions in the Energy Policy Act of 

2005. Among other things, those provisions required the NRC to establish a nationwide mandatory tracking system for the high-risk 

radioactive sources; two, establish additional controls on the import 

and export of radioactive sources, including background check requirements for individuals involved in import and exports shipments; and, three, establish a new interagency Task Force on Radiation Source Protection and Security. 

Mr. Chairman, perhaps we need to consider expanding some of 

these provisions, where appropriate, to help responsible agencies do 

a better job in securing dangerous radiological materials, both domestically and abroad. I am also intrigued by the GAO’s recommendation to provide NRC with the authority and direct appropriation to assist foreign regulators in developing regulatory infrastructure in lieu of providing funds from DOE. That is a more direct way of getting it done. 

I do understand that the international dimension of this program 

has added significant challenges, but clearly we cannot and should 

not do this alone. I would like to better understand the difficulties 

each agency is having in dealing with your international counterparts, including the IAEA, both in funding and programmatic cooperation. 

Thank you, Mr. Chairman, for having this hearing today. 

Chairman AKAKA. Thank you very much, my friend and Ranking 

Member, Senator Voinovich. 

And now I welcome our guests. They are Richard Stratford, Director, Office of Nuclear Energy, Safety, and Security, Department 

of State; Andrew Bieniawski, Associate Deputy Administrator, Office of Global Threat Reduction, National Nuclear Security Administration; Janice Dunn Lee, Director, Office of International Programs, U.S. Nuclear Regulatory Commission; and Eugene Aloise, 

Director, Natural Resources and Environment, Government Accountability Office. 

It is the custom of this Subcommittee to swear in all witnesses, 

and I would like to ask you all to stand and raise your right hand. 

Do you solemnly swear that the testimony you are about to give 

this Subcommittee is the truth, the whole truth, and nothing but 

the truth, so help you, God? 

Mr. STRATFORD. I do. 

Mr. BIENIAWSKI. I do. 

5

1The prepared statement of Mr. Stratford appears in the Appendix on page 29. 

Ms. DUNN LEE. I do. 

Mr. ALOISE. I do. 

Chairman AKAKA. Thank you. To all of you, we will include your 

full statements in the record, and I would like you, Mr. Stratford, 

to proceed with your statement. 

TESTIMONY OF RICHARD J.K. STRATFORD,1 DIRECTOR, OFFICE OF NUCLEAR ENERGY, SAFETY, AND SECURITY, U.S. 

DEPARTMENT OF STATE 

Mr. STRATFORD. Thank you, Mr. Chairman. Mr. Chairman and 

Senator Voinovich, thank you for the opportunity to speak to the 

topic of U.S. international efforts on radiological security and to explain the role of the Department of State in this important area. 

Radioactive sources are used throughout the world for numerous 

beneficial purposes, but they can also have malevolent uses. Ensuring access to these valuable technologies, while also ensuring the 

safe and secure management of radioactive sources, requires a balanced and a multilateral approach. 

The principal role of the Department of State in U.S. international efforts to secure radioactive material is the development 

and direction of U.S. foreign policy and the oversight of U.S. Government activities abroad. 

The missions and activities of the Department of Energy and the 

Nuclear Regulatory Commission are complementary and essential 

for implementing U.S. policy objectives. DOE has the resources and 

technical expertise for implementing on-the-ground radiological security work in foreign countries. NRC maintains the technical and 

legal expertise related to the licensing and control of radioactive 

sources. And, of course, State provides diplomatic support to the 

technical agencies, where needed. 

The Department of State has also taken a leadership role on developing, strengthening, and building support for international 

standards and instruments for the management of radioactive 

sources. The IAEA Code of Conduct on the Safety and Security of 

Radioactive Sources was revised in 2003 to incorporate post-September 11 security concerns. In 2004, the IAEA Guidance on the 

Import and Export of Radioactive Sources was developed and approved. 

Together, the Code of Conduct and the Guidance now represent 

the international benchmark for radiation protection authorities. 

The Department of State also supports and promotes IAEA programs that help member States evaluate and address gaps in their 

regulatory infrastructures. The Regulatory Authority Information 

System (RAIS), is a software platform which enables regulators to 

track radioactive sources, licenses, and qualifications of authorized 

users. Since 2003, the State Department has provided $1.4 million 

to the IAEA for training and for upgrading RAIS software. 

Mr. Chairman, I would also like to highlight the U.S. Government’s important work in Iraq and Ukraine. Now, if you are following my short written statement, you will see that I am skipping 

over the phrase ‘‘regionally in North America,’’ because I am going 

to cut that paragraph at the end. 

6

1The prepared statement of Mr. Bieniawski appears in the Appendix on page 38. 

With respect to Iraq, in 2004 the State Department led U.S. efforts to enhance radiological security in Iraq through the establishment of an effective regulatory authority to ensure a native capacity for locating and securing radioactive sources. The rapid standup 

of the Iraqi Radioactive Source Regulatory Authority, which was 

made possible by monies from the Department of State, maintained 

key search and recovery capabilities that were established during 

the Coalition Provisional Authority. Since that time, hundreds of 

missions to search for abandoned and vulnerable radioactive 

sources have been completed, including a recent sweep of Sadr 

City. 

Our Nonproliferation and Disarmament Fund (NDF) has also 

provided direct support to Ukraine to improve long-term security of 

high-risk radioactive sources through better accounting, training, 

and establishment of regional regulatory offices. The State Department considers the Ukraine project a success, and it was accomplished at about a quarter of the originally estimated cost. 

In closing, let me say that significant progress has been made by 

the United States to enhance control over radioactive sources 

around the world and to reduce the risk of their malicious use. This 

progress has been achieved through close coordination within the 

U.S. Government, but there is obviously more to be done. Continued success on international radiological security will require continued close collaboration among the key U.S. Government agencies 

in partnership with the international community. 

Thank you. 

Chairman AKAKA. Thank you very much. Mr. Bieniawski. 

TESTIMONY OF ANDREW BIENIAWSKI,1 ASSISTANT DEPUTY 

ADMINISTRATOR, OFFICE OF GLOBAL THREAT REDUCTION, 

NATIONAL NUCLEAR SECURITY ADMINISTRATION, U.S. DEPARTMENT OF ENERGY 

Mr. BIENIAWSKI. Thank you, Mr. Chairman and Senator 

Voinovich, for giving me the opportunity to testify on the Department of Energy’s efforts to secure and recover vulnerable, high-risk 

radioactive sources outside the United States. At the very outset, 

Mr. Chairman, I would like to thank you for your continued interest and leadership on this very important issue of securing vulnerable radiological sources. 

I am pleased to report to you that, since the inception of our program back in 2002, the Department of Energy’s International Radiological Threat Reduction Program has completed security upgrades at more than 500 sites in over 40 countries around the 

world. Radioactive sources such as cobalt, cesium, strontium, and 

americium, which are used worldwide for many legitimate purposes, could be exploited by terrorists to produce a radiological dispersion device, or dirty bomb. 

Our program’s primary objectives are threefold: First, to implement rapid physical security upgrades at vulnerable sites containing these sources; second, to locate, recover, and consolidate 

lost or abandoned high-risk sources; and, third, to support the deVerDate 0ct 09 2002 08:20 Jul 25, 2007 Jkt 034410 PO 00000 Frm 00010 Fmt 6633 Sfmt 6633 C:\DOCS\34410.TXT SAFFAIRS PsN: PAT
7

velopment of the infrastructure necessary to sustain these security 

enhancements that we are doing. 

Now, the intent of terrorists to acquire radioactive materials for 

use in an RDD does pose a significant risk to the American public 

and must be addressed. One of the many lessons learned from the 

attacks of September 11 is that some of the most common tools 

used in our daily lives, such as commercial airliners, can and will 

be used by terrorists in an attempt to wreak havoc on the United 

States. Should terrorists acquire and use these materials in an 

RDD, the psychological, physical, and economic impact could be significant. 

From various reports, we know that al Qaeda is known to be interested in acquiring the materials for a radiological weapon. We 

would add that in June 2005, Senator Lugar polled dozens of nonproliferation experts around the world, and the Lugar survey concluded that the probability of a radiological attack was twice as 

high as the probability of other WMD attacks using biological or 

nuclear materials. Therefore, given the reality of this situation, the 

Department of Energy, this Administration, and Congress have 

taken important steps to increase our radiological threat reduction 

efforts. 

So to address this threat, in 2004 the Department of Energy consolidated its radiological threat reduction efforts into a single central office called the Global Threat Reduction Initiative. GTRI is a 

vital part of the President’s National Security Strategy, and GTRI 

directly addresses and is implementing some of the recommendations of the bipartisan 9/11 Commission. 

The DOE and the National Nuclear Security Administration are 

committed to securing and removing vulnerable sources around the 

world. Over the past several years, we have significantly accelerated our efforts and secured more than 500 vulnerable radiological 

sources since 2002. In fact, I think it is very important to note that 

since our efforts first began back in 2002, we have accelerated 

these efforts each and every year. So each and every year we are 

doing more and more to address this very serious radiological 

threat. 

As of January 2007, DOE has spent approximately $120 million 

to secure these sources. This demonstrates a strong commitment 

and, from our perspective, a successful program that produces tangible results. 

Now, in terms of the GAO report, we are pleased that in the 

GAO report it was recognized that DOE has achieved noteworthy 

accomplishments by improving the security of radiological sources 

at hundreds of sites. The GAO report also highlighted several other 

key accomplishments under this program, and I would like to recap 

several of them. 

First, it noted that we had removed more than 5,000 curies of radioactive cobalt and cesium from war-torn Chechnya. We have removed nearly 1,000 high-risk sources from Iraq. We have created 

secure storage facilities in Uzbekistan and Georgia. We have removed or secured, in cooperation with our international partners, 

more than 30 percent of these high-powered RTGs in Russia. We 

have improved coordination with the Department of State and with 

the Nuclear Regulatory Commission. We have improved coordinaVerDate 0ct 09 2002 08:20 Jul 25, 2007 Jkt 034410 PO 00000 Frm 00011 Fmt 6633 Sfmt 6633 C:\DOCS\34410.TXT SAFFAIRS PsN: PAT
8

1The prepared statement of Ms. Dunn Lee appears in the Appendix on page 45. 

tion with the IAEA and several donor States to implement this program. These are excerpts straight out of the GAO report. And we 

have also developed successful bilateral cooperation. 

In closing, I would like to conclude by saying that we welcome 

this opportunity to focus attention on this very important and 

pressing issue. Thanks to your support, we have made significant 

progress to date to reduce the likelihood that terrorists will be able 

to acquire radiological sources. However, we fully agree, Mr. Chairman, that much work remains to be done, and we look forward to 

working closely with you in the future to continue to accelerate 

these efforts. Thank you. 

Chairman AKAKA. Thank you very much, Mr. Bieniawski. Ms. 

Dunn Lee. 

TESTIMONY OF JANICE DUNN LEE,1 DIRECTOR, OFFICE OF 

INTERNATIONAL PROGRAMS, U.S. NUCLEAR REGULATORY 

COMMISSION 

Ms. DUNN LEE. Thank you, Mr. Chairman and Ranking Member 

Voinovich. My name is Janice Dunn Lee. I am the Director of the 

Office of International Programs at the U.S. Nuclear Regulatory 

Commission. My office oversees and supports the NRC technical 

staff which participates in international assistance and cooperation 

activities. A high priority among these activities are efforts to create effective, sustainable regulatory oversight of radioactive sources 

worldwide. 

I would like to join my colleagues in thanking you for giving us 

this opportunity today to discuss NRC’s international efforts to enhance security of risk-significant radioactive sources. As requested, 

we provided prepared testimony for the record that describes in detail NRC’s activities in this area. At this time I will highlight key 

elements of this testimony, including addressing the recommendations contained in the recently released GAO report, which is the 

basis for this hearing. 

The Commission fully supports the recommendation made in the 

GAO report that Congress consider providing NRC with a direct 

appropriation to assist foreign nations in their regulatory oversight 

of risk-significant radioactive sources. NRC believes that the risk 

that some radioactive materials might be put to malicious use is 

still sufficient to warrant continued provision of international assistance. 

The NRC can be most effective in supporting the effort to control 

sources by having appropriated funds to implement its programs 

and to participate in the combination of bilateral and multilateral 

regulatory assistance efforts to continue to lower this risk. 

With effective planning and project management, continued reductions in risk can be achieved through modest investments in 

U.S. taxpayer funds. For example, an increase in non-fee-based 

funding for NRC, estimated at $2 to $3 million per year over the 

next few years, would allow NRC to expand ongoing efforts to create sustainable, effective national regulatory programs, integrating 

safety and security controls over these widely used sources. 

9

1The prepared statement of Mr. Aloise appears in the Appendix on page 54. 

As our written testimony reflects, NRC believes that international efforts to assist foreign nations in controlling risk-significant sources must be based on the Code of Conduct on the Safety 

and Security of Radioactive Sources. During development of the 

code, the NRC ensured that it was appropriately risk-informed, effective, realistic, and verifiable. Over a 2-year period, NRC led the 

world in implementing the code by revising our domestic regulatory 

programs, establishing a registry to meet the intent of the code, developing a National Source Tracking System, and enhancing import-export restrictions for risk-significant sources. 

Our international activities have paralleled those domestic efforts, primarily focusing on helping other countries to adopt and 

implement the code. Should Congress provide the modest increase 

in non-fee-based funding needed, these activities could judiciously 

be expanded. 

Specifically in the multilateral arena, NRC would work closely 

with the International Atomic Energy Agency to identify how best 

to support IAEA’s efforts to assist other countries to implement the 

code. The NRC could also consider, for example, stationing experts 

at the IAEA to strengthen and better coordinate regulatory assistance activities and directly funding high-priority IAEA regulatorystrengthening efforts. 

In the bilateral area, NRC could expand upon the success 

achieved and the experience gained working with our regulatory 

counterparts in Armenia, Georgia, and Kazakhstan. The NRC has 

reviewed these countries’ laws, which now authorize the regulators 

to implement the guidance of the code and include the ability to enforce regulations. NRC has also provided training for inspectors 

and assisted in the development of national registries of radioactive 

sources. With additional funding, NRC could consider work with 

our regulatory counterparts in the States of the former Soviet 

Union, similar to the work already achieved in Armenia and ongoing in Georgia and Azerbaijan. 

We would continue to devote a significant portion of available 

funding, typically over 60 percent, to utilize in-country technical 

expertise and resources needed to implement these projects. More 

broadly, the NRC would also consider working directly with regulatory authorities of key countries which import U.S.-manufactured 

sources to ensure that the highest resources are used safely and securely. 

Mr. Chairman and Mr. Voinovich, this concludes my statement. 

I would be happy to answer any questions you may have. Thank 

you. 

Chairman AKAKA. Thank you very much, Ms. Dunn Lee. Mr. 

Aloise. 

TESTIMONY OF GENE ALOISE,1 DIRECTOR, NATURAL RESOURCES AND ENVIRONMENT, U.S. GOVERNMENT ACCOUNTABILITY OFFICE 

Mr. ALOISE. Thank you. Mr. Chairman and Senator Voinovich, I 

am pleased to be here today to discuss our report, which addresses 

10

the progress DOE has made in securing high-risk sources in other 

countries. 

Since the program’s start in 2002, DOE has spent over $100 million to secure hundreds of sites in over 40 countries. However, 

some of the highest-risk and most dangerous sources remain unsecured. Specifically, 16 of 20 nuclear waste storage sites across Russia and Ukraine remain unsecured, and more than 700 portable 

generators, possibly containing the largest unsecured quantity of 

radioactivity in the world, remain operational or abandoned in Russia and are vulnerable to theft or misuse. 

In 2003, DOE decided to expand the program’s scope. In our 

view, this is where the program detoured from its original mission 

to secure the highest-risk and most dangerous sources. The program expanded to countries outside the former Soviet Union. It 

also expanded the types of sites that required security upgrades to 

include hospitals and oncology clinics. The sources in these medical 

facilities pose much less of a threat to our national security interests than higher-priority sources such as the portable generators 

and waste storage facilities. However, as of September 30 of last 

year, almost 70 percent of all sites DOE secured were medical facilities. 

While we understand that many of the portable generators cannot yet be removed, removing as many as possible or securing 

those that cannot be removed should be a critical component of 

DOE’s program. 

DOE has also experienced numerous problems and challenges 

implementing its program, including: some high-risk countries 

have been unwilling to cooperate in implementing security upgrades; some security upgrades have been poorly done and required 

additional funding to fix; and some countries lack adequately 

trained and equipped guard forces to respond to site alarms. 

Furthermore, DOE has not developed a long-term plan to sustain 

the upgrades it has installed. In fact, program officials told us that 

they believed upgrades would only be sustained in about 25 percent 

of the countries receiving assistance. 

Regarding coordination, although it has improved among DOE, 

NRC, and the State Department, it has been inconsistent and there 

is no comprehensive governmentwide approach to securing sources 

overseas. In addition, we found that DOE needs to better coordinate program activities within this program, as well as with other 

related DOE programs, to leverage financial resources. 

We believe that DOE’s reorganization of its nuclear and radiological threat reduction efforts is a step in the right direction. However, there are still significant management issues that need to be 

resolved and addressed. Our report makes several recommendations designed to improve the DOE’s program. 

Mr. Chairman, that concludes my remarks. I would be happy to 

respond to any questions you or Senator Voinovich might have. 

Chairman AKAKA. Thank you very much, Mr. Aloise. 

Mr. Bieniawski, you mentioned in your statement that there 

have been 500 sites DOE secured, which of those could be considered high priority? 

Mr. BIENIAWSKI. Yes, Mr. Chairman. All the sites that we have 

secured are considered high priority and contain vulnerable 

11

sources. Some of those are the high-powered RTGs in the Russian 

Federation. Some of those are medical sources that are vulnerable 

and exceed our minimum threshold of 1,000 curies. We believe you 

have to have a comprehensive approach and secure a range of 

sources, but all of those that we have secured to date are the highest priority. 

Chairman AKAKA. Mr. Bieniawski, DOE claims a number of successes in securing, as you have said, radioactive sources throughout 

the world. But as you know, there remain countless sites with 

sources that have not been secured, and terrorists are even more 

eager to steal them. 

Why then has DOE steadily reduced funding for this activity? 

Mr. BIENIAWSKI. Mr. Chairman, each and every year under this 

program, as I said in my oral testimony, we have accelerated our 

efforts. The first year, back in 2003, we just did eight sites. Then 

we did an additional 61 sites, then an additional 174 sites, and 

then last year an additional 257 sites. So we have been accelerating the program, and in order to continue the program, you are 

absolutely right, we need funds to make sure that we can accelerate. 

What I would like to note is that, regarding the fiscal year 2008 

budget request, in addition to the $6 million that we requested in 

2008, there is currently a supplemental request before Congress for 

a fiscal year 2008 supplemental for $20 million specifically for this 

program. 

In terms of what that will buy if Congress authorized an additional $20 million for our program, we will directly implement several of the recommendations from the GAO that you just heard 

about. We will recover an additional 45 of these high-powered 

RTGs in Russia. We will secure up to 10 radiological sites in China. 

We will secure an additional seven radiological sites in Pakistan. 

We will secure five vulnerable sites in Lebanon, three additional 

sites in Egypt, 10 sites in Turkey, and three additional sites in 

Kenya. 

So if the supplemental is funded, that would bring our funding 

level up in fiscal year 2008 to a total of $26 million for this program and enable us to secure at least an additional 85 vulnerable 

sources. 

Chairman AKAKA. Thank you. 

Mr. Aloise, will the recent reorganization of DOE’s program have 

a positive impact on DOE efforts to assist other countries to secure 

radiological sources? And if not, why not? 

Mr. ALOISE. Well, we think it is a step in the right direction, but 

it is too early to tell. We think the proof of whether it will be or 

not is if the program refocuses on securing the highest-priority 

sources, not just numbers of sources but the highest-priority 

sources, and not just numbers of sites but the highest-priority sites. 

Those include the generators we have talked about and waste storage sites. 

Chairman AKAKA. Mr. Bieniawski, would you please explain your rationale for not providing NRC with the $5 million as directed by 

the Senate Appropriations Committee report? 

Mr. BIENIAWSKI. Yes, sir. The detail on that situation is that 

back in fiscal year 2004—this was the fiscal year 2004 budget procVerDate 0ct 09 2002 08:20 Jul 25, 2007 Jkt 034410 PO 00000 Frm 00015 Fmt 6633 Sfmt 6633 C:\DOCS\34410.TXT SAFFAIRS PsN: PAT
12

ess—the $5 million proposed transfer was only in the Senate report. There was no mention of this $5 million transfer in the House 

report, so, therefore, it was an issue that had to be resolved in the 

conference negotiations for the final fiscal year 2004 budget process. 

During the conference negotiations, the House did not support 

the Senate position, and the Senate receded to the House. And, 

therefore, this was not in the final report. The Senate gave up on 

their initial request and, therefore, we were specifically directed 

not to transfer the $5 million to NRC. We checked at that time 

with our appropriators, and they confirmed that because this was 

not, as you know, in the final report, there was no requirement to 

transfer those funds and, therefore, we did not do so. 

Chairman AKAKA. I understand, Mr. Bieniawski, the rationale 

you have provided. However, I understand that DOE and the NRC 

had initially come to an agreement on providing the funding to 

NRC. Do you know why the agreement was not implemented? 

Mr. BIENIAWSKI. To clarify, NRC and DOE did have discussions 

regarding the possible transfer of DOE funds to NRC for international radiological security cooperation. However, no final agreement was reached with NRC due to the fact that since the specific 

NRC-related activities would be periodic and intermittent in nature, NRC could not dedicate full-time staff to support this effort 

and therefore it was mutually agreed not to continue further discussions on this matter. 

Chairman AKAKA. Ms. Dunn Lee, would you like to comment on 

that? 

Ms. DUNN LEE. I would be pleased to, Mr. Chairman. 

DOE and NRC have a mutual common goal of securing radioactive sources from potential theft and diversion. However, we 

come at these goals with different approaches. And when you put 

money in one agency to manage a program, I think there is a natural tendency to use money to support that agency’s approach. 

When funds are limited to begin with, the pot of money there 

really needs to be managed very carefully. And while we had a 

very good dialogue going on with DOE at the time, it was not workable because of the small streams of money that came in and that 

came in very prescriptively. We were asked to support work with 

specific tasks in specific countries, given specific time frames, with 

very little flexibility, and it is very inconsistent with our regulatory 

approach. And, therefore, we were unable to support some of the 

items that DOE had come up with, so it was a little bit unfortunate 

in that regard that we were not able to work out a mutual program 

to support our mutual goal, which is to secure these radioactive 

sources. 

Chairman AKAKA. Thank you. 

Mr. Aloise, GAO found that DOE does not have a strategy for 

sustaining its security upgrades. Did you determine why this is the 

case? 

Mr. ALOISE. Well, they have a 3-year warranty on their upgrades, and DOE has talked about that a lot. But as we got more 

into the program, we found out they had nothing beyond that to 

sustain these upgrades. And a lot of these sites that they have upgraded are private hospitals or oncology clinics. Moreover, many of 

13

these sites are in countries that are very strapped for cash, and it 

is not clear that the countries are going to be able to sustain the 

upgrades. So it is important that DOE develop a plan to do that, 

and as of yet, a long-term plan has not been developed. 

Chairman AKAKA. Mr. Bieniawski, would you want to comment 

on that? 

Mr. BIENIAWSKI. Yes, sir. As Mr. Aloise said, we do have a shortterm sustainability plan for 3 years where we provide maintenance 

over a 3-year period. We fully agree that we need to devote more 

attention to the long-term sustainability. Part of this is that if additional funds are made available through the supplemental, some 

of those funds can also be used to help us work to sustain this 

work in other countries. 

As a result of the GAO recommendation, we have set up an internal task force to look at the long-term sustainability. One of the 

things we do not want to do is just reinvent the wheel, and there 

is a lot of work that some of the other DOE programs have already 

done under our Material Protection Control and Accounting Program. So as part of this task force, we will be looking at what they 

have done, what can be applied to our upgrades, and we will be devoting more attention to this in the future. 

Chairman AKAKA. Well, thank you very much for your responses. 

I would like to ask Senator Voinovich for his questions. 

Senator VOINOVICH. Do you all agree that, based on threat assessment, this is a problem that we should be very concerned about 

relative to some other things? Everybody is nodding their head. 

[Laughter.] 

If it is, why aren’t we doing a better job? For example, Mr. 

Bieniawski, the GAO report cites a comment by senior DOE official 

who believed that there is still a significant amount of work to be 

done to secure radiological sources in the United States. What is 

DOE’s current estimate of the number of high-risk sources in this 

country that still need to be located and secured? If you can respond without disclosing sensitive information. And how does that 

compare with the number of sources outside of the United States? 

Mr. BIENIAWSKI. My program, GTRI, has several sub-elements. It 

has both an international program, which is the focus of the GAO 

report, and then also a domestic program. 

To answer the last part of your question first, in terms of additional sources outside the United States that need to be secured, 

we estimate that there are approximately 3,300 high-risk sources 

in other than high income economy countries that meet this minimum curie level of at least 1,000 curies that are near important 

U.S. strategic interests that need to be secured. So that is a number that we have surveyed, that we have good confidence in that 

number. 

In terms of the United States, what I would comment on and 

then see if the NRC would have additional comments, one of the 

programs we have under GTRI is securing what is called excess 

and unwanted sources here in the United States. These are sources 

that are no longer needed by industry. To date, we have recovered 

14,000 of those sources. 

To answer your question specifically, we estimate that each year 

we need to recover around 2,000 to 2,500 that become excess each 

14

year and are no longer needed by industry. And what we do under 

this program, which is our domestic radiological program, is we go 

and remove them and secure them at Los Alamos. 

So that is how I would answer that, but NRC might have some 

additional information. 

Senator VOINOVICH. Well, Ms. Dunn Lee, one of the security provisions in the Energy Policy Act of 2005 that I cosponsored requires 

the NRC to develop a National Source Tracking System to help secure high-risk radiological sources in the country. What is the status of this program? You were just talking about looking at it, but 

how are you coordinating? Are you using DOE’s information or are 

you using NRC’s information? How does that work? 

Ms. DUNN LEE. Senator Voinovich, yes, the NRC has a responsibility for developing the National Source Tracking System, and we 

have met the deadline in the Energy Policy Act to promulgate regulations. The final rule, which requires licensees to report inventories and transactions of Category 1 and 2 materials, was issued 

in November 2006. 

We expect the National Source Tracking System to be up and 

running—it is a big data system—by the end of 2008. In the meantime, we continue to use an interim database to meet its obligations for the registry under the requirements of the Code of Conduct. 

With regard to the recovery of orphan sources——

Senator VOINOVICH. Is that the Code of Conduct of the International Atomic Energy Agency? 

Ms. DUNN LEE. Correct, yes, which recommends that each country have a national registry of these radioactive sources. 

With regard to the recovery of orphan sources, it is primarily a 

DOE program, and we work together in this effort, but I would 

have to defer to the Department of Energy with respect to the data 

on the numbers of orphan sources around. The National Source 

Tracking System tells you what sources are under the jurisdiction 

of licensees. These are the known sources. It does not really account for the abandoned and orphan sources. 

Senator VOINOVICH. OK. Are the abandoned and orphan sources 

the result of activity of people that have been regulated by the Nuclear Regulatory Commission? 

Mr. BIENIAWSKI. Yes, the sources that are excess and unwanted 

are no longer needed by those licensees, and they go to a secure 

database, and they basically say that these sources are no longer 

needed and please have these sources removed because they are 

one step away from basically being orphaned or abandoned. 

Senator VOINOVICH. Your job is, as part of your Department, that 

when you have sources like this that are not used anymore——

Mr. BIENIAWSKI. Correct. 

Senator VOINOVICH [continuing]. Your job is to get rid of them? 

Mr. BIENIAWSKI. Yes, sir. 

Senator VOINOVICH. I was just thinking about something that I 

have written to Secretary Bodman about. We have the tailings of 

uranium at the Piketon facility in Ohio, USEC does, so that is just 

laying out there. 

Mr. BIENIAWSKI. Yes, sir. 

15

Senator VOINOVICH. And one of the things we want to do is see 

if DOE would be interested in removing the uranium from those 

tailings, which would make more uranium available and make it 

more likely that you could then get rid of it. 

Mr. BIENIAWSKI. Yes, sir. These sources that we recover are what 

we call sealed sources that are no longer needed. They are not the 

in-use ones, but they are actually sealed sources that we can then 

pick up and remove to Los Alamos or our Nevada test site. 

Senator VOINOVICH. You are talking about nuclear materials, 

what about radiological sources in hospitals? 

Mr. BIENIAWSKI. Well, some of these are from hospitals, but most 

of these are just licensed facilities that no longer need them. 

I think what you are getting at is what about all the sources that 

are still in use that are being used by hospitals, whether they are 

cobalt and cesium, and that is under the auspices of the NRC, to 

in-use sources. 

Senator VOINOVICH. GAO recommended Congress to authorize 

the NRC with direct authority, and a direct appropriation to help 

other countries develop regulatory infrastructure in lieu of providing funds to DOE and the State Department and then have 

these agencies reimburse NRC. I know from Ms. Lee’s testimony 

that NRC supports this recommendation. I would like to get the 

State Department’s and DOE’s positions on this proposal. 

Would this step enhance or further complicate policy efforts and 

coordination? 

Mr. STRATFORD. Senator, I do not have specific guidance on that 

issue, but I do have a view. Thirty years ago, when I was a junior 

lawyer, I was a legal assistant to one of the first NRC commissioners for 3 years, from 1975 to 1978. I was very impressed then 

with what the NRC could do, and 30 years later, today they are 

the premier nuclear regulatory organization in the world. They 

have a lot to offer in terms of boosting safety culture overseas and 

making life safer and more secure for all of us. 

In my judgment, it is passing strange for the NRC to have to go 

from agency to agency with a tin cup asking for donations so that 

they can do the very things that the State Department would like 

them to do. 

So in my personal judgment, yes, I think it would make sense 

for the NRC to have an appropriation that they could use to help 

boost safety and security around the world. 

Senator VOINOVICH. So they would not have to rely on money 

coming from DOE. They would have the money there to do it either 

by a direct appropriation or a charge-back. I suspect they would 

rather have the money than the charge-back. 

Mr. STRATFORD. Just as a matter of personal management, some 

bureaus maintain all funds in the front office, and if you are an office director and you want something, you have to go ask for it. 

Our bureau does not do it that way. I have a budget. I have a 

travel budget. I have a training budget. And it is allotted to me, 

and it is my job to figure out how to get the job done within what 

they give me. 

So, from my point of view, it makes more sense to have NRC 

have a budget that they know what they can do with instead of 

16

having to go begging for money whenever something makes sense 

for them to do it. 

Senator VOINOVICH. So they would have the money to do the 

identification and do the tracking that they supposedly do here and 

work with other countries that do it. 

Mr. STRATFORD. And provide training. 

Senator VOINOVICH. And provide training on how to handle the 

stuff. 

Mr. STRATFORD. That is right. 

Senator VOINOVICH. And in this country, DOE would have the responsibility to take care of disposing of the stuff that is not being 

used anymore, basically. I mean, in those countries where we have 

radiological materials which need to be disposed of, they get information from the NRC or from the International Atomic Energy 

Agency about how to do that? 

Mr. STRATFORD. Well, when you talk about sustainability, what 

you are talking about is a country’s ability to run a regulatory program, to run its own national registry, and to know how to go and 

pick things up safely and dispose of them safely. That is a matter 

of training, and nobody knows how to do that better in this country 

than the NRC. 

So should they go explain to other people how to have a successful program? In my judgment, yes, they should. Should they have 

the resources to do that? In my judgment, yes, they should. 

Senator VOINOVICH. Thank you. 

Chairman AKAKA. Thank you very much. 

Mr. Stratford, in recognition of the lower level of safety in the design and operation of Soviet-designed nuclear power plants and 

later the need to secure radioactive sources in the former Soviet 

Union, the State Department created a stand-alone office to provide policy guidance to DOE and NRC in their assistance efforts to 

these countries. However, over the last year or so, that stand-alone 

office was folded back into your office. 

What are you doing to ensure that the profile of these efforts to 

secure high-risk radioactive sources remains high? 

Mr. STRATFORD. Originally, the Department created a Senior Coordinator for Reactor Safety Assistance whose job it was to work 

with the DOE and the NRC to be sure that their activities in the 

safety assistance area were fully coordinated. That later evolved 

into what you described, which is a Senior Coordinator for Safety 

with an office to handle a number of different safety issues, including sources. 

In the last reorganization, which combined the Arms Control Bureau and the Nonproliferation Bureau, that office was handed over 

to me and combined with my office, I suppose because management 

felt that all of the peaceful nuclear issues, including safety, should 

be handled under the same management. 

I have inherited all of those people, with the exception of the 

former office director, who is now working in Vienna for the IAEA. 

The person who was deputy director I have left in charge of all the 

people that she brought with her. I have canceled no slots. I am 

letting them devote the amount of time they need to the radioactive 

source issue, which is three people full-time and two people parttime. I do not plan to change that. I may look at the situation in 

17

1The prepared statement of Mr. Dodd appears in the Appendix on page 69. 

terms of workloads in another year or so. But right now I think 

from a management point of view, the most important thing is to 

make those people feel comfortable, that they have not been relegated, that they have not been forgotten, that they still have a job 

to do and they are doing it for the person they were working for 

before. 

I think it is important to make them feel comfortable, I think it 

is important to let them do their job, and they are very highly 

qualified people, most of whom are Ph.D.s in hard science, which 

is a relatively rarity in the State Department. 

Chairman AKAKA. Let me finally ask you, Mr. Aloise, for your 

view on the State Department organization. 

Mr. ALOISE. Mr. Chairman, we really have not looked at that 

issue closely, so I cannot comment on that. 

Chairman AKAKA. Well, I want to thank you. I have further 

questions that I will submit for the record, but I want to thank you 

so much. You have been helpful, and we are all trying to do the 

same thing. It is to help our country do the best we can to secure 

our Nation. And I want to thank all of you very much for your part 

in doing this, and I look forward to working with all of you in the 

future. 

Thank you. 

I would like to ask our second panel of witnesses to come forward. Testifying are Dr. Charles Ferguson, Science and Technology 

Fellow at the Council on Foreign Relations; Dr. Brian Dodd, President, Health Physics Society; and Joel Lubenau, a Certified Health 

Physicist and former adviser to NRC Commissioner Greta Dicus. 

As you know, it is the custom of this Subcommittee to swear in 

all witnesses, so I ask all of you to raise your right hand. Do you 

swear that the testimony you are about to give to this Subcommittee is the truth, the whole truth, and nothing but the truth, 

so help you, God? 

Mr. DODD. I do. 

Mr. FERGUSON. I do. 

Mr. LUBENAU. I do. 

Chairman AKAKA. Thank you. Mr. Dodd, will you please begin. 

TESTIMONY OF BRIAN DODD,1 PRESIDENT, HEALTH PHYSICS 

SOCIETY 

Mr. DODD. Good afternoon. My name is Brian Dodd. I work as 

a consultant under BDConsulting, and I am also the President of 

the Health Physics Society. I want to thank you for holding this 

hearing and providing me with the opportunity to testify both personally and as the President of the Health Physics Society. 

Information about the society as well as my background and experience with the IAEA and as a consultant are detailed in my 

written testimony. However, I do need to clarify that I cannot 

speak for the IAEA and that I am still bound by my confidentiality 

agreement with them. 

Having been involved in the field of safety and security of 

sources before, during, and after September 11, I feel that we have 

achieved a great deal in the years since. As Americans, I believe 

18

we can be proud of our involvement in helping to secure dangerous 

sources around the world. I have no doubt that we are safer and 

securer now than we were then. That being said, there is still 

much to be done. 

Our initial efforts have focused on the high-risk sources, but as 

these are being dealt with and as we begin to address those with 

lower risks, the problems grow because their numbers increase by 

orders of magnitude. The first phase has largely been characterized 

by short-term outside assistance. We now need to transition to the 

point where local internal controls take over. 

The issue of self-reliance and sustainability has always been a 

basic objective of the IAEA. Programs that help countries develop 

their laws and regulations to implement the Code of Conduct contribute significantly in this regard. However, there are some fundamental difficulties that are often overlooked. 

First is the issue of priority. Bluntly, these countries do not see 

themselves as targets of terrorist activity using radioactive sources 

and have much more basic human needs to focus on. Should the 

government of a poor country spend its limited resources on source 

problems or provide running water and sanitation to a village? It 

is not that they do not care about RDDs, but they are pretty far 

down their list. To a certain extent, what we are trying to do is to 

impose our priorities and values on other countries. Sometimes we 

can gain short-term external conformance with our carrots and 

sticks, but clearly it is better that they have an internal will to address the issues. 

Second, there is the problem of personnel. The IAEA has been attempting to grow national expertise as part of its sustainability effort. However, it seems that it is taking much longer than anyone 

would have predicted. One of the major reasons is that as soon as 

a person becomes trained, he or she then leaves for a ‘‘better’’ position—often in another country where salaries and living conditions 

are much more desirable. It requires a high degree of self-actualization for a highly qualified person to continue to work in appalling conditions with little official government support. 

I believe that these issues of priority and personnel are the major 

impediment to building the national infrastructure and sustainability necessary to achieve the ongoing level of safety and security 

that we desire. However, we should not stop trying. 

In fact, one of the Health Physics Society’s efforts to address the 

personnel problem is our Radiation Safety Without Borders program. As a society of professionals, I think the best thing we can 

do to help build infrastructure and sustainability is to help our 

peers in developing countries. In the revitalized RSWB program, a 

Health Physics Society chapter links itself to a country, much like 

the sister city approach—for life. The chapter members will get to 

know the HPs in that country and how best to support them. 

The countries we are pairing with are those without a professional radiation safety society, with the ultimate objective of helping them develop their own. This will then become affiliated with 

the International Radiation Protection Association, perhaps via the 

stepping stone of forming a foreign HPS chapter. The desire is to 

help our fellow HPs get the same level of support that we receive 

from belonging to a high-quality professional organization. 

19

1The prepared statement of Mr. Ferguson appears in the Appendix on page 74. 

This program has the full support of the IAEA, the IRPA, and 

has the full knowledge of the State Department. 

It would be remiss of me not to mention the fact that the HPS 

has a position paper on radioactive source control. In particular, I 

would like to point out our recommendations regarding sufficient 

funding, No. 8, and making it an administrative mission to recover 

sources abroad, No. 16, instead of it being an ad hoc process. 

I hope you find these remarks helpful, and once again, I thank 

you for the opportunity to provide them in this hearing. I shall be 

pleased to answer questions as you desire. 

Chairman AKAKA. Thank you very much, Mr. Dodd. Mr. Ferguson. 

TESTIMONY OF CHARLES D. FERGUSON,1 FELLOW FOR 

SCIENCE AND TECHNOLOGY, COUNCIL ON FOREIGN RELATIONS 

Mr. FERGUSON. Thank you, Mr. Chairman. 

Several observations follow from an analysis of the radiological 

terrorism threat. First, we have to learn to live with a certain level 

of risk. We cannot and should not try to make the risk of radiological terrorism zero. Millions of people have derived great benefits from the use of radioactive sources. We have to learn to use radioactive sources more smartly, safely, and securely to reduce the 

risk as low as possible. 

Developing a safety and security culture takes many years. That 

is why we need a long-term sustainability plan that involves all 

countries. Governments, the radioactive source industry, and users 

of radioactive sources need to take ownership of the safety and security problems. This endeavor will require long-term concentrated 

effort to educate users, establish regulatory infrastructures where 

needed, improve existing regulatory agencies, and create public-private partnerships with industry. A public-private partnership 

would work toward finding alternatives to potent radioactive 

sources and replacing easily dispersible radioactive materials with 

hard-to-disperse materials. 

Users should have the opportunity to make an informed decision 

about whether to buy a non-radioactive alternative product or radioactive source. The purchase decision should include an assessment of the safety and security cost as well as the efficacy of the 

alternative product as compared to traditional radioactive sources. 

A number of applications have already substituted in non-radioactive alternatives, but more could be done in this area. The National Nuclear Security Administration, in particular, has a major 

role to play here. NNSA already has established a precedent in the 

nuclear security program to replace nuclear-weapons-usable highly 

enriched uranium with non-weapons-usable low-enriched uranium 

in research reactors. Similarly, I recommend that NNSA be given 

the mission and mandate to work with industry to identify, research, and develop suitable alternative replacement products for 

potent radioactive sources as well as to research, develop, and 

make available less dispersible radioactive materials in the marketplace. 

20

Unlike the several-billion-dollar nuclear security program the 

United States is funding along with international partners, a 

multi-billion-dollar program is not required to significantly reduce 

the radiological terrorism threat. With relatively modest amounts 

of funding over the past 4 to 5 years, NNSA has accomplished a 

substantial amount of security work, with much of that work being 

done in Russia as well as in 40 more countries. 

The NNSA program has provided the needed jump-start for 

many countries to improve their radioactive source security. What 

is needed now is development of a long-term sustainable program 

which can come about only with the full participation of all countries. For starters, I would recommend that the G–8 countries 

begin to identify how much money is required over the coming 

years to develop a sustainable program. Similar to what the United 

States did in 2002 at the G–8 Summit in starting the Global Partnership to deal with nuclear security and other weapons of mass 

destruction, I believe we have the opportunity to have a parallel 

program with radioactive source security. It will cost far less 

money, but I think we have yet to establish such a program among 

the G–8 countries, who are the major manufacturers of radioactive 

sources. 

I would like to just briefly touch on in my remaining time some 

of the other recommendations from my written testimony. 

Congress should require NNSA, the NRC, and other relevant 

government agencies to perform an urgent, comprehensive risk assessment of all types of radioactive sources. This assessment 

should be updated at least every 2 years and should evaluate the 

dynamical nature of the terrorism threat. 

A global problem requires a global solution. I commend Congress 

for giving NNSA, in October 2006, the mandate to seek and obtain 

international, monetary, and other contributions to counter the radiological threat. But as I said a little while ago, I think the United 

States can do more and should leverage international donations to 

help create a long-term sustainable program. Other countries 

should not continue to look to the United States to provide the bulk 

of these resources and money to develop these programs. It is everyone’s responsibility. 

The United States and partner governments should form publicprivate partnerships within industry to work vigorously toward 

phasing our production and use of easily dispersible radioactive 

materials. 

The radioactive source industry and the user community should 

internalize as many of the safety, security, and disposal costs in 

the price of commercial radioactive sources. 

And, finally, the Nuclear Regulatory Commission and regulatory 

agencies in other countries should encourage users to make an informed decision about whether to purchase a radioactive source or 

a non-radioactive alternative product. Such a decision should factor 

in all relevant costs, including security. 

Thank you, Mr. Chairman, for the opportunity to offer guidance 

on this important issue. 

Chairman AKAKA. Thank you very much, Mr. Ferguson. Mr. 

Lubenau. 

21

1The prepared statement of Mr. Lubenau appears in the Appendix on page 80. 

TESTIMONY OF JOEL O. LUBENAU,1 CERTIFIED HEALTH 

PHYSICIST 

Mr. LUBENAU. Mr. Chairman, thank you for your continuing interest in this subject, and also thank you for the opportunity to 

offer comments on this subject. My submitted testimony includes a 

brief historical overview of radioactive source safety and security in 

the submittal, and it should be noted that, with respect to history, 

concerns about accountability and control of radioactive sources 

pre-September 11. The submittal also discusses the setting of priorities and the need for long-term measures. With these considerations as background, the following recommendations are offered: 

One, the radioisotope thermal generators, the RTGs, in the 

former Soviet Union that are disused, have been abandoned, or 

lack security and continue to need priority attention. Priority attention also needs to be given to locating and securing mobile seed 

irradiators in the former Soviet Union. That said, other high-risk 

and lower-risk sources will also need attention. 

Two, improving security of radioactive waste repositories should 

receive priority attention. To not do so simply continues the risk 

when recovered radioactive sources are transferred to an unsecured 

waste repository. 

Three, DOE’s program to recover domestic radioactive sources 

posing safety and security risks is greatly needed. Over 14,000 

sources have been recovered in the United States to date. Another 

31,000 are projected to need recovery between now and 2021. 

Funding shortfalls have historically impacted this important program that does not include an overseas mission as well. Future 

competing, non-predictable priorities within the DOE should not be 

allowed to adversely affect this program, either domestically or 

internationally. 

Four, development of national regulatory infrastructures must 

include development of adequate continuing funding sources to sustain them. The NRC’s experience and that of the agreement States 

is a resource that should be utilized. To this end, neither NRC license fees nor interagency fund transfers should be utilized. Instead, Congress should directly fund NRC work in this area using 

general revenues. 

Last, long-term measures must become an integral part of national and international programs to improve radioactive source security. The lack of viable, affordable disposal paths for unused and 

unwanted sources has led to unplanned storage that increases their 

vulnerability to loss and theft. In the short-term, programs such as 

the DOE off-site source recovery program help to address this. In 

the long term, better solutions must be found for low-level radioactive waste disposal. 

We need to use radioactive sources more wisely than in the past. 

The IAEA, the National Academy of Sciences, the National Council 

on Radiation Protection and Measurements, the Health Physics Society, and numerous experts recommend developing and using safer 

chemical and physical forms of radioactive material in sources and 

alternatives to radioactive sources. These measures should be vigVerDate 0ct 09 2002 08:20 Jul 25, 2007 Jkt 034410 PO 00000 Frm 00025 Fmt 6633 Sfmt 6633 C:\DOCS\34410.TXT SAFFAIRS PsN: PAT
22

orously pursued. Public-private partnerships should be explored to 

advance these measures. 

Mr. Chairman, again, thank you for the opportunity to testify on 

this important subject. I will be glad to answer any questions that 

you and the Subcommittee Members may have. 

Chairman AKAKA. Thank you very much, Mr. Lubenau. I am so 

glad to see my friend Senator Carper here joining me, and I will 

ask three questions, and then I will call on you. 

I also note that Mr. Bieniawski has remained here, and I want 

to commend you for spending the time here. 

Dr. Dodd, you have testified that you are working to revitalize 

the Radiation Safety Without Borders program. How has this program been funded in the past and how do you plan to fund it in 

the future? 

Mr. DODD. Yes, Mr. Chairman, we had some funds from the Department of Justice. However, the emphasis on the program was 

more related to nonproliferation objectives, very much more of a review of some of the various countries’ Radiation Safety Regulatory 

programs. In my mind, the program was more determined by those 

considerations rather than the professional-to-professional considerations. My view is now that we need to help the people, the 

things that we were trying to do are better done by a government 

and government agencies. As a professional society, I believe the 

best thing we can do is help the people in a peer-to-peer type relationship with other professionals. 

It does not require a lot of funding. Frankly, we do not have nor 

asked for any additional funding from anyone to do this program. 

The idea is that each of the chapters will pair with the countries, 

and determine how best they can help that country. It might just 

be at the end of a phone call to provide some advice. Many of the 

chapters have a few thousand dollars perhaps to bring one of the 

key members of the regulatory agency from that country to the 

United States to a Health Physics Society meeting to see how to 

do professional society business. 

Certainly if we had some funding, we could do more country-tocountry visits, but I think almost everything else we can do without additional funding. A lot of it can be done electronically, 

through telephone and e-mail. 

Chairman AKAKA. Mr. Dodd, GAO has found that hundreds of 

radioisotope thermal generators remain unsecured in Russia. 

Mr. DODD. Yes. 

Chairman AKAKA. To your knowledge, has the IAEA been involved in securing such large, dangerous sources? And if so, why 

do you think so many of them remain unsecured? 

Mr. DODD. Well, the reason that we have RTGs is to provide electrical power in remote regions where there is none. So to start off 

with, they are in places in the world which are very remote. There 

are approximately 900 of them along the northern navigation route 

along the Arctic Circle north of Russia and so on. So they are in 

very remote, inhospitable places in the first place because that is 

what they do well. They provide power for such things as navigation beacons. 

The agency has certainly been working with many countries to 

improve the situation with regard to RTGs. In particular, Norway 

23

and Canada have helped. Norway, I believe, has helped recover 

probably on the order of several dozen RTGs back to MAYAK for 

reprocessing. 

Chairman AKAKA. Thank you. Let me call on Senator Carper for 

a statement or questions that he has. 

OPENING STATEMENT OF SENATOR CARPER 

Senator CARPER. What I would like to ask you to do is just—I 

do not care who goes first, second, or third, but I would like for 

each of you to respond to a couple of questions. 

I think a couple of you cited sustainability as one of the major 

problems with securing radioactive sources in other countries. For 

example, poor countries have to choose between some basic needs—

health care—as opposed to protecting radioactive sources. And, in 

addition, some poor countries have problems retaining personnel 

that have been trained to secure radioactive sources because they 

leave, I guess, for better positions once they are trained. 

What do you see as possible solutions that the United States 

alone and in conjunction with the international community could 

engage in to address these problems? I think you have spoken to 

this already in your testimonies, but I am going to ask you to take 

another shot at it, if you would, please. 

Whoever wants to go first. But I would appreciate a response 

from each of you. 

Mr. LUBENAU. Senator, thank you. I referred in my testimony to 

using the agreement States as a resource in this area. 

Senator CARPER. I am sorry. Say that again? 

Mr. LUBENAU. In my testimony, I suggest that using the agreement States—these are the States that have agreements with the 

NRC to regulate radioactive material—as a model because they 

have had funding problems in the past. And they are also smaller 

in size and thus more comparable to many of these countries. They 

have more in the way of shared experience in this area. 

But one common theme that has helped the States has been the 

collection of user fees, which is a large part of the support of the 

NRC program. And this would go a long way, I think, to solving 

funding problems. As Dr. Dodd and others have commented, we 

cannot keep handing out goodies. They have got to develop their 

own resources, not only in terms of training people but also retaining them. That takes providing decent salaries, and to that you 

need to have a fund available that can be depended upon to pay 

the salaries and also pay for the equipment and so on that will be 

required. 

Senator CARPER. Thank you. Dr. Ferguson. 

Mr. FERGUSON. Yes, Senator. I think my answer is threefold. 

I think we can draw on the IAEA’s program, the model project 

that has been around since the mid-1990s. They have worked with, 

I think, close to almost 100 countries now trying to improve the 

regulatory infrastructure. As I said in my oral remarks, it takes 

many years to develop a safety and security culture. You cannot 

turn around on a dime. But I think much more work can be done 

there. The IAEA has been cash-strapped. The U.S. Government 

and other governments have had a policy to keep the IAEA funding 

pretty much flat, and I think we need to—those countries that benVerDate 0ct 09 2002 08:20 Jul 25, 2007 Jkt 034410 PO 00000 Frm 00027 Fmt 6633 Sfmt 6633 C:\DOCS\34410.TXT SAFFAIRS PsN: PAT
24

efit the most from using radioactive sources and nuclear technology 

should contribute the most to the IAEA’s efforts to control those 

technologies. So that is one part of the answer. 

I think we also need to think through future use of radioactive 

sources. I said in my oral remarks that we need to think about alternatives to radioactive sources, and this is not any kind of antinuclear statement. There have been many applications—and Mr. 

Lubenau knows this much better than I do—that many applications have substituted in nonradioactive products that do the same 

job, but they do not have the safety and security risk that radioactive materials have. I do not think we can do this across the 

board. We need to think very carefully about applications and 

which ones can use substitutes. I think much more work can be 

done in research and development of those substitutes, and I would 

recommend that the Department of Energy and NNSA have a 

major role to play here. They have a lot of technical expertise at 

the National Laboratories, and I think they can be given the mission and the mandate to focus on the R&D question like they have 

been doing in terms of converting research reactors into using nonweapons-usable type of uranium. They have not had that mandate 

yet, and I would recommend that they get that. 

And then, finally, I want to just second what Mr. Lubenau said 

about user fees. The United States has been assessing user fees to 

try to take account of some of these costs, and I think we need to 

encourage other countries to continue to develop user fees as well. 

Senator CARPER. My time has expired, but, Dr. Dodd, would you 

just take a minute as well and respond to the question? Thank you. 

Mr. DODD. Yes. Very quickly, priorities—they are both big, difficult issues, which is why I raised them in the first place. It is interesting that the countries which have had an accident with a radioactive source, priorities are not a problem. It is nationally embarrassing for them to be seen as deficient, and they have put the 

resources into it. 

I hate to say that we should have an accident in every country, 

but that solves the problem to a certain extent. 

One of the issues, I think, is getting countries committed to the 

Code of Conduct because then that gives them the national impetus 

and desire to make that international commitment. 

When I was at the IAEA, one of the things we tried to do was 

to make it legally binding for that very purpose so that it would 

not be an option, that they would have to prioritize is. That, too, 

I think helps the personnel problem, that if the people have the 

backing and the will from the government to deal with the issue, 

then there is a certain amount of pride and respect that goes into 

doing that. And that is part of what our Radiation Safety Without 

Borders program is trying to do, too, is to provide the status to the 

professional to deal with the issue. 

But the personnel one is a very difficult one that has been ongoing for many years in lots of areas the agency is working on. I do 

not have any easy solutions, I am afraid. 

Senator CARPER. All right. Thank you, sir. Thank you all. 

Thanks, Mr. Chairman. 

Chairman AKAKA. Thank you. If you do not mind, we will go into 

a second round here. 

25

Dr. Ferguson, do you believe that DHS is taking the RDD threat 

seriously? 

Mr. FERGUSON. Mr. Chairman, if you are referring to the Department of Homeland Security, particularly their Domestic Nuclear 

Detection Office program, my concern is they have competing priorities. I think they are trying to do too much for the technologies 

they have right now. They are trying to solve the nuclear bomb 

problem and the dirty bomb problem. My understanding as a physicist, as a scientist, looking at the radiation detection capability 

today that they have, I would recommend to them to prioritize the 

dirty bomb problem. It is far more likely—I agree with everything 

you said in your opening statement, sir, that it is far more likely 

that a dirty bomb would occur, even though it is not nearly as damaging as a nuclear bomb. But the thing with our technologies now 

is we can detect the highly radioactive materials, and it is very difficult to detect the nuclear materials that would go into an actual 

nuclear weapon. So I would recommend shifting priorities at DHS 

in that program. 

Chairman AKAKA. Dr. Ferguson, what, in your opinion, is a 

greater threat to the United States: A terrorist organization acquiring highly enriched uranium or plutonium, or stealing a radioactive 

source? 

Mr. FERGUSON. Mr. Chairman, it is really hard to decide between 

the two. In my written comments, I said experts agree in terms of 

the likelihood and the consequences, and I think there is this tension right now—we see it being played out in the government—how 

we should devote our resources to dealing with these two very important threats. 

I do not think it is either/or. I think we need to try to find a way 

to tackle both of these threats. Fortunately, the dirty bomb threat 

requires far less money to deal with than the nuclear bomb threat. 

Chairman AKAKA. Yes. Do you believe that the threat of a dirty 

bomb attack in the United States is greater or lower than the time 

just after the September 11 attack? 

Mr. FERGUSON. Mr. Chairman, I think a dirty bomb threat is, I 

think, greater post-September 11 than it was pre-September 11, although we did see evidence from al Qaeda pre-September 11 that 

they were trying to get their hands on material for a nuclear bomb 

or a dirty bomb. But I think we have seen just a recent upsurge 

of criminal and terrorist interest in the radiological terrorism 

threat. 

Chairman AKAKA. Mr. Lubenau, based on your knowledge of the 

Nuclear Regulatory Commission, do you believe that the NRC has 

adequate resources to help secure radioactive sources internationally? 

Mr. LUBENAU. Mr. Chairman, the resources may involve funding. 

Resources include staffing. It also involves the ability to engage in 

travel if NCR is going to do international work. 

I think the NRC has done its best to obtain the necessary resources. That has been my experience when I was there. But they 

are also very mindful of overall Federal budget constraints. They 

are also mindful of the fact that work in this area does not directly 

relate to the regulation of the users, and the users’ fees to a large 

part in the past have had to be used for this purpose. 

26

That is why, for example, the direct funding of additional work 

by the NRC using general revenues presumably is a better alternative than either using the user fees or seeking those funds from 

other agencies. To me that is the key issue. Once the funding is 

made available, then it is a matter of deciding where to apportion 

the funding for the resources that are needed. 

Chairman AKAKA. I was asking about international funding. Do 

you believe the NRC has been effective in securing sources internationally? 

Mr. LUBENAU. The NRC is not directly involved in that. What 

they have done and continue to do is to work with the IAEA, the 

State Department, and the DOE to support programs—the IAEA 

programs, the DOE programs—to recover and secure radioactive 

sources. But the NRC does not directly go out and recover the 

sources, nor does it operate or provide equipment, for example, to 

secure the repositories where the sources are taken to. That is a 

responsibility that lies with the host governments. But in terms of 

direct engagement, that is not an NRC function—at least in my experience when I was there. 

Chairman AKAKA. Mr. Lubenau, do you believe that the NRC has 

been effective—I have asked you that. Do you believe that the NRC 

is well suited to help other countries strengthen control over 

sources? 

Mr. LUBENAU. I think the testimony before by Mr. Stratford that 

the NRC is recognized as the premier regulatory agency in the 

world, I would agree with that assessment. And it does serve as a 

model for other countries, and I think they are well positioned to 

provide assistance or advice to other countries in developing their 

programs. 

Chairman AKAKA. Do you believe that the Commission has made 

this initiative a priority and afforded it adequate resources? 

Mr. LUBENAU. To the extent—and I realize I am throwing this 

back to the Congress—to the extent that funds have been made 

available by Congress, my answer would be yes. 

Chairman AKAKA. Well, I thank you all for your responses. Especially I thank those who have traveled from out of town to come 

here for this hearing. 

Mr. LUBENAU. I do not travel as far as you, though. [Laughter.] 

Chairman AKAKA. Your testimony, again, has been very informative and in a sense somewhat disturbing. It has also served to remind all of us that the threat of dirty bombs has not gone away. 

This is the disturbing part. These sources were not adequately secured, as you know, continue to be a risk to the safety and security 

of this country, and also to the rest of the world. It is inexcusable 

that sufficient funding for DOE and NRC activities to secure radioactive sources internationally is not being made available. Al 

Qaeda’s desire to acquire a radioactive source and to fashion it into 

a dirty bomb to inflict destruction upon the American people, or the 

people of any country, has not waned and has not dissipated. In response, our efforts cannot wane. Attention to these critical efforts 

cannot be diverted either. 

It is, therefore, my intention, as a member of the Energy Committee as well as Chair of this Subcommittee, to press for sufficient 

funding for both DOE and NRC to continue their valuable efforts 

27

to help other countries secure radioactive sources. I will also continue to highlight the need to secure these sources both here in the 

United States and around the world. 

Again, I thank you very much for being here and for providing 

the information you have. The hearing record will be open for 1 

week for additional statements or questions that other Members 

may have. 

Again, thank you very much, and this hearing is adjourned. 

[Whereupon, at 4:12 p.m., the Subcommittee was adjourned.] 

(29)

A P P E N D I X 


34410.001
30


34410.002
31


34410.003
32


34410.004
33


34410.005
34


34410.006
35


34410.007
36


34410.008
37


34410.009
38


34410.010
39


34410.011
40


34410.012
41


34410.013
42


34410.014
43


34410.015
44


34410.016
45


34410.017
46


34410.018
47


34410.019
48


34410.020
49


34410.021
50


34410.022
51


34410.023
52


34410.024
53


34410.025
54


34410.026
55


34410.027
56


34410.028
57


34410.029
58


34410.030
59


34410.031
60


34410.032
61


34410.033
62


34410.034
63


34410.035
64


34410.036
65


34410.037
66


34410.038
67


34410.039
68


34410.040
69


34410.041
70


34410.042
71


34410.043
72


34410.044
73


34410.045
74


34410.046
75


34410.047
76


34410.048
77


34410.049
78


34410.050
79


34410.051
80


34410.052
81


34410.053
82


34410.054
83


34410.055
84


34410.056
85


34410.057
86


34410.058
87


34410.059
88


34410.060
89


34410.061
90


34410.062
91


34410.063
92


34410.064
93


34410.065
94


34410.066
95


34410.067
96


34410.068
97


34410.069
98


34410.070
99


34410.073
100


34410.074
101


34410.075
102


34410.076
103


34410.077
104


34410.078
105


34410.079
106


34410.080
107


34410.081
108


34410.082
109


34410.083
110


34410.084
111


34410.085
112


34410.086
113


34410.087
114


34410.088
115


34410.089
116


34410.090
117


34410.091
118


34410.092
119


34410.093
120


34410.094
121


34410.095
122


34410.096
123


34410.097
124


34410.098
125


34410.099
126


34410.100
127


34410.101
128


34410.102
129


34410.103
130


34410.104
131


34410.105
132


34410.106
133


34410.107
134


34410.108
135


34410.109
136


34410.110
137


34410.111
138


34410.112
139


34410.113
140


34410.114
141


34410.115
142


34410.116
143


34410.117
144


34410.118
145


34410.119
146


34410.120
147


34410.121
148


34410.122
149


34410.123
150


34410.124
151


34410.125
152


34410.126
153


34410.127
154


34410.128
155


34410.129
156


34410.130
157


34410.131
158

Æ


34410.132