Report to Congressional Committees

United States Government Accountability Office

GAO 

NUCLEAR SECURITY

Better Oversight 

Needed to Ensure 

That Security 

Improvements at 

Lawrence Livermore 

National Laboratory 

Are Fully 

Implemented and 

Sustained 

March 2009

GAO-09-321 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

March 2009

NUCLEAR SECURITY

Better Oversight Needed to Ensure That Security 

Improvements at Lawrence Livermore National 

Highlights of GAO-09-321, a report to Laboratory Are Fully Implemented and Sustained 

congressional committees 

In April 2008, the Department of 

Energy’s (DOE) security inspection

at Lawrence Livermore National

Laboratory (LLNL) found 

significant weaknesses, particularly

in LLNL’s protective force’s ability

to assure the protection of

weapons-grade (special) nuclear 

material. LLNL is overseen by the 

National Nuclear Security

Administration (NNSA), a 

separately organized agency within 

DOE, and managed by a contractor. 

NNSA is planning to remove most 

of the special nuclear material from

LLNL. GAO was asked to (1) 

characterize security deficiencies 

identified in the 2008 inspection; 

(2) determine the factors that 

contributed to these deficiencies;

(3) identify LLNL’s corrective 

actions to address security

deficiencies; and (4) assess LLNL’s 

plan to permanently remove the 

riskiest special nuclear material 

from its site. To conduct this work,

GAO visited LLNL, reviewed

numerous documents and plans,

and interviewed LLNL and NNSA 

security officials. 

What GAO Recommends

GAO recommends that the 

Administrator of NNSA improve 

and sustain federal oversight of

security at LLNL by (1) developing 

a detailed plan and budget for 

training NNSA’s Livermore Site 

Office (LSO) security staff and (2) 

providing financial incentives to 

LLNL’s contractor to sustain 

security improvements. NNSA 

generally agreed with the report’s

findings and recommendations.

DOE’s Office of Independent Oversight found numerous and wide-ranging 

security deficiencies with LLNL’s safeguards and security program. DOE gave 

the laboratory the lowest possible rating in two security areas: protective 

force performance and classified matter protection and control. The Office of 

Independent Oversight also reported that LLNL’s physical security systems, 

such as alarms and sensors, and its security program planning and assurance 

activities needed improvement. 

Weaknesses in LLNL’s self-assessment program and LSO’s oversight 

contributed to security deficiencies at the laboratory. LLNL’s security selfassessment program and LSO’s annual security survey failed to identify 

numerous security deficiencies before DOE’s Office of Independent Oversight 

conducted its inspection. According to one DOE official, both programs were 

“broken” and missed even the “low-hanging fruit” of compliance-oriented 

deficiencies. More specifically, LLNL’s self-assessment program should have 

identified the magnitude of technical problems with a key weapon system 

used at the laboratory. Furthermore, LSO’s September 2007 security survey

gave LLNL 100-percent satisfactory ratings in its security performance—

differing markedly from the security performance DOE observed during its 

inspection a short time later. To address these issues, LSO is implementing a

new program to better train security officials to perform security assessments 

and recognize deficiencies; however, according to LSO officials, LSO does not 

have a specific budget to implement this new security training program. 

LLNL has developed corrective action plans to address the 54 security 

deficiencies identified by the Office of Independent Oversight, and both NNSA

and DOE will oversee the plans’ implementation. As of December 2008, LLNL 

reported having completed 74 percent of the milestones included in corrective 

action plans to address physical security deficiencies. DOE plans to reinspect LLNL in April 2009 and focus on the effectiveness of corrective 

actions. In the past, LLNL has not sustained corrective actions to address 

similar security deficiencies. For example, in 1999 DOE reported that LLNL’s 

capability to conduct vulnerability assessments was deficient. By 2000, this 

problem had been corrected. In 2008, DOE again noted deficiencies in LLNL’s 

vulnerability assessment capability. NNSA has the opportunity to use its new 

performance-based management and operating contract to hold LLNL’s 

contractor financially accountable for ensuring that security improvements 

resulting from corrective actions are sustained. 

The plan to remove most of LLNL’s special nuclear material by the end of 

fiscal year 2012 faces challenges because the plan’s schedule depends on a 

number of factors, some of which LLNL does not control, such as the 

willingness and ability of other NNSA and DOE sites to receive the material, 

the timeliness of the effort, adequate funding, and the availability of 

specialized transport trucks operated by NNSA’s Office of Secure 

Transportation to transfer material to other DOE sites. 

To view the full product, including the scope 

and methodology, click on GAO-09-321.

For more information, contact Gene Aloise at 

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

Letter 1

Background 4

DOE’s Office of Independent Oversight Identified Several 

Significant Weaknesses in LLNL’s Safeguards and Security 

Program 7

A Weak Laboratory Self-Assessment Program and Insufficient 

Federal Oversight Contributed to Security Deficiencies at LLNL 12 

LLNL Has Developed Corrective Action Plans to Address 54 

Identified Security Deficiencies, and Both NNSA and DOE Will 

Oversee Their Implementation 18 

LLNL Faces Challenges in Implementing Plans to Complete Deinventory of Its Category I and II Special Nuclear Material by the 

End of Fiscal Year 2012 27 

Conclusions 29

Recommendations for Executive Action 30 

Agency Comments and Our Evaluation 30 

Appendix I Safeguards and Security Topics Covered in Office of 

Independent Oversight Inspections 32 

Appendix II Comments from the National Nuclear Security 

Administration 34 

Appendix III GAO Contact and Staff Acknowledgments 36 

Tables 

Table 1: LLNL Security Deficiencies Identified by the Office of

Independent Oversight, by Topical Area, April 2008 8 

Table 2: LLNL’s Required Protective Force Performance Assurance 

Testing 14

Figures 

Figure 1: LLNL Corrective Action Milestones by Security Topic, as 

of December 2008 19 

Page i GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
Figure 2: Timeline for the Development and Final Approval of 

LLNL’s Corrective Action Plans 23 

Abbreviations 

DBT design basis threat 

DOE Department of Energy 

LLNL Lawrence Livermore National Laboratory 

LLNS Lawrence Livermore National Security, LLC 

LSO Livermore Site Office 

NNSA National Nuclear Security Administration 

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Page ii GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
United States Government Accountability Office

Washington, DC 20548 

 

March 16, 2009

The Honorable Henry A. Waxman 

Chairman 

The Honorable John D. Dingell 

Chairman Emeritus

The Honorable Joe Barton 

Ranking Member 

Committee on Energy and Commerce 

House of Representatives 

The Honorable Bart Stupak 

Chairman 

The Honorable Greg Walden 

Ranking Member 

Subcommittee on Oversight and Investigations 

Committee on Energy and Commerce 

House of Representatives 

The Department of Energy (DOE) has long recognized that a successful 

terrorist attack on a site containing nuclear weapons or the fissile material 

used in nuclear weapons—called special nuclear material—could have 

devastating consequences for the site and its surrounding communities. 

Lawrence Livermore National Laboratory (LLNL), located in Livermore, 

California, is one of three national laboratories responsible for designing, 

developing, and maintaining a safe, secure, and reliable nuclear weapons 

deterrent.1

 For these and other missions, LLNL stores and uses special 

nuclear material. Special nuclear material—including plutonium and 

highly enriched uranium—is considered to be Category I when it is 

weapons-grade and in specified forms and quantities. The risks associated 

with Category I special nuclear material vary but include theft, and the 

potential for sabotage in the form of radiological dispersal, also known as 

a “dirty bomb.” Because of these risks and LLNL’s location in California’s 

densely populated San Francisco Bay area, NNSA decided in October 2007 

 1

The other design and development laboratories are Los Alamos National Laboratory in Los

Alamos, New Mexico, and Sandia National Laboratories in New Mexico and California.

Page 1 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

to permanently remove, or “de-inventory,” all Category I nuclear material 

from LLNL.2

LLNL is overseen by the National Nuclear Security Administration 

(NNSA), a separately organized agency within DOE. DOE’s and NNSA’s 

safeguards and security program develops policies essential for preventing

an unacceptable, adverse impact on national security. To manage potential 

risks, DOE has developed a classified policy that identifies the potential

size and capabilities of terrorist forces against which facilities containing 

Category I special nuclear material—which at LLNL is the “Superblock”

facility—must be prepared to defend.3

 Additionally, LLNL must adhere to 

other DOE security requirements on the effective protection of classified 

assets, such as documents, removable electronic media, and nuclear 

weapons components. LLNL documents its ability to meet these 

requirements through its Site Safeguards and Security Plan. 

On October 1, 2007, Lawrence Livermore National Security, LLC (LLNS) 

took over as the management and operating contractor of LLNL after more 

than 50 years of operation by the University of California.4

 NNSA measures 

LLNL’s performance and determines LLNS’ management and operating 

incentive fee using annual performance evaluation plans that establish 

NNSA’s priorities for LLNL and ensure that contract requirements—such 

as effective security performance—are met. 

To determine the overall effectiveness of LLNL’s implementation of DOE 

and NNSA security requirements—including its protection strategy to

meet the DBT—two organizations periodically conduct comprehensive 

reviews of LLNL’s security performance. First, NNSA’s Livermore Site 

Office (LSO)—the on-site, federal office responsible for ensuring the 

secure operation of LLNL facilities and for accepting certain security risks 

 2

LLNL also plans to de-inventory all of its Category II special nuclear material—smaller 

quantities of weapons-grade materials, such as highly enriched uranium and plutonium—

that could be credibly aggregated into Category I quantities. 

3

Until recently, this policy was known as DOE’s design basis threat (DBT). In 2008, DOE

replaced the DBT with a Graded Security Protection policy that provides information that 

is similar to the information in the DBT but is tailored to risks at specific sites within the 

DOE nuclear weapons complex. 

4

LLNS is a limited liability corporation made up of Bechtel National, Inc.; the University of

California; BWX Technologies, Inc. (now part of the Babcock & Wilcox Company); and the 

Washington Group International, Inc. The team also includes Battelle Memorial Institute, 

four small business contractors, and Texas A&M University.

Page 2 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

on NNSA’s behalf—conducts an annual survey and issues a report based 

on survey results, observations of security performance, and compliance 

with DOE and NNSA security directives. This survey is a means for LSO to 

oversee the laboratory’s security performance and is intended to ensure 

that the security risks NNSA accepts are both known and mitigated to the

extent practicable. Second, the Office of Independent Oversight, within 

DOE’s Office of Health, Safety and Security, performs comprehensive, 

periodic security inspections at LLNL and other sites. These inspections 

may include performance assurance tests, such as “force-on-force” 

exercises that evaluate the ability of LLNL’s protective force to 

successfully defend the Superblock facility against a mock terrorist group 

simulating a potential attacking force. All deficiencies—“findings”—

identified during surveys and independent inspections require LLNL to 

take corrective actions; both LSO and the Office of Independent Oversight 

track the implementation of these actions. In addition, both LSO and DOE 

review the self-assessments LLNL conducts of its own security 

performance. 

In April 2008, DOE’s Office of Independent Oversight concluded a 

comprehensive inspection of security at LLNL. As a result of this 

inspection, LLNL earned the lowest possible rating—“Significant 

Weakness”—in two of seven security performance areas, including 

protective force performance. Two additional security performance areas 

were rated as “Needs Improvement.” 

In this context, you asked us to (1) characterize the security deficiencies 

identified by DOE’s Office of Independent Oversight in its April 2008 

inspection; (2) determine the factors that contributed to the deficiencies 

DOE’s Office of Independent Oversight identified in its inspection; (3) 

identify corrective actions LLNL is taking to address identified security 

deficiencies and how these actions are being overseen; and (4) assess 

LLNL’s plan for permanently removing Category I and II special nuclear 

material from its Superblock facility.

To address these questions, we visited LLNL and observed facilities 

included in the Office of Independent Oversight’s inspection. We also 

reviewed applicable DOE safeguards and security policies, such as the 

DBT and DOE Manual 470-4.1, Safeguards and Security Program 

Planning and Management. Furthermore, we reviewed both the Office of 

Independent Oversight’s inspection reports and LSO’s security surveys of 

LLNL from 1999 to the present and analyzed trends in security 

performance, with a focus on the four of seven security areas for which 

the Office of Independent Oversight provided overall ratings of less than 

Page 3 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

effective performance in its 2008 inspection report. In addition, we 

analyzed LLNL’s Site Safeguards and Security Plan for defending the site 

against the 2003 DBT as well as other key laboratory plans for ensuring 

that DOE security training and performance testing requirements are met. 

Furthermore, we reviewed LLNL’s and LSO’s interim and final corrective 

action plans to address security performance deficiencies identified by the 

Office of Independent Oversight. We also interviewed officials from DOE’s 

Office of Health, Safety and Security; NNSA’s offices of Defense Nuclear 

Security and of Nuclear Material Management Integration; LSO; and LLNL. 

We conducted this performance audit from July 2008 to March 2009 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. 

LLNL’s inventory of special nuclear material consists predominantly of 

weapons-grade plutonium and highly enriched uranium. This inventory 

takes two forms: (1) metals, including weapons components and material

machined into forms for use in weapons components; and (2) oxides and 

other compounds, such as salts. Some of LLNL’s special nuclear material 

inventory has been determined to be “programmatic,” or material that has 

been declared to be of national security value and that has an identified 

program use. Other special nuclear material in LLNL’s inventory has been 

determined to be “excess,” or material declared to be of national security 

value but that does not have an identified program use. Finally, LLNL’s 

inventory includes waste material that does not have a national security 

value. 

Background 

In accordance with DOE Manual 470.4-1, Safeguards and Security 

Program Planning and Management, NNSA must develop a safeguards 

and security program that ensures NNSA has the necessary protections in 

place to protect its security interests against malevolent acts, such as 

theft, diversion, sabotage, modification, compromise, or unauthorized 

access to nuclear weapons, nuclear weapons components, special nuclear 

material, or classified information. The safeguards and security program 

integrates NNSA’s physical security efforts by protective guard forces, 

information and personnel security systems, and nuclear material control

and accountability systems. Contractors that manage and operate NNSA 

laboratories—including LLNS—are required to comply with DOE 

Page 4 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

safeguards and security directives, as stated in their management and 

operating contracts. 

Because LLNL contains Category I and II special nuclear material, DOE 

Manual 470.4-1 requires that it prepare a Site Safeguards and Security Plan, 

a classified document that identifies known vulnerabilities, risks, and 

protection strategies for the site and formally acknowledges how much 

risk the contractor and DOE are willing to accept. The protection 

measures identified in LLNL’s approved Site Safeguards and Security Plan 

are developed in response to site-specific vulnerability assessments and 

become the basis for executing and reviewing protection programs at the 

Superblock. LLNL must annually review its Site Safeguards and Security 

Plan to ensure that implementation of the plan will provide effective

security protection. This review includes a validation of the protective 

strategy, accomplished in part through an annual force-on-force exercise, 

which exercises LLNL’s protective force against a mock adversary group 

simulating a potential attacking force. Force-on-force exercises are 

conducted using plausible attack scenarios. In addition, DOE Manual 

470.4-3, Protective Force, requires that LLNL conduct other performance 

assurance tests throughout each year, including quarterly performance 

assurance tests of a more limited scope than full force-on-force exercises.

While most NNSA and DOE sites were required to meet DOE’s 2005 DBT,5

LLNL has been declared “non-enduring” and is required to meet DOE’s 

less-demanding 2003 DBT. Specifically, in a March 7, 2008, memorandum

the Acting Deputy Secretary of Energy concurred with NNSA’s October 

2007 decision to declare LLNL a non-enduring Category I and II special 

nuclear material site because of plans to remove this material.6

 Together 

with DOE, NNSA determined that the benefits of expediting the removal of 

Category I and II special nuclear material outweighed the risks associated 

with foregoing security upgrades, and funds that were to be spent on these 

upgrades were redirected to support the de-inventory of special nuclear 

material. In line with this decision, DOE also agreed with NNSA’s decision 

to suspend planned security upgrades at LLNL’s Superblock facility that 

would have brought LLNL’s security posture to the level consistent with 

 5

As noted earlier, DOE has now replaced the 2005 DBT (DOE Order 470.3A) with the

Graded Security Protection plan (DOE Order 470.3B).

6

Prior to this decision, NNSA had committed LLNL to meeting the 2005 DBT and had 

reported these plans to Congress in June 2006 as required by Section 3113 of the National

Defense Authorization Act for Fiscal Year 2006 (Pub. L. No. 109-163, 119 Stat. 3136, 3543). 

Page 5 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

the larger adversary threat identified in DOE’s 2005 DBT. However, DOE 

and NNSA are requiring LLNL to maintain a “denial-of-task” security 

strategy until de-inventory is complete. Under this strategy, any 

adversaries that gain hands-on access to special nuclear material must be 

neutralized. LLNL and NNSA documented the site’s ability to meet the 

2003 DBT through their approvals of LLNL’s Site Safeguards and Security

Plan, which had been revised and approved in January 2007, and through a 

validation force-on-force exercise conducted in December 2006. 

To evaluate the effectiveness of sites’ protection programs, DOE uses a 

three-stage evaluation model: laboratory self-assessment, federal site 

office security surveys, and Office of Independent Oversight inspections. 

In each stage of the evaluation model, the results of performance 

assurance tests are considered. All three stages are required to address 

laboratory safeguards and security programs comprehensively. More 

specifically:

• LLNL’s self-assessment program is intended to provide the opportunity to 

self-identify security performance strengths and to address weaknesses 

internally before they can be exploited by a potential adversary. When 

security vulnerabilities are self-identified, these become the basis for 

federal decisions about how to mitigate them and what level of risk to 

accept. DOE requires that LLNL complete specific numbers and types of 

performance assurance tests to inform its self-assessments and assure 

DOE and NNSA that safeguards and security interests are being protected

at their required levels. 

• LSO security surveys are intended to confirm the availability and adequacy 

of safeguards and security programs, as implemented by LLNL. Surveys 

must be conducted annually and are based, in part, on direct observations

of security performance, including compliance with DOE and NNSA 

security directives. LSO may also consider LLNL’s security self-assessment 

as part of its annual survey as well as its performance assurance test 

results. To be comprehensive, LSO surveys cover eight topical areas and

33 subtopical areas and provide one of three ratings: satisfactory—the 

element being evaluated meets protection objectives or provides 

reasonable assurance that protection objectives are being met; marginal—

the element being evaluated partially meets protection objectives or 

provides questionable assurance that protection objectives are being met;

or unsatisfactory—the element being evaluated does not meet protection 

objectives or does not provide adequate assurance that protection 

objectives are being met. LSO may identify security deficiencies that are 

required to be addressed through corrective actions. 

Page 6 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

• The inspections by DOE’s Office of Independent Oversight evaluate 

LLNL’s and LSO’s security performance. To determine the adequacy of 

security policy and the implementation of those policies, the Office of 

Independent Oversight conducts its own performance assurance tests of 

key security systems, observes security performance, and conducts 

interviews. Inspections result in reports, which may identify deficiencies 

that must be addressed through corrective actions. To be comprehensive, 

Office of Independent Oversight inspections cover eight topical areas and

36 subtopical areas7

 (see app. I) and provide one of three ratings: effective 

performance—the system inspected provides reasonable assurance that 

the identified protection needs are met; needs improvement—the system 

inspected only partially meets identified protection needs or provides 

questionable assurance that the identified protection needs are met; or 

significant weakness—the system inspected does not adequately assure 

that identified protection needs are met. 

During the course of its April 2008 inspection, the Office of Independent

Oversight found significant weaknesses in LLNL’s protective forces’ 

performance against the adversary threat identified in DOE’s 2003 DBT, 

particularly during force-on-force scenarios and in other types of 

performance assurance testing. Deficiencies identified in LLNL’s 

protection program management contributed to the protective forces’ 

poor performance. In addition, the office identified deficiencies in LLNL’s 

classified matter protection and control programs, which are intended to 

provide protection against unauthorized disclosure of classified matter, as 

well as in LLNL’s physical security systems. LLNL’s security performance 

in two other security topical areas—material control and accountability, 

and personnel security8

—was rated effective.9 Table 1 describes the Office 

DOE’s Office of 

Independent 

Oversight Identified 

Several Significant 

Weaknesses in LLNL’s

Safeguards and 

Security Program 

 7

LSO and the Office of Independent Oversight categorize the topics and subtopics they 

cover differently. The Office of Independent Oversight also includes in its inspections 

subtopics covering safeguards and security at LSO. 

8

While the Office of Independent Oversight gave an effective performance rating to LLNL’s 

personnel security program, in December 2008 DOE’s Office of Inspector General found

that LLNL did not fully adhere to DOE requirements regarding security clearance 

justifications and that no internal controls were in place to validate the justifications stated 

in security clearance requests. See U.S. Department of Energy, Office of Inspector General,

Office of Inspections and Special Inquiries, Security Clearances at Lawrence Livermore 

National Laboratory and Sandia National Laboratory-California, INS-O-09-01 

(Washington, D.C.: December 2008). 

9

The Office of Independent Oversight also inspected classified and unclassified cyber 

security at LLNL. Separately, we are reviewing cyber security across the DOE complex, 

including at LLNL, and therefore we did not include an assessment of cyber security 

findings at LLNL as part of this review. 

Page 7 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

of Independent Oversight’s overall findings for LLNL. The office also 

identified 12 security deficiencies for LSO. 

Table 1: LLNL Security Deficiencies Identified by the Office of Independent 

Oversight, by Topical Area, April 2008 

Topical area Number of findings Overall rating 

Protective force 13 Significant weakness 

Classified matter protection

and control 

7 Significant weakness

Physical security systems 7 Needs improvement 

Protection program 

management 

7 Needs improvement

Personnel security 4 Effective performance

Material control and 

accountability 

0 Effective performance

Source: Office of Independent Oversight. 

Note: The Office of Independent Oversight identified an additional 16 security deficiency findings in 

cyber security that were outside the scope of our review. 

Despite an approved Site Safeguards and Security Plan and performance 

tests that validated LLNL’s ability to defend against the 2003 DBT, DOE’s 

Office of Independent Oversight identified 13 specific deficiencies in 

LLNL’s protective force’s performance; these deficiencies resulted in an 

overall rating of significant weakness, the lowest rating possible. These 

deficiencies became most apparent during force-on-force exercises 

designed to evaluate tactical response capabilities associated with the 

protection of LLNL’s special nuclear material inventory, as well as limited 

scope performance tests to determine skill levels associated with routine 

and emergency duties. Specifically, the Office of Independent Oversight 

found the following: 

LLNL’s Protective Force 

Performed Poorly in an 

Exercise against the 2003 

DBT 

• LLNL had not conducted an annual force-on-force exercise, as required by 

DOE Manual 470-4.3, Protective Force. Prior to the April 2008 exercise 

conducted during the Office of Independent Oversight’s inspection, LLNL 

had not conducted a full force-on-force exercise since December 2006, 

when LLNL validated the site’s ability to meet the adversary threat 

postulated by the 2003 DBT. 

• Other quarterly performance assurance tests, also required by DOE 

Manual 470-4.1, were too limited in scope to meet performance testing 

Page 8 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

requirements. In addition, not all required quarterly performance 

assurance tests were completed. 

• LLNL protective force members did not demonstrate proficiency in 

specific response capabilities, such as donning chemical masks in the 

required time. 

• Communication among protective force members was poor during the 

force-on-force exercise and did not facilitate rapid and effective response 

to alarms and adversary movements. 

• While protective force members performed well in individual qualification 

tests, the protective force did not demonstrate effective team tactics. 

• Protective force commanders did not demonstrate sufficient command 

and control capabilities during the force-on-force exercise to effectively 

direct tactical units. 

• Protective force members failed to respond to their fighting positions as 

required by LLNL’s Security Incident Response Plan. 

• LLNL’s mobile weapon platform—an armored vehicle that carries a 

mounted M-134D Dillon multi-barreled machine gun and that was 

identified in the laboratory’s approved Site Safeguards and Security Plan

as key to the site’s security—failed to competently support the protection 

mission. Numerous technical problems were noted with the weapon 

system’s operation, and officers were unable to perform operational tests 

of the weapon at the Superblock because of safety and security concerns. 

Furthermore, officers were not allowed to train with the weapon at LLNL’s 

nearby training range because of environmental concerns. 

• LLNL experienced “controller errors” when those running the exercise 

failed to communicate critical information on simulated events—such as 

explosions—that might have affected the exercise’s outcome. Office of 

Independent Oversight and LLNL officials agreed that errors of this nature 

can be attributed to a lack of practice in conducting force-on-force 

exercises. 

In several instances, LLNL security officials knew of the deficiencies 

identified by the Office of Independent Oversight before the April 2008 

inspection, but had not committed to corrective actions. For example, 

LLNL security officials were aware of some mechanical problems with the 

mobile weapon platform before April 2008. Officials said the full extent of 

the problems was not known because the platform had not been 

sufficiently tested in an operational environment. Officials explained that

Page 9 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

performance tests of the mobile weapon platform did not include tests of

how effectively the weapon would function in different attack scenarios, 

but rather tested officers’ response times for getting to the weapon and 

positioning it. Nevertheless, a review of LLNL’s quarterly performance 

assurance testing reports to LSO shows that LLNL reported completing 

100 percent of required performance tests on all essential protection 

strategy elements, including the mobile weapons platform. These reports 

do not include the results of the performance assurance tests; they only 

state that the tests were conducted. LLNL has since taken steps to improve 

the reliability of the mobile weapon platform, and a complete review of the 

electrical and mechanical systems is underway. Similarly, in 2006, LSO 

found that LLNL had not conducted its annually-required force-on-force 

exercise. There was an 18-month gap between a June 2005 exercise at 

LLNL and the one conducted in December 2006 to validate LLNL’s 

protection strategy against the 2003 DBT. 

Deficiencies in LLNL’s protection program management also contributed 

to the protective forces’ poor performance. The Office of Independent 

Oversight found seven security deficiencies in the area of protection 

program management—LLNL’s security program planning and assurance 

activities—and rated this security topic as needing improvement. The 

seven findings were focused on three areas of security planning and 

feedback: vulnerability assessment, self-assessment, and performance 

assurance testing. More specifically, the office found the following: 

• The evidence files to support the vulnerability assessments underpinning 

LLNL’s Site Safeguards and Security Plan were incomplete and raised 

questions about the scope and methodology used to prepare vulnerability 

assessments.

• LLNL’s security self-assessment program was not comprehensive and 

individual assessments of security elements lacked the breadth and depth

to provide management with information necessary to make meaningful 

decisions. 

• The list of essential security program elements LLNL had included in its 

performance assurance test plan was incomplete and the performance 

assurance tests did not always include measures that would test the 

effectiveness of these elements. 

Page 10 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

DOE Manual 470.4-4, Information Security, lays out the classified matter 

protection and control requirements that are intended to prevent the 

unauthorized disclosure of classified matter. Protection strategies include

properly marking classified documents and media to make visible their 

classification level and other information; using security containers (or 

safes), vaults, and vault-type rooms for classified matter storage; having 

accountability systems that use unique identification numbers for 

controlling access to and movement of certain classified matter; and 

having access barriers, such as combination locks. Other physical security

systems—such as alarms and sensors to detect unauthorized access to 

rooms storing classified matter—are considered separately during Office 

of Independent Oversight inspections. 

According to DOE officials, in the area of classified matter protection and

control, none of the seven individual findings of security deficiencies 

would independently have resulted in a rating of significant weaknesses; 

however, in total, the deficiencies identified led officials to question the 

overall effectiveness of LLNL’s classified matter protection and control 

program. More specifically, the Office of Independent Oversight found the 

following classified matter protection and control deficiencies: 

• LLNL failed to comply with basic security requirements, such as the 

frequency of changes to safe combinations when individuals’ needs for 

access to safes have changed; repeated errors in classified document 

marking; weaknesses in the timely completion of classification reviews for 

working papers; and errors in location records for all safes containing 

classified matter. 

• Individual LLNL directorates’ policies for storing accountable classified 

removable electronic media after hours were inconsistent and conflicted 

with DOE requirements. 

The Office of Independent Oversight also reported that LLNL’s physical 

security systems needed improvement. The office identified seven security 

deficiencies, including the adequacy of the alarm systems’ redundancy; the 

quality of lighting for, and images from, closed circuit television 

monitoring systems; the extent to which protective force posts needed 

repairs; and the protection strategy for security keys. Two of the office’s 

findings involved the security of vault-type rooms in which classified 

matter is stored. 

DOE Concluded That 

LLNL’s Protection and 

Control over Classified 

Matter Was Deficient 

DOE Identified Additional 

Areas of LLNL’s Security 

Program That Needed 

Improvement 

Page 11 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

The personnel security and material control and accountability security 

areas received effective performance ratings from the Office of 

Independent Oversight in April 2008. However, four security deficiencies 

were found in the personnel security area. All four related to aspects of 

LLNL’s Human Reliability Program, a program designed to ensure that 

individuals who occupy positions affording access to special nuclear and 

explosive materials meet the highest standards of reliability and physical 

and mental suitability. 

Neither LLNL’s security self-assessment program nor LSO’s annual 

security survey identified the security performance deficiencies that 

DOE’s Office of Independent Oversight found. According to one DOE 

official, both programs were “broken” and missed even the “low-hanging 

fruit” of compliance-oriented deficiencies that LLNL must now take 

actions to correct. More specifically, LLNL’s self-assessment program did 

not identify security deficiencies in the laboratory’s classified matter 

protection and control program or the performance assurance program 

established to test the operability and effectiveness of elements essential 

to LLNL’s protective strategy. Furthermore, LSO’s September 2007 annual

security survey, completed only 6 months before the Office of Independent 

Oversight’s inspection, resulted in 100-percent satisfactory ratings for the 

laboratory’s security performance. The Office of Independent Oversight 

found LSO’s survey program was not comprehensive, and LSO security 

officials said site office employees who conduct surveys need more 

subject matter training. 

DOE’s safeguards and security orders require that self-assessments 

comprehensively cover all topical and subtopical areas in order to assure 

the adequacy and effectiveness of security programs and their 

implementation. However, LLNL’s self-assessment program failed to 

identify the security deficiencies identified by DOE’s Office of 

Independent Oversight because the program (1) was not comprehensively

implemented and (2) not supported by an effective performance assurance 

testing regime. In terms of implementation, the office reported that LLNL’s 

and LSO’s collaborative approach to selecting high-priority security topical 

areas for self-assessment each year benefited the self-assessment program 

by making efficient use of limited resources; however, it also reported that 

several subtopic areas were not evaluated annually as required. 

Specifically:

A Weak Laboratory 

Self-Assessment 

Program and 

Insufficient Federal 

Oversight Contributed 

to Security 

Deficiencies at LLNL 

LLNL’s Self-Assessment 

Program Did Not Identify 

the Security Deficiencies 

Identified by DOE’s Office 

of Independent Oversight 

Page 12 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

• There had not been a comprehensive, site-wide assessment of safes 

containing classified matter for 3 years. 

• LLNL’s self-assessments were not broad and deep enough to provide 

laboratory management with sufficient information to make meaningful 

decisions about security performance. For example, self-assessments 

completed in fiscal year 2007 did not describe the evaluation criteria used

to perform the assessments. 

DOE requires that all essential elements of a site’s protection program be 

subject to performance testing to provide comprehensive assurance that 

the required levels of protection are met. Essential elements include the

equipment (such as weapon systems), procedures (such as security 

incident response plans), and personnel (such as security police officers) 

components of LLNL’s safeguards and security program. The failure of any 

of these components would reduce protection of departmental property to 

an unacceptable level. Each site, including LLNL, is required to develop a 

Performance Assurance Program Plan that describes the program and its 

implementation by identifying elements essential to the protection of 

Category I and II special nuclear material and Top Secret classified matter. 

The results of required performance assurance tests should contribute to

the security topic self-assessments. 

We reviewed LLNL’s quarterly reports to LSO on the laboratory’s 

performance assurance testing activities for fiscal year 2007 and the first 

half of fiscal year 2008. With the exception of the first quarter of fiscal year

2007, these reports show the performance testing requirements were met 

or exceeded. However, the Office of Independent Oversight’s inspection 

revealed multiple deficiencies in the design and implementation of LLNL’s 

performance assurance testing program. Specifically, the office found that 

(1) the individual test plans LLNL developed for essential protection 

elements did not always measure the effective performance of these 

elements; (2) not all essential elements were included in LLNL’s 

performance assurance testing program; and (3) LLNL did not perform 

annual force-on-force exercises or quarterly integrated performance tests 

as required. The September 2007 LSO security survey also found that LLNL 

did not perform some performance assurance tests with the required 

frequency. Table 2 provides information on LLNL’s required protective 

force performance assurance tests and deficiencies identified by the Office 

of Independent Oversight and LSO. 

Page 13 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

Table 2: LLNL’s Required Protective Force Performance Assurance Testing

Type of test Description 

Minimum performance test 

frequency 

Office of Independent 

Oversight and LSO findings

Limited Scope Performance 

Tests 

Scheduled or unscheduled limited 

scope performance tests of individuals 

or teams test any operation, 

procedure, skill, or task performance 

that falls within the scope of protective 

force responsibility. Examples of these 

tests include individual and team 

tactical movement, arrest and control 

techniques, building clearing, 

command and control activities, and 

implementation of protection 

strategies. 

Weekly at Category I/II 

special nuclear material 

facilities; all other facilities as 

required depending on 

security protection levels. 

The Office of Independent 

Oversight found that LLNL’s 

protective force lacked a specific 

protection capability that should 

have been demonstrated in

limited scope performance tests. 

Further, technical problems with 

the mobile weapon platform 

should have been identified to a 

greater extent during limited

scope performance tests. Finally, 

some limited scope performance 

tests did not effectively measure 

the performance of the security

elements being tested. 

Alarm Response and 

Assessment Performance 

Tests 

Unscheduled tests based on

simulated adversary actions 

consistent with the DBT to evaluate 

protective force response to a specific 

location under alarm protection and 

readiness to alarm conditions.

Twice per quarter at 

Category I/II special nuclear 

material facilities and other 

alarmed special nuclear 

material facilities; once per 

quarter at all other locations. 

The LSO survey reported that 

LLNL failed to assure that the

required number of alarm 

response and assessment 

performance tests were 

conducted. 

The Office of Independent 

Oversight noted LSO’s finding in 

its report. 

Validation Force-on-Force 

Exercises 

Major tests of all elements involved in

response to a DBT and site-specific 

threats that is used to validate sitespecific protection strategies. 

Once per year per facility for 

all sites with armed protective

force. 

The Office of Independent 

Oversight reported that LLNL 

protective force management 

had not conducted a validation 

force-on-force exercise in 

calendar year 2007. 

Command Post Exercises Scheduled or unscheduled exercises 

conducted to observe and evaluate 

crisis teams’ overall handling of 

simulated safeguards and/or security 

or a natural disaster incident. Lines of 

authority, timeliness of reporting and 

decision-making, and facility and 

equipment availability must be

included. 

Twice per year at Category 

I/II special nuclear material 

facilities, and once per year 

at all other facilities. 

Not discussed.

Page 14 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

Type of test Description 

Minimum performance test 

frequency 

Office of Independent 

Oversight and LSO findings

Command Field Exercises Extensions of Command Post

Exercises, these exercises test the 

interaction among various support 

organizations, site management, and 

the protective force to a simulated 

event. Exercises focus on procedures, 

tactical intelligence, communications, 

logistics, and the interfaces between 

federal and contractor support 

systems. 

Twice per year at Category 

I/II special nuclear material 

facilities, and once per year 

at all other facilities. 

Not discussed.

Joint Training Exercises Exercises conducted with outside 

agencies that support the successful 

mitigation of a security incident. 

At least once per year and 

consistent with requirements 

of the Site Safeguards and 

Security Plan. 

Not discussed.

Integrated Performance 

Tests 

Scheduled tests encompassing all 

essential protection elements 

associated with a comprehensive site 

or facility threat scenario conducted to 

evaluate the overall facility safeguards 

and security effectiveness. 

Category I facilities requiring 

denial protection strategies 

under the DBT (such as 

LLNL’s Superblock) must 

conduct Integrated 

Performance Tests on a 

quarterly basis.

The Office of Independent 

Oversight reported that there 

was no evidence that LLNL’s 

protective force had conducted 

quarterly integrated performance 

tests as required. 

Training Exercises Exercises involving each protective 

force shift are site-specific to the 

protective force in preventing the 

success of potential adversarial acts 

defined in the DBT.

Monthly. Not discussed.

Sources: GAO analysis of DOE Manual 470.4-3, Protective Force; DOE Manual 470-4.1, Safeguards and Security Program Planning 

and Management; Lawrence Livermore National Laboratory, Safeguards and Security Organization Performance Testing and 

Assurance Program Plan, September 21, 2006; Department of Energy, Office of Health, Safety, and Security, Volume I: Independent 

Oversight Safeguards and Security Inspection of the Livermore Site Office and the Lawrence Livermore National Laboratory, June 26, 

2008; and National Nuclear Security Administration, Livermore Site Office, Periodic Safeguards and Security Survey of Lawrence 

Livermore National Laboratory (LLNL) October 2, 2006, through September 28, 2007. 

Had LLNL’s self-assessment program been implemented comprehensively,

with the required breadth and depth, and used performance assurance 

testing in addition to compliance-based reviews, security deficiencies 

identified by the Office of Independent Oversight might have been selfidentified and corrected internally. This is particularly true with respect to 

deficiencies in the operation of the mobile weapon platform and 

protective force performance in command and control, communications, 

and team tactics. Significantly, the one area of LLNL security performance 

where the Office of Independent Oversight identified no security findings 

was nuclear material control and accountability. According to DOE and 

LLNL officials, the self-assessment program for nuclear material control 

and accountability provides assurance that all elements are evaluated. In 

addition, appropriate performance testing is conducted in this area. Since 

the April 2008 force-on-force exercise, LLNL has conducted four full-scale 

exercises—two each in August and November 2008—during which 

Page 15 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

protective force performance was successful. In addition, limited scope 

performance tests continue to be conducted to ensure readiness and 

knowledge of LLNL’s Security Incident Response Plan. Furthermore, since 

April 2008 LLNL has conducted quarterly force-on-force exercises, which 

the laboratory believes fulfills the requirement to conduct quarterly 

integrated performance tests. According to a LLNL security official, LSO

and LLNL disagree as to whether conducting quarterly force-on-force 

exercises meets the requirement to conduct quarterly integrated 

performance tests. The official said LLNL and LSO are working to resolve 

the disagreement. 

LSO’s Annual Security 

Survey Did Not Identify 

Deficiencies DOE 

Reported in 2008 

LSO completed an annual survey of LLNL’s security performance in

September 2007, 6 months before the Office of Independent Oversight 

inspected LLNL in April 2008. The survey consisted of a year-long process 

during which LSO staff conducted assessments, walk-throughs, and 

observations to gather data on different security programs. As a result of 

this survey, LLNL received 100-percent satisfactory ratings in its security 

performance—differing markedly from the security performance DOE 

observed during its inspection a short time later. In particular, LSO’s 

survey report noted as strengths that LLNL’s self-assessment program was 

supported by laboratory management and that LLNL had succeeded in

sustaining a protection strategy consistent with the 2003 DBT, assertions 

the Office of Independent Oversight inspection called into question. The 

LSO survey did result in six findings of security deficiencies: one for 

protective force, two for physical security systems, two for cyber security, 

and one for nuclear material control and accountability. For example, with 

respect to protective forces, LSO found that LLNL could not assure that it 

had conducted the necessary number of alarm response and assessment 

performance tests during the survey period. With respect to physical 

security, LSO found that LLNL did not adequately implement DOE 

requirements prohibiting employees from bringing personal laptop 

computers into secure locations and did not adequately implement a key 

management system. 

The Office of Independent Oversight also includes a review of site offices’ 

survey programs when it conducts its inspection of the protection 

program management security topic. In its April 2008 review, the office 

found LSO’s survey program was deficient in several areas. Specifically, 

the office found that the LSO security survey: 

• Was not comprehensive, as required by DOE Manual 470.4-1. LSO staff did 

not consistently follow the assessment schedule, did not prepare adequate

Page 16 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

assessment plans, and did not retain evidence files of individual survey 

activities. It also did not provide enough data to assure that survey reports

comply with DOE requirements to characterize the impact associated with 

observed deficiencies. 

• Did not consistently assure that security deficiencies were identified or 

that identified deficiencies resulted in findings that would require 

corrective action. For example, the office noted that survey narratives 

pertaining to the physical security systems area identified several 

deficiencies; however, the survey program did not assign findings to these 

deficiencies, and the survey report did not describe LLNL’s compensatory 

measures, as required. 

• Resulted in a satisfactory rating for LLNL’s self-assessment program 

without conducting the activities necessary to determine that the program 

was comprehensive. 

• Used reviews of the contractor’s records and the contractor’s 

implementation of the performance assurance program to determine the 

status of compliance and performance of protective force duties, rather 

than conducting independent performance assessments of LLNL’s 

protective force. 

LSO security officials told us they are redesigning their security survey 

program in response to these findings. Rather than aggregating LSO 

security staffs’ observations made over the course of a year, security at 

LLNL will be comprehensively surveyed during two set periods each year. 

These survey periods will be supplemented by continuous observation 

throughout the year. Surveys will continue to review compliance with 

DOE orders and requirements, but will also increase focus on assessing 

the extent to which security performance is effective. In addition, LSO is 

creating a security training program to ensure that all LSO officials who 

participate in the security survey program cover the different security 

topics comprehensively and are expert enough to recognize and report on

deficiencies. According to LSO officials, site office employees have been 

responsible for identifying their own training needs and have had 

independence in determining how they met training requirements. Little 

formal training was provided on how to conduct security surveys. Rather, 

training was received on the job and through what one official described 

as an “oral tradition” of how to perform oversight activities. The new 

training program is designed around DOE security standards, and LSO 

officials said the majority of the training will be provided by DOE’s 

National Training Center. The program is intended to ensure that LSO 

Page 17 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

security staff members are adequately trained to fulfill their duties and 

responsibilities. LSO’s goal is to have all security staff qualified through 

this program by 2010. Underpinning this new training program is what LSO 

security officials described as a “cultural shift”—an effort to rely less on 

contractor assurance of security performance and more on independent,

federal expertise to test and recognize that performance. However, 

according to LSO officials, LSO does not have a specific budget to 

implement this new security training program.10

LLNL has developed corrective actions to address the security deficiencies

identified by the Office of Independent Oversight. LSO and DOE will 

oversee the implementation of these corrective actions, and NNSA will 

judge whether implementation was successful when it determines LLNS’ 

contract award fee at the end of fiscal year 2009. While LLNL’s corrective

actions put the laboratory on a path toward improved security

performance, LLNL has not sustained corrective actions intended to 

address security deficiencies identified in 1999 and 2002 that are similar to 

those identified by the Office of Independent Oversight in 2008. 

LLNL has developed corrective action plans to address 54 security 

deficiencies identified by the Office of Independent Oversight.11 These 

plans include a total of 257 individual milestones, 185 of which are 

associated with the 4 security areas DOE rated as either having significant 

weaknesses or needing improvement. Corrective action plans associated 

with physical security deficiencies were made final between September 

and November, 2008. LLNL has reported that it will complete 

implementation of physical security milestones by October 30, 2009. As of 

LLNL Has Developed 

Corrective Action 

Plans to Address 54 

Identified Security 

Deficiencies, and 

Both NNSA and DOE 

Will Oversee Their 

Implementation 

Corrective Action Plans 

Are Intended to Address 54 

Identified Security 

Deficiencies 

 10We have reported in the past on the lack of comprehensiveness of site office security 

surveys and on a lack of training for site office staff. See GAO, Nuclear Security: NNSA 

Needs to Better Manage Its Safeguards and Security Program, GAO-03-471 (Washington,

D.C.: May 30, 2003); and National Nuclear Security Administration: Additional Actions 

Needed to Improve Management of the Nation’s Nuclear Programs, GAO-07-36 

(Washington, D.C.: Jan. 19, 2007). 

11LLNL’s 54 corrective action plans address both physical and cyber security findings. Of

these plans, 34 corrective action plans address physical security topical areas that received 

less than effective performance ratings. 

Page 18 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

December 2008, LLNL reported having completed 136 of the 185 

milestones, or about 74 percent (see fig. 1). 

Figure 1: LLNL Corrective Action Milestones by Security Topic, as of December 

2008 

In compliance with DOE Manual 470.4-1, Safeguards and Security 

Program Planning and Management, each corrective action plan includes

a root cause analysis, risk assessment, and cost-benefit analysis, where 

appropriate. To complete root cause analyses, LLNL used a DOE-agreed 

upon methodology and assigned root causes as directed by agency 

guidance. Of the 54 findings, LLNL determined that 29 had a single root 

cause, 18 had 2 root causes, 2 had 3 root causes, and 5 had 4 or more root 

causes. LLNL identified five recurring causes and issues as a result of its 

root cause analysis, including: 

0

10

20

30

40

50

60

70

80

90

Number of corrective action plan milestones

Security topic

Remaining

Completed

Source: GAO analysis of LLNL corrective action plans and milestone completion reports.

Protection Program

Management

Protective Force

Physical Security

Classified Matter Protection and Control

Systems

8

23

12

24

9

29

20

60

Page 19 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

• Resource allocation. LLNL identified resource allocation as the single 

largest root cause of the security deficiencies. According to the Office of 

Independent Oversight, LLNL had sufficient financial and human 

resources to meet applicable protection requirements. However, LLNL and 

LSO officials believe that LLNL could not fully fund all security program 

activities within available security budgets. Instead, LLNL allocated 

security resources on the basis of a broad set of priorities, management 

decisions, and budget constraints, which resulted in unfunded security 

activities and accepted risks. By identifying resource allocation as a root 

cause of the security deficiencies, LLNL determined that security 

deficiencies might have been avoided if resources had been allocated 

differently.

• Work/organization planning. In several cases, an activity or project was 

poorly planned or deviated from its plan because of time or budget 

constraints. In addition, some projects did not follow good project 

management practices or did not include contingency plans. For example, 

the Office of Independent Oversight found that a protective force armorer 

assigned to maintain weapons had not completed DOE’s recertification 

requirements. LLNL determined that armorer recertification planning 

could be improved by adding this requirement to a training database. 

• Policies and procedures. In several instances, policies or procedures were 

not followed, and DOE orders and requirements were unclear or were 

interpreted differently from the Office of Independent Oversight’s 

interpretation. For example, the Office of Independent Oversight found 

that LLNL did not follow DOE’s requirement to conduct weekly

inventories for all hard drives containing classified nuclear weapons 

design information. LLNL had interpreted DOE’s requirement differently 

and did not conduct weekly inventories for hard drives that had been

demagnetized, which makes the information stored on them unreadable.

• Training. In several cases, training content did not adequately cover all 

requirements. In addition, LLNL reported that a lack of practical, hands-on 

experience—performance testing—was a contributing factor in many 

areas of protective force deficiencies. NNSA headquarters security 

officials told us that the lack of training was the main cause for the 

protective force’s performance during the April 2008 force-on-force 

exercise. 

LLNL, LSO, and DOE officials agreed on other factors that contributed to 

the laboratory’s overall security performance. First, the change in 

management and operating contractor from the University of California to 

LLNS in October 2007 contributed to a loss of focus on security 

performance. According to LLNL security officials, during the period of 

Page 20 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

contract transition, employees’ focus was on ensuring safety as well as on 

potential impacts on employee pensions. In addition, the contract 

transition contributed to a delay in conducting LLNL’s required annual 

force-on-force exercise. Second, DOE’s and NNSA’s determination to 

declare LLNL a non-enduring site for Category I and II special nuclear 

material affected the morale of laboratory employees. LLNL security 

officials said highly experienced employees left the laboratory as a result 

of this declaration. Finally, successive changes to DOE’s DBT policy 

between 2003 and 2005 affected the analytical process that underpins 

security planning. In particular, LLNL security officials said the laboratory 

faced challenges in completing necessary vulnerability assessments. 

To complete corrective action plans’ risk assessments, LLNL security 

officials evaluated the worst-case scenario presented by individual 

findings of security deficiencies relative to a set of seven risk areas: 

mission success, cost, schedule, health and safety, environment, 

safeguards and security, and political and public trust. Ultimately, each 

finding was assigned a single, overall risk level: negligible risk, low risk, 

moderate risk, or high risk. According to LLNL’s analysis, 43 percent of the

findings were determined to be of negligible risk, and 57 percent were 

determined to be of low risk. LLNL officials said the low risk ratings 

associated with each of these findings is associated with the relatively low 

likelihood of a worst case scenario ever occurring, as well as the level of 

redundancy that exists for security systems. In contrast to LLNL’s risk 

assessment methodology, the Office of Independent Oversight based its 

security ratings on evaluations of management system performance. 

The vast majority of the physical security corrective actions LLNL has 

planned can be completed using existing funding, according to the 

laboratory’s plans. The complexity of these corrective actions and the 

costs associated with their implementation range from relatively simple 

and inexpensive to complex and expensive. For example, to correct one 

classified matter protection and control deficiency concerning policies for 

handling accountable classified removable electronic media after regular 

laboratory hours, LLNL plans to develop a new policy and conduct a series 

of briefings on how to implement the policy. Milestones associated with 

completing these corrective actions are straightforward and can be 

completed with existing funds. 

In contrast, to address the finding that LLNL’s protective force had not 

conducted quarterly integrated performance assurance tests of sufficient 

scope, LLNL plans to redesign its performance assurance testing program 

and has already begun to conduct larger, more frequent protective force 

Page 21 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

exercises. According to LLNL and NNSA security officials, conducting 

additional performance assurance training has resulted in a 30-percent 

overtime increase for the protective force and a $5.5 million budget 

shortfall in fiscal year 2009 to address findings and sustain this level of 

activity. According to NNSA, after an examination of security priorities 

and tradeoffs, the Office of Defense Nuclear Security provided LLNL with 

additional funding to cover this shortfall. 

LSO and the Office of Independent Oversight have overseen the 

development of LLNL’s corrective action plans, and the completion of 

these plans has been an iterative process (see fig. 2). While the process 

was ongoing, LLNL took steps to complete milestones that would be 

included in final corrective action plans. 

NNSA and DOE Plan to 

Oversee Implementation of 

Corrective Actions 

Page 22 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

Figure 2: Timeline for the Development and Final Approval of LLNL’s Corrective Action Plans 

December 15, 2008: The Office of Independent 

Oversight provides concurrence with LSO’s approvals

for physical security corrective action plans.

November 13, 2008: LSO approves the 

remaining 8 corrective action plans

April May June July August September October November December

October 22, 2008: LLNL sends

LSO revisions to the 8 unapproved 

corrective action plans

October 10, 2008: LSO approves

all but 8 corrective action plans

September 10, 2008: LLNL 

sends revised corrective action 

plans to LSO

September 2, 2008: Office of Independent 

Oversight sends additional comments on 

interim corrective action plans to LLNL

July 15, 2008: LLNL sends interim 

corrective action plans to LSO

July 8, 2008: Office of Independent 

Oversight inspection report finalized

July 28, 2008: LSO sends comments on 

interim corrective action plans to LLNL 

and the Office of Independent Oversight

April 15, 2008 – April 24, 2008: 

Office of Independent Oversight 

conducts inspection

Source: GAO analysis of LLNL, LSO, and Office of Independent Oversight corrective action plan documentation.

LSO officials said they plan to meet with LLNL officials every month to 

review the status of the corrective actions. LSO is required to describe the 

overall implementation status of corrective action plans and the extent to

which these actions are effective in its annual security survey reports. In 

addition, the Office of Independent Oversight has scheduled a follow-up 

security inspection of LLNL for April 2009 that will include a force-onPage 23 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

force exercise. Office of Independent Oversight officials told us the 

inspection will also include a review of progress on corrective actions 

associated with the four security areas that received less than satisfactory 

ratings in 2008. 

In keeping with the requirements of the National Defense Authorization 

Act for Fiscal Year 2000 which created NNSA,12 NNSA’s Office of Defense 

Nuclear Security has provided significant assistance to LLNL and LSO to 

help address identified security deficiencies. Office of Defense Nuclear 

Security officials have worked directly with LLNL to develop a recovery 

plan to improve the effectiveness of LLNL’s protection strategy. In 

addition, Office of Defense Nuclear Security officials have assisted LLNL 

in identifying corrective actions, and have provided assistance in 

implementing these corrective actions effectively. For example, officials 

from the Office of Defense Nuclear Security observed force-on-force 

exercises conducted at LLNL in August and November 2008 and provided 

feedback. In addition, to help LSO better integrate its security activities 

and improve security oversight, the Office of Defense Nuclear Security 

temporarily augmented LSO’s security staff with assistance teams of 

security experts from other NNSA site offices and from NNSA 

headquarters. These assistance teams provided independent technical 

reviews of revisions to LLNL’s vulnerability assessment documentation, 

protection strategy, training and testing procedures, and Site Safeguards 

and Security Plan, as well as support in resolving issues associated with 

classified matter protection. 

NNSA will ultimately judge the success of LLNL’s corrective action 

implementation when it determines a contract award fee at the end of 

fiscal year 2009.13 In fiscal year 2008—LLNL’s first year of contract 

performance evaluated under the new performance-based contract with 

LLNS—LLNS earned approximately $17.2 million, or 54 percent of the 

 12Pub. L. No. 106-65, 113 Stat. 512, 953 (1999). 

13According to LLNL’s corrective action plans, one milestone to correct a protective force 

deficiency will not be completed before the end of fiscal year 2009. It is scheduled for 

completion on October 30, 2009. 

Page 24 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

total “at-risk” incentive fee available under the contract.14 This amount 

included $1.3 million, or just 9 percent, of the total incentive fee available 

for safe and secure operations. NNSA identified the results of the Office of 

Independent Oversight’s inspection and the significant issues in LLNL’s 

physical and information security programs as concerns that contributed 

to the low award fee determination in this area. In particular, NNSA noted 

in its performance evaluation report for LLNL that considerable 

management attention from LLNS, NNSA, and DOE leadership was 

required to assure that the laboratory could meet protection requirements 

for special nuclear material. Furthermore, NNSA reported that LLNL failed 

to submit a security self-assessment report for fiscal year 2008, despite the 

Office of Independent Oversight’s findings on the laboratory’s selfassessment program. 

LLNL Has Not Sustained 

Corrective Actions That 

Addressed Past Security 

Deficiencies 

In its June 1999 and April 2002 inspections of security performance at 

LLNL, the Office of Independent Oversight identified weaknesses in 

LLNL’s protection program management and protective force 

performance, as well as numerous deficiencies in its classified matter 

protection and control program. LLNL implemented corrective actions, 

and the Office of Independent Oversight later rated LLNL’s performance as 

effective in these areas. However, LLNL did not sustain the corrective 

actions. Specifically: 

• In 1999, the Office of Independent Oversight reported that LLNL’s 

capability to conduct the vulnerability assessments that underpin 

protection program planning was deficient. By 2000, LLNL had corrected 

this problem, and in a follow-up inspection the office called LLNL’s 

vulnerability assessment program a model for the rest of the nuclear 

weapons complex. In its 2008 inspection, however, the Office of 

Independent Oversight again reported several deficiencies in the area of 

vulnerability assessment.

• In 2002, the office found weaknesses in protective force training and 

command and control. These weaknesses appear to have been addressed 

by the time of the 2006 force-on-force exercise, when Office of 

 14In fiscal year 2008, $1.5 million was deducted from the $17.2 million in incentive fee that

LLNS earned as a penalty for the loss of key personnel during the first year of the contract. 

However, LLNS also was awarded an additional $21.9 million, which represents the fixed 

fees for laboratory management and operation ($13.7 million) and work for other federal 

agencies and organizations ($8.2 million). In total, LLNS earned $37.5 million, or 70 percent 

of the maximum available total fee. 

Page 25 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

Independent Oversight officials said LLNL’s protective force performed 

well. In its 2008 inspection, however, the office again found significant 

weaknesses in protective force training and command and control. 

• In its 1999 inspection the office gave LLNL’s classified matter protection 

and control program the lowest possible rating, but the office rated LLNL’s 

program as satisfactory in a follow-up inspection 6 months later. Though 

some findings were reported in the interim, overall satisfactory ratings 

were maintained for classified matter protection and control until the 

Office of Independent Oversight’s 2008 inspection.

According to officials in NNSA’s Office of Defense Nuclear Security, it will 

be challenging to sustain the security improvements that result from 

LLNL’s successful implementation of corrective actions because of the 

laboratory’s non-enduring status and the drawdown in security resources 

that will come as special nuclear material de-inventory activities are 

completed. Officials said that NNSA must provide incentives to ensure that 

LLNL’s protective force can sustain the appropriate levels of protection 

until de-inventory is complete. According to a senior LSO official, 

sustaining attention on security performance could be difficult as NNSA 

priorities shift and future Site Office management weighs NNSA priorities. 

LLNL has taken steps to ensure a sufficient number of protective force 

members will remain employed by the laboratory to protect Category I and 

II special nuclear material throughout the de-inventory process as 

currently scheduled. A new collective bargaining agreement with LLNL’s 

protective force union, concluded in December 2008, expires at the end of 

fiscal year 2012. The agreement includes annual, additional lump sum 

payments of up to $50,000 over 3 years to protective force members who 

remain at LLNL during the de-inventory process. 

Page 26 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

When DOE concurred with NNSA’s decision to remove Category I and II 

special nuclear material from LLNL, the de-inventory process was 

expected to be completed no later than the end of fiscal year 2014. 

According to officials from NNSA’s Office of Nuclear Material 

Management Integration, NNSA decided to accelerate this schedule and 

complete de-inventory by the end of fiscal year 2012 as part of its efforts to 

transform the nuclear weapons complex. LLNL has completed a detailed 

schedule and associated resource-loaded project management 

documentation in support of the 2012 de-inventory date. NNSA officials 

said this accelerated schedule does not include any contingency funds set 

aside for risks within the project scope; however, LLNL officials said the 

schedule is aggressive but realistic. As of August 2008, LLNL had already 

decreased its inventory of Category I and II special nuclear material by 

approximately 33 percent from the laboratory’s fiscal year 2006 inventory.

In order to de-inventory most of its special nuclear material, LLNL must 

stabilize the material and package it according to DOE standards for 

shipment to a receiving site.15 The stabilization process uses special 

equipment, such as furnaces and gloveboxes, to remove impurities. The 

material packages are containers approved for use in transporting 

Category I and II special nuclear material to storage and other disposition 

sites. Given these requirements, it takes time to prepare packages for 

shipment. For example, according to LLNL it takes approximately 2 

months to prepare each package of plutonium oxide for shipment. LLNL 

plans to ship over 250 packages of special nuclear material to sites around 

the nuclear weapons complex to complete the de-inventory, including Los 

Alamos National Laboratory; the Nevada Test Site; the Savannah River Site 

in Aiken, South Carolina; the Y-12 National Security Complex in Oak 

Ridge, Tennessee; the Idaho National Laboratory near Idaho Falls, Idaho;

and the Waste Isolation Pilot Plant, in Carlsbad, New Mexico. Each of 

these sites has particular safety requirements in place that govern the 

types and amounts of material they can receive. For example, according to

NNSA officials, the Savannah River Site can only receive material excess 

to programmatic needs. Similarly, the Waste Isolation Pilot Plant can only 

receive certain waste material. Work to stabilize and package LLNL’s 

special nuclear material inventory is being conducted at Superblock while 

programmatic operations are ongoing. 

LLNL Faces 

Challenges in 

Implementing Plans 

to Complete Deinventory of Its

Category I and II 

Special Nuclear 

Material by the End of 

Fiscal Year 2012 

 15DOE-STD-3013-2004 Stabilization, Packaging, and Storage of Plutonium-Bearing 

Materials (April 2004); and DOE-STD-3028-2000 Criteria for Packaging and Storing 

Uranium-233-Bearing Materials (July 2000). 

Page 27 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

The plan to de-inventory LLNL’s Category I and II special nuclear material 

by the end of fiscal year 2012 is challenging because executing it depends 

on a number of factors, some of which LLNL does not control. Specifically:

• The willingness and ability of other NNSA and DOE sites to receive the

material. NNSA officials said work stoppages at receiving sites could 

delay shipments, as could disputes over the terms of receiving special 

nuclear material. NNSA’s Office of Nuclear Material Management 

Integration, an office NNSA created in July 2008 to coordinate the 

consolidation of special nuclear material among DOE sites, is helping to 

anticipate material acceptance issues by conducting monthly 

videoconferences with LLNL and receiving sites. 

• The Superblock facility will be operational nearly 100 percent of the time 

through fiscal year 2012. According to NNSA officials, there is always a 

chance of a work stoppage in Superblock. At least one lengthy, safetyrelated work stoppage at Superblock occurred in the recent past and 

lasted approximately 16 months, from January 2005 to May 2006, until

operations fully resumed. 

• Timely and adequate funding. LLNL estimates the entire de-inventory 

process will cost $41.3 million over 5 years (fiscal years 2008 through 

2012). This estimate does not include inflation or contingency funding. 

• The availability of specialized shipping packages and transport trucks 

consistent with the de-inventory schedule. All sites within the nuclear 

weapons complex use the same shipping packages and rely on NNSA’s 

Office of Secure Transportation to safely and securely move special 

nuclear material. The current de-inventory schedule plans to have 

completed packaging and shipment of 90 percent of the inventory by 

March 2011. The final 10 percent of the material, the most difficult to 

process, will take the remaining 18 months. Any change in the availability 

of packages or transport trucks could affect the de-inventory schedule. 

• The availability of skilled staff and fissile materials handlers. According 

to a LLNL official, a limited number of people are qualified to use the 

equipment at LLNL necessary to stabilize and package special nuclear 

material, and the number of skilled staff may diminish as the laboratory’s 

special nuclear material inventory diminishes. 

• The on-time procurement, installation, and startup of additional 

equipment. In order to meet the accelerated 2012 schedule, LLNL is 

procuring and installing additional equipment to add capabilities specific 

to the stabilization processes for certain metals and oxides. The last of 

Page 28 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

these capabilities is expected to come on line in June 2009. A delay could 

potentially affect the de-inventory schedule. 

According to LLNL and NNSA officials, there are not any feasible options 

that would allow substantial acceleration of the de-inventory schedule. We 

agree with this assessment. LLNL explored three options for further 

schedule acceleration. First, LLNL assessed the extent to which increasing 

its processing rate for special nuclear material by adding manpower or 

installing additional processing equipment would accelerate de-inventory. 

LLNL determined that only moderate schedule gains would be made by 

adding manpower because processing equipment is already operating 24

hours a day, 7 days a week. Installing additional processing equipment is 

not feasible because, according to LLNL, startup of new equipment of this 

type generally takes several years and would not be operational in time to 

affect the de-inventory process as currently scheduled. Second, LLNL 

explored options for shipping materials to other sites for processing at a 

later date. LLNL determined that this option is not feasible because sites 

do not have enough storage space for material that is not yet packaged. 

Furthermore, a LLNL official said other sites do not have processing 

capability, and material would have to be shipped back to LLNL for 

processing at a later date. Moreover, sites have restrictions on the types of

material they can receive. Finally, DOE looked at whether the Department 

of Transportation’s regulatory requirements for packaging and shipping 

could be relaxed. DOE and LLNL determined that any such relaxation 

would unacceptably increase safety, environmental, and security risks. 

It is essential that sites adequately protect the Category I and II special 

nuclear material they possess, given the threats and risks this material 

poses. Until LLNL has fully completed the process of de-inventorying its 

Category I and II special nuclear material from Superblock, it must 

maintain a high level of security. As LLNL’s inventory of Category I and II 

special nuclear material diminishes, it may prove difficult to sustain the 

level of security vigilance expected of Category I sites. Even after Category

I and II special nuclear material is no longer present at LLNL, LSO’s 

security oversight responsibilities will continue because laboratory 

employees must comply with requirements for protecting and controlling 

classified matter and lesser categories of special nuclear material. Strong

federal oversight can help ensure that security remains a priority at LLNL 

and that corrective actions implemented as a result of the Office of 

Independent Oversight’s April 2008 inspection are sustained. To do this, a 

federal site office with adequately trained subject matter experts to 

Conclusions 

Page 29 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

perform comprehensive security oversight, as required by DOE policies, is 

needed. In addition, NNSA’s annual performance evaluation plans, 

associated with its management and operating contract for the laboratory, 

include financial incentives for security performance. NNSA can use 

performance evaluation plans to provide LLNS with financial incentives to 

sustain laboratory security improvements. 

To improve and sustain federal oversight of security performance at LLNL, 

we recommend that the Administrator of NNSA and the LSO Manager take 

the following two actions: 

• Develop a detailed plan and budget for implementing LSO’s proposed 

security training program. 

• Incorporate financial incentives into future performance evaluation plans,

as allowed by the new LLNS management and operating contract, for 

sustaining security improvements at LLNL through the completion of the 

laboratory’s Category I and II special nuclear material de-inventory. 

We provided a draft of this report to NNSA for its review and comment. 

NNSA generally agreed with the report and its recommendations. NNSA 

noted that in its view the Office of Defense Nuclear Security and LSO are 

providing strong oversight over security at LLNL to ensure that security 

improvements are fully implemented and sustained. In particular, NNSA 

emphasized the Office of Defense Nuclear Security’s role in supporting the 

overall improvement of security at LLNL. NNSA’s comments on our draft 

report are presented in appendix II. NNSA also provided technical 

comments, which we incorporated into the report as appropriate. 

As arranged with your offices, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days after the 

date of this report. At that time, we will send copies of this report to the 

Secretary of Energy; Administrator of NNSA; Director of LLNL; and 

appropriate congressional committees. In addition, the report will be 

available at no charge on the GAO Web site at http://www.gao.gov. 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 

Page 30 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
 

If you or your staffs have any questions about this report or need 

additional information, please contact me at (202) 512-3841 or 

aloisee@gao.gov. Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this report. 

Appendix III lists key contributors to this report. 

Gene Aloise 

Director, Natural Resources 

 and Environment 

Page 31 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
Appendix I: Safeguards and Security Topics 

Covered in Office of Independent Oversight 

Inspections 

Safeguards and security topics Program definition

Protection Program Management 

• Planning process 

• Organization and staffing 

• Budget process 

• Program direction 

• Control systems 

• Survey program 

Programs are designed to ensure that security interests are

provided an appropriate degree of protection from hostile acts. It is 

an iterative process, whereby activities related to planning, staffing, 

budget, direction, and feedback are integrated with overall strategic 

and near-term operational planning. 

Physical Security Systems 

• Intrusion detection assessment 

• Entry and search controls 

• Badges, passes, and credentials 

• Barriers 

• Communications 

• Testing and maintenance 

Programs are designed to use intrusion detection and assessment, 

entry and search control, barriers, communications, testing and 

maintenance, and supporting systems and interfaces to deter, 

detect, annunciate, assess, delay, and communicate an 

unauthorized activity. 

Protective Force 

• Management 

• Training 

• Equipment and facilities 

• Duties 

Programs are designed to protect both DOE security interests from 

theft, sabotage, and other hostile acts that may adversely impact 

national security or the health and safety of the public, as well as life 

and property at DOE facilities. 

Classified Matter Protection and Control 

• Program management 

• Control of secret and confidential documents 

• Control of top secret documents 

• Control of classified materials

• Special programs 

• Operations security 

• Technical surveillance countermeasures 

• Classification management 

Programs are designed to provide protection against unauthorized

disclosure of classified matter and for sensitive information from its 

inception to destruction or decontrol. 

Material Control and Accountability 

• Administration

• Accounting 

• Measurements

• Inventories 

• Containment 

Programs are designed to provide an information and control system 

for nuclear material. These programs encompass those systems 

and measures necessary to establish and track nuclear material 

inventories, control access, detect loss or diversion of nuclear 

material, and ensure the integrity of those systems and measures. 

Appendix I: Safeguards and Security Topics 

Covered in Office of Independent Oversight 

Inspections 

Page 32 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
Appendix I: Safeguards and Security Topics 

Covered in Office of Independent Oversight 

Inspections 

Safeguards and security topics Program definition

Personnel Security

• Management 

• Personnel clearance program

• Security education program 

• Visitor control program 

• Human reliability program 

Programs are designed to ensure that access to sensitive 

information, classified matter, and special nuclear material will be

granted only after it has been determined that such access will not 

endanger security and is consistent with the national interest. 

Cyber Security—classified and unclassified Programs are designed to prevent deliberate or inadvertent

unauthorized disclosure, acquisition, manipulation, modification, or 

loss of information contained within computer networks and

systems, as well as measures designed to prevent denial of

authorized use of the system. 

Source: Office of Independent Oversight’s inspector guides. 

Note: The Office of Independent Oversight inspects classified and unclassified cyber security as

separate security topics. 

Page 33 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
Appendix II: Comments from the National Appendix II: Comments from the National Nuclear Security Administration

Nuclear Security Administration 

Page 34 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
Appendix II: Comments from the National 

Nuclear Security Administration

Page 35 GAO-09-321 Physical Security at Lawrence Livermore National Laboratory
Appendix III: GAO

A

 Contact and Staff 

cknowledgments 

Page 36 GAO-09-321 

Appendix III: GAO Contact and Staff 

Acknowledgments 

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

In addition to the individual named above, Jonathan Gill and John Cooney,

Assistant Directors; Allison Bawden; Tom Twambly; Ray Rodriguez; Omari 

Norman; Jamie Roberts; Tim Persons; Nabajyoti Barkakati; and Carol 

Hernstadt Shulman made important contributions to this report. 

Physical Security at Lawrence Livermore National Laboratory

GAO Contact 

Staff 

Acknowledgments 

(360985) 
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