SEPTEMBER 29, 2011

AUDIT REPORT

REPORT NO. IG-11-027 (ASSIGNMENT NO. A-11-004-00)

OFFICE OF AUDITS

A REVIEW OF NASA’S REPLACEMENT OF 

RADIATION MONITORING EQUIPMENT ON THE 

INTERNATIONAL SPACE STATION

OFFICE OF INSPECTOR GENERAL

National Aeronautics and 

Space Administration

 
REPORT NO. IG-11-027 

Final report released by:

Paul K. Martin

Inspector General

Acronyms 

ARI Advanced Radiation Instrumentation 

EV-CPDS Extra-Vehicular Charged Particle Directional Spectrometer

EV-TEPC Extra-Vehicular Tissue Equivalent Proportional Counter 

EVA Extra-Vehicular Activity

IRMA Integrated Risk Management Application 

ISS International Space Station

IV-CPDS Intra-Vehicular Charged Particle Directional Spectrometer

IV-TEPC Intra-Vehicular Tissue Equivalent Proportional Counter 

MORD Medical Operations Requirements Document 

MSL Mars Science Laboratory 

NPR NASA Procedural Requirements

OIG Office of Inspector General

RAD Radiation Assessment Detector

REID Risk of Exposure-Induced Death 

REM Roentgen Equivalent Man 

ROM Rough Order of Magnitude 

TEPC Tissue Equivalent Proportional Counter 
SEPTEMBER 29, 2011

REPORT NO. IG-11-027 

OVERVIEW

A REVIEW OF NASA’S REPLACEMENT OF 

RADIATION MONITORING EQUIPMENT ON THE 

INTERNATIONAL SPACE STATION

The Issue

Space radiation, including gamma rays, protons, and neutrons, poses a danger to NASA’s 

astronauts, increasing their risk of cataracts, cancer, damage to the central nervous 

system, and cardiovascular fatality.1

 Consequently, protecting astronauts from space 

radiation has been a fundamental requirement since space travel began.

2

Results

 To monitor 

astronauts’ exposure to radiation while aboard the International Space Station (ISS) and

to guard against overexposure, NASA installed a suite of monitoring instruments on the 

ISS between October 2000 and April 2002. However, these instruments have exceeded 

their design life; experienced varying degrees of failure, including in one case complete 

failure; and do not meet all ISS medical operations and radiation monitoring 

requirements. As a result, in 2008 NASA created the Advanced Radiation 

Instrumentation (ARI) Project to develop a new suite of instruments and ensure that 

NASA has the real-time information needed to protect its astronaut crews. Given the 

importance of radiation monitoring aboard the ISS and NASA’s past challenges in the 

areas of acquisition and project management, the NASA Office of Inspector General 

(OIG) reviewed the ARI Project to assess its status and determine whether radiation 

monitoring and applicable project management requirements have been met. Details of 

the audit’s scope and methodology are in Appendix A.

NASA has poorly managed the development of replacement radiation monitoring 

instruments. As a result, the replacement instruments are costing more than expected, are 

behind schedule, and will not include all planned elements. More effective project 

management would have enabled the Agency to better use its resources to assess and 

protect astronaut health, ensure that astronaut radiation exposure is as low as reasonably 

 

1 Space radiation consists primarily of ionizing radiation in the form of high-energy, charged particles that 

can cause acute and long-term damage to living cells depending on the dose received. There are three 

naturally occurring and highly variable sources of this type of radiation: radiation trapped in the Earth’s 

magnetic field, galactic cosmic radiation originating from outside the solar system, and radiation caused

by solar events. 

2 Appendix B lists acceptable limits for astronaut radiation exposure, the health effects overexposure may 

cause, and a description of our review of astronaut exposure histories. 
OVERVIEW

ii REPORT NO. IG-11-027 

achievable, and collect data needed for planning long-range exploration missions during 

which astronauts’ risk from radiation exposure will significantly increase.

In addition, until April 2010 NASA was developing an instrument that did not meet the 

radiation monitoring requirements identified in its ISS Medical Operations Requirements 

Document (MORD). The MORD specifies the monitoring and measuring requirements

of charged particles outside the ISS, but NASA was developing an instrument that only 

would have measured radiation dosage. 

Although we did not identify any instances of crewmembers exceeding defined radiation 

exposure limits, the instruments that provide real-time monitoring of the Space Station’s 

radiation environment have reached the end of their design life and have partially or 

completely failed. 

In addition, while reviewing NASA’s management of the ARI Project and its 

development of new radiation monitoring instruments, we also found that the ISS 

Program has never monitored astronaut exposure to neutrons in accordance with MORD

requirements.

3

The ARI Project Is Costing More Than Planned, Is Behind Schedule, and Will Not 

Include All Planned Elements. The ARI Project experienced significant cost growth 

and schedule delays. Total estimated ARI Project costs increased approximately 

62 percent, from $16 million to $26 million. Further, delivery of the new instruments has 

been delayed by almost 3 years. The cost growth and schedule delays occurred because 

the ISS Program approved the ARI Project based on cost estimates and schedule 

milestones that were not supported by accurate and complete data. For example, NASA 

did not have a firm proposal from the contractor responsible for building one of the 

replacement instruments when the ISS Program approved the ARI Project. When NASA 

received the proposal 7 months later, the cost of the instrument had nearly doubled from 

NASA’s baseline projection. 

 Further, the Program had not adequately analyzed, planned, tracked, or 

controlled the risk created by this inability to monitor neutrons aboard the ISS. Research 

suggests that neutron radiation, which can deeply penetrate the body and damage bloodforming organs, may contribute as much as 10 to 30 percent of the total radiation dose 

received by astronauts inside spacecraft such as the ISS. 

Only after the ARI Project’s Preliminary Design Review did ISS Program management 

completely understand the scope of work required to deliver the replacement suite of ISS 

radiation monitoring instruments, when the instruments realistically could be delivered, 

and how much they would cost. Baselining the ARI Project after the Preliminary Design 

Review, as described in NASA’s project management policies, would have provided the 

Agency a better chance to deliver the Project within the planned cost, schedule, and 

scope. 

 

3 Section 7.5.3.2.1.3 of the ISS MORD requires that “[r]adiation monitoring instruments . . . provide the 

capability to characterize the neutron contribution to crew exposures.” 
OVERVIEW

REPORT NO. IG-11-027 iii

We also found that the ARI Project included an instrument that did not meet existing 

external radiation monitoring requirements. Specifically, NASA did not review and, as 

necessary, formally initiate steps to revise radiation monitoring requirements during the 

early phases of the Project to ensure that the requirements, if met, would address the true 

radiation monitoring needs of the ISS Program. Johnson Space Center’s Space Life 

Sciences Directorate should have established the current external radiation monitoring 

requirement and, if necessary, initiated steps to properly execute an official change to the 

MORD before beginning any development effort.4

As a result of these missteps, the ARI Project has been de-scoped, will not include all 

planned elements, and key radiation monitoring requirements for astronauts aboard the 

ISS continue to go unmet. 

 

ISS Risk Management for Neutron Monitoring Was Inadequate. To accurately track 

astronaut radiation exposure and assess risks to crew health, the ISS Program is required 

to monitor the neutron portion of the radiation environment aboard ISS. However, the 

Program has never met the neutron-monitoring requirement and is not expected to do so 

before December 2014 when the instrument being developed to monitor neutrons will be 

available. In the interim, the Program did not adequately explain in its risk management 

system the context of the risk posed to astronaut crews. Further, the Program did not 

develop or document a plan to address the risk. NASA requires that risks be managed 

until they are mitigated or resolved. The failure to fully report the risk posed by the 

inability to monitor neutron radiation aboard the ISS meant that the issue did not receive 

the focused management attention required for timely resolution. 

When we informed the Assistant Associate Administrator for ISS of this issue during the 

fieldwork for this audit, he acknowledged that the neutron risk had not been fully 

developed and directed the ISS Program to take immediate corrective action. 

Subsequently, the Program updated the ISS risk management system to more fully report 

the risk of not measuring astronaut exposure to neutrons while aboard the ISS. As a 

result, we are not making any formal recommendations related to this issue. 

Management Action

To improve project management, we recommended that the ISS Program Manager ensure 

that all future ISS-related projects follow the tenets of NASA’s project management 

policy and do not proceed to the implementation stage until managers demonstrate 

projects are properly anchored by firm requirements, realistic cost and schedule 

estimates, sufficient funding, and successful completion of a Preliminary Design Review. 

We also recommended that Johnson Space Center’s Director, Space Life Sciences, 

determine whether the current ISS medical operations requirement for external radiation 

 

4 The MORD must be updated in coordination with the Mission Integration and Operations Control Board, 

the Multilateral Medical Policy Board, and any affected international partners.
OVERVIEW

iv REPORT NO. IG-11-027 

monitoring of the spectra of charged particles is appropriate and, if not, formally initiate 

steps to update the MORD in coordination with the Mission Integration and Operations 

Control Board, the Multilateral Medical Policy Board, and international partners. 

In response to our draft report, the Assistant Associate Administrator for ISS concurred 

with our recommendations but took issue with some of our findings and conclusions. 

The full text of his comments are reprinted in Appendix C. 

In response to our first recommendation, the Assistant Associate Administrator agreed to 

follow NASA’s project management policy in the future. However, he stated that the ISS 

Program does not interpret NASA’s policy to require that a project only proceed to 

implementation after completion of a Preliminary Design Review. He also took issue 

with our finding that the ARI Project has been poorly managed. Despite these 

disagreements, the Assistant Associate Administrator stated that as part of the lessons 

learned process the ISS Program will review how the ARI Project’s cost and schedule 

estimates and assumptions concerning technology readiness levels were developed to 

determine what improvements can be made for future projects. The planned corrective 

action will be completed by December 15, 2011. 

We consider the ISS Program’s proposed actions to be responsive to the intent of our 

recommendation and will close the recommendation upon completion and verification of 

the proposed actions. We believe the planned review of the development of cost and 

schedule estimates and assessment of the technology readiness level for the ARI Project 

will help ensure future ISS-related projects are planned using more reliable estimates and 

more accurate information. 

However, we disagree with the ISS Program’s interpretation of NASA’s project 

management policy. Section 2.3 of the policy establishes the project life cycle; describes 

the activities that occur in the formulation and implementation phases; and states that, 

although projects are initiated in the formulation phase, approval marks the transition 

from project formulation to implementation.

5

Although the ARI Project was given “full and final approval” in July 2008, managers did 

not gain a true understanding of the scope of work, cost, and schedule required until after 

the Project’s Preliminary Design Review in April 2009. As a result, the Project’s total 

estimated costs increased approximately 62 percent, from $16 million to $26 million; the 

 The Section further states that project 

plans – which include technical, schedule, and cost objectives – are baselined after the 

Preliminary Design Review and before approval to proceed to full implementation. After 

all, the purpose of the Preliminary Design Review is to establish the basis for proceeding 

with detailed design work by demonstrating that a project’s preliminary design meets all 

requirements within an acceptable level of risk and existing cost and schedule constraints. 

Furthermore, Section 2.5 of the policy specifically lists the Preliminary Design Review as 

one of the internal reviews that leads to project approval and, therefore, implementation.

 

5 NASA Procedural Requirements 7120.5D, “NASA Program and Project Management Processes and 

Requirements,” March 2, 2007. 
OVERVIEW

REPORT NO. IG-11-027 v 

Project will not include one of the three planned instruments to reduce uncertainties in 

crew exposure and corresponding health risk; and delivery of one of the two remaining 

instruments has been delayed by almost 3 years. We believe these facts demonstrate that 

the Project was poorly managed and do not understand NASA’s rationale for insisting 

otherwise. 

In response to our second recommendation, the Assistant Associate Administrator stated 

that the Director of the Space Life Sciences Directorate will determine whether the 

current ISS medical operations requirement for external radiation monitoring of the 

spectra of charged particles is appropriate. Further, by October 15, 2011, the Director 

will provide the ISS Program with a plan to review and update the MORD. We consider 

the Space Life Sciences Directorate’s proposed action to be responsive to our 

recommendation and will close the recommendation upon completion and verification of 

the proposed action. 

 

SEPTEMBER 29, 2011

REPORT NO. IG-11-027 

CONTENTS

INTRODUCTION

Background _________________________________________ 1 

Objectives __________________________________________ 7 

RESULTS

The ARI Project Is Costing More Than Planned, Is Behind 

Schedule, and Will Not Include All Planned Elements _______ 8 

ISS Risk Management for Neutron Monitoring 

Was Inadequate __________________________________ 15

APPENDIX A 

Scope and Methodology_______________________________ 17

Review of Internal Controls ____________________________ 19

Prior Coverage ______________________________________ 19

APPENDIX B 

Radiation Exposure Limits and Health Effects ______________ 20

APPENDIX C 

Management Comments ______________________________ 22

APPENDIX D 

Report Distribution___________________________________ 26

SEPTEMBER 29, 2011

REPORT NO. IG-11-027 1 

INTRODUCTION

Background

Exposure to space radiation, including gamma rays, protons, and neutrons, increases

astronauts’ risk of cataracts, cancer, central nervous system damage, and cardiovascular 

fatality.6

Passive and Active Radiation Monitoring. To protect astronauts living and working 

aboard the ISS from the adverse effects of radiation, the ISS Medical Operations 

Requirement Document (MORD) establishes radiation health and exposure monitoring 

requirements.

 NASA recognized this hazard and began monitoring astronaut exposure to 

radiation as early as Project Mercury in 1961 and has continued such monitoring during 

the Space Shuttle and International Space Stations (ISS) programs. Future long-duration 

expeditions outside Earth’s protective magnetic field and into interplanetary space where 

space radiation is more intense will increase the risk of crew exposure. As NASA 

considers the feasibility of such future human space flight missions, radiation protection 

remains one of the key technological issues that must be resolved. Gathering accurate 

information on the effects of radiation aboard the ISS is an important step to 

understanding and resolving this issue.

7

 Specifically, the MORD requires the monitoring and measurement of 

(1) radiation doses absorbed by human tissue, (2) charged particles and neutron radiation

inside the ISS, and (3) charged particles outside the ISS during extra-vehicular activities 

(EVAs).8

Because no single instrument is capable of measuring all energies, quantities, and types 

of radiation, NASA uses multiple passive and active monitoring devices to protect ISS

crewmembers. Passive monitoring devices include personal dosimeters worn by each 

 With regard to radiation, the Agency follows the “ALARA” philosophy, which 

means keeping astronaut radiation exposure As Low As Reasonably Achievable. 

 

6 Space radiation consists primarily of ionizing radiation in the form of high-energy, charged particles that 

can cause acute and long-term damage to living cells depending on the dose received. There are three 

naturally occurring and highly variable sources of this type of radiation: radiation trapped in the Earth’s 

magnetic field, galactic cosmic radiation originating from outside the solar system, and radiation caused 

by solar events. 

7

 Space Station Program 50260, “International Space Station Medical Operations Requirements Document 

(ISS MORD),” Revision C, February 2006. Approval authority for the MORD is delegated to the 

Mission Integration and Operations Control Board, while the Multilateral Medical Operations Panel has

control of all technical content of the MORD. Any changes or revisions to the MORD must be jointly 

agreed to and signed by NASA and the affected ISS international partners.

8 Charged particles (protons and heavy ions) originating from solar flares and cosmic rays can cause acute 

and chronic health effects, depending on the dose received. The exterior of the ISS or fabric of a 

spacesuit can stop most charged particles; however, interactions of high-energy charged particles with 

spacecraft materials can produce neutron radiation (low-energy, uncharged particles). Neutron radiation, 

which also is generated by solar events, can deeply penetrate human tissue and damage blood-forming 

organs. Ten to thirty percent of the total radiation on the ISS is estimated to be neutron radiation. 
INTRODUCTION

2 REPORT NO. IG-11-027 

crewmember that measure the dosage but not the type of radiation exposure. However, 

such passive devices do not provide real-time data and must be returned to Earth for 

analysis. In addition, they do not record the date and time an astronaut was exposed to 

particular doses of radiation. Accordingly, NASA supplements the data obtained from 

passive instruments with active instruments that provide the real-time measurements 

needed to allow crewmembers to take action in response to changes in the radiation 

environment in and around the ISS. For example, data from active instruments could 

alert NASA to a sudden or unexpected increase in radiation and allow crewmembers to 

take necessary action. In fact, after a large solar flare was detected the evening of 

December 12, 2006, crewmembers slept overnight in heavily shielded areas of the 

spacecraft as a precautionary measure. 

A crewmember’s cumulative radiation exposure history impacts his or her eligibility for 

future space flights. Therefore, radiation monitoring devices not only help NASA 

manage crew health and assess crew risk, they also are used to help make crew selection 

and assignment decisions. As described in Appendix B, each year a NASA radiation 

specialist uses the data from radiation monitoring devices to generate the Astronaut’s 

Annual Radiation Exposure Report, which tracks each astronaut’s career exposures and, 

thus, their eligibility for future missions. Career exposure limits, as specified in the 

MORD, cannot be 3 percent more than the general public’s estimated risk of dying from 

cancer. 

First Generation Active Monitoring Instruments: TEPC, IV-CPDS, and EV-CPDS. 

To characterize and quantify the radiation environment inside and outside the ISS, NASA 

installed three active monitoring instruments between October 2000 and April 2002: 

1. The Tissue Equivalent Proportional Counter (TEPC) measures the real-time 

radiation dose human tissue receives inside the ISS. The TEPC became 

operational in October 2000 and continues to function, although it has a history of 

failures. The ISS has one operational TEPC and one spare unit on board. Both of 

these units have exceeded their design life by more than 3 years, and NASA has 

no other spares on the ground. 

2. The Intra-Vehicular Charged Particle Directional Spectrometer (IV-CPDS) was 

deployed to the ISS in March 2001 to measure charged particles inside the ISS. 

The IV-CPDS failed in 2006 and has not been repaired or replaced. There are no 

spares. Intra-vehicular charged particle data is required to support crew risk 

estimation and recordkeeping as well as crew selection and assignment processes. 

According to NASA officials, data obtained from the instrument when it was 

operational along with ongoing research have led to the adoption of risk 

estimation procedures that help compensate for the loss of the instrument. 

3. Flight controllers need information about radiation levels outside the ISS to 

evaluate the environment prior to and during spacewalks. To gather this 

information, NASA deployed the Extra-Vehicular Charged Particle Directional 

Spectrometer (EV-CPDS) to the ISS in April 2002. The instrument is essentially 
INTRODUCTION

REPORT NO. IG-11-027 3 

three IV-CPDS units arranged at different angles on the outside of the ISS. 

However, only two of these units are operating – the third failed in May 2003 – 

and both have exceeded their design life by more than 5 years. In addition, 

NASA expects the units will fail before the ISS Program is scheduled to end in 

2020.

Below are photographs of the first generation active radiation monitoring instruments 

(TEPC, IV-CPDS, and EV-CPDS). 

Figure 1. TEPC, IV-CPDS, and EV-CPDS Photographs

Source: Space Radiation Analysis Group, Johnson Space Center.

Replacement Suite of Active Monitoring Instruments: IV-TEPC, RAD, and 

EV-TEPC. In light of the repeated problems with the TEPC, the failure of the IV-CPDS
INTRODUCTION

4 REPORT NO. IG-11-027 

in 2006, and partial failure of the EV-CPDS in 2003, the ISS Program began developing 

a plan to replace the first generation hardware. In July 2008, the Program approved a 

replacement suite of active radiation monitoring instruments consisting of a new intravehicular TEPC (IV-TEPC); a Radiation Assessment Detector (RAD) to take the place of 

the IV-CPDS; and a second TEPC (EV-TEPC) to be deployed outside the ISS for 

monitoring radiation during EVAs. At the same time, the Advanced Radiation 

Instrumentation (ARI) Project was established at the Johnson Space Center (Johnson) to 

manage and develop the new instrument suite. 

Below are illustrations of the three new instruments (IV-TEPC, EV-TEPC, and RAD) 

approved in the replacement suite.

Figure 2. IV-TEPC, EV-TEPC, and RAD Illustrations

 Source: Engineering Directorate’s Avionic Systems Division, Johnson Space Center.
INTRODUCTION

REPORT NO. IG-11-027 5 

As shown in Figure 3 below, there are two fundamental differences between the proposed 

replacement instrument suite and the original hardware. First, the IV-CPDS will be 

replaced with a RAD that will measure charged particles inside the ISS. In addition, 

unlike the IV-CPDS, the RAD will also measure neutrons. At the time of proposal, a 

RAD had just passed Critical Design Review on the Mars Science Laboratory (MSL) 

payload complement, and the ISS Program hoped to develop an ISS RAD based on a 

modified design of the MSL model.9

Second, the instrument proposed to replace the EV-CPDS and measure radiation outside 

the Space Station would no longer monitor charged particles but instead would measure 

the radiation dose absorbed by human tissue. Specifically, Johnson’s Space Life 

Sciences Directorate and ISS Program management told us that their experience with the 

EV-CPDS gave them a good understanding of the charged particle environment outside 

the ISS. Based on 10 years of using the EV-CPDS, they determined that the real need on 

the ISS was an EV-TEPC, which would measure the radiation dose absorbed by human 

tissue during EVAs. However, as discussed below, the current MORD requires 

measurement of charged particles. 

 Southwest Research Institute designed both the 

MSL RAD and the ISS RAD. 

Figure 3. Relationship between First and Second Generation ISS Active Radiation 

Monitoring Instruments and Corresponding Medical Operations Requirements 

 First Generation Second Generation 

Instruments Instruments

NASA Project Management Requirements. Agency-wide policies establish the 

requirements by which NASA should formulate and implement space flight programs 

and projects like the ARI Project.

10

 

9 The Critical Design Review is a major milestone in program development, which demonstrates that a 

program’s design is mature enough to proceed with full-scale fabrication, assembly, integration, and 

testing. Additionally, the Critical Design Review ensures that the technical effort will complete flight and 

ground system development and mission operations and meet overall performance requirements within 

the identified cost and schedule constraints. 

 Specifically, NPR 7120.5D and NM 7120-81 provide 

10 NASA Procedural Requirements (NPR) 7120.5D, “NASA Program and Project Management Processes 

and Requirements,” March 2, 2007, and NM 7120-81, “NASA Space Flight Program and Project 

Management Requirements,” NASA Interim Directive for 7120.5D. 

TEPC IV-TEPC 

IV-CPDS RAD

EV-CPDS EV-TEPC 

Measures radiation dose 

absorbed by human tissue

inside the ISS

Will measure radiation dose 

absorbed by human tissue

inside the ISS

Measured charged particles 

inside the ISS (failed in 2006)

Will measure charged 

particles and neutron 

radiation inside the ISS

Measures charged particles 

outside the ISS

Will measure radiation dose 

absorbed by human tissue

outside the ISS
INTRODUCTION

6 REPORT NO. IG-11-027 

that project planning should be based on realistic cost estimates. In addition, as shown in 

Figure 4, during a project’s pre-formulation and formulation phases, project managers are 

to develop and define requirements and the basis for cost and schedule estimates to meet 

those requirements. Moreover, before the project is approved for implementation, a 

Preliminary Design Review is required to ensure that all requirements can be met with 

acceptable risk and within cost and schedule constraints. At completion of the 

Preliminary Design Review, NASA’s project management principles require a baseline 

Project Plan to guide the project through the implementation phase. Baseline schedule

estimates should be achievable in light of projected costs and available resources and 

based on realistic supplier cost and schedule proposals.11

Figure 4. Space Flight Project Management Process Overview

 

Source: Adapted from NM 7120-81, “NASA Space Flight Program and Project Management 

Requirements,” NASA Interim Directive for NPR 7120.5D. 

 

11 Baselines are an agreed-upon set of requirements, cost, schedule, designs, and documents. Changes to 

baseline information are made through a formal approval and monitoring process. 

 Project Implementation

Project Life Cycle

Project PreFormulation

Project Formulation Approval 

Program establishes 

team to conduct 

broad range of 

concept studies that 

meet requirements, 

define management 

and technical 

approaches, and 

select acceptable 

alternatives. 

Decision Authority 

conducts key decision 

points and approves 

project to proceed.

Project develops 

and refines concept, 

management and 

technical 

approaches, 

requirements, etc. 

Project conducts 

Systems Design 

Review and 

develops 

preliminary Project 

Plan.

Project develops 

baseline design to 

meet requirements 

with acceptable risk 

within cost and 

schedule constraints; 

completes technology 

development; 

conducts Preliminary 

Design Review; and 

completes baseline 

Project Plan.

Decision Authority 

conducts key decision 

points and approves 

project to proceed.

Decision Authority 

conducts key decision 

points and approves 

project to proceed.

Project implements in accordance 

with Project Plan and Project 

Life Cycle. Update project approach, 

Project Plan, and budget when 

major budget or content issues 

require such changes. 

Project conducts 

decommissioning 

review. Decision 

Authority approves 

decommissioning. 

Project archives data.
INTRODUCTION

REPORT NO. IG-11-027 7 

Objectives 

Our objective was to determine whether the ARI Project was meeting cost, schedule, and 

performance requirements. In addition, we examined whether NASA managers followed

applicable project management requirements when developing radiation monitoring 

instruments and managing the Project. See Appendix A for details of the audit’s scope 

and methodology, our review of internal controls, and a list of prior coverage. 
RESULTS

8 REPORT NO. IG-11-027 

THE ARI PROJECT IS COSTING MORE THAN 

PLANNED, IS BEHIND SCHEDULE, AND WILL 

NOT INCLUDE ALL PLANNED ELEMENTS

The ARI Project has experienced significant cost growth and schedule delays. 

Total estimated ARI Project costs increased approximately 62 percent from a 

baseline figure of $16 million in 2008 to $26 million in 2009, and delivery of one 

of the instruments has been delayed for almost 3 years. These conditions 

occurred, in part, because the ISS Program approved the ARI Project based on 

cost estimates and schedule milestones that were not supported by accurate and 

complete data. In addition, we found that the Program made a determination that 

the existing MORD requirements did not reflect the most current knowledge and 

needs concerning external radiation monitoring. Based on this assessment and 

without seeking to amend the MORD, the Program planned an instrument that 

would not have satisfied existing MORD requirements. As a result of NASA’s 

poor management, the Project has been de-scoped and will not include all planned 

elements; the ISS Program has not been able to timely address known concerns 

about failed or failing radiation monitoring equipment; and key radiation 

monitoring requirements continue to go unmet. 

ARI Project Experienced Significant Cost Growth and Schedule 

Delays

The ISS Program baselined the ARI Project in July 2008, approving $16 million to 

deliver three instruments: an IV-TEPC, RAD, and EV-TEPC (two flight units and one 

qualification unit for each instrument).12 Approximately 7 months later, the Project 

obtained a firm proposal from Southwest Research Institute, the company that was 

building the MSL RAD, to build the RAD for the ISS. The contractor’s proposal of 

$13.7 million nearly doubled the RAD’s baseline cost. The cost for the TEPCs also 

increased from the baseline figures due to higher-than-expected manufacturing costs and 

problems Johnson’s Avionic Systems Division encountered when developing the 

instruments’ detectors.

13

 

12 A qualification unit, identical to a flight unit in form, fit, and function, is used to verify and certify the 

instrument’s environmental and performance requirements. 

 As a result, total estimated ARI Project costs increased 

approximately 62 percent, from $16 million to $26 million; development of the IV-TEPC 

slipped 11 months; development of the RAD slipped almost 3 years; the planned 

deliverables for the RAD have been reduced from two flight units and a qualification unit 

to one flight unit with spare parts; and the EV-TEPC has been canceled outright. The 

13 As depicted in Figure 2 (page 4), the IV-TEPC and EV-TEPC each consist of two detectors to measure 

radiation doses.
RESULTS

REPORT NO. IG-11-027 9 

increases in Project cost and schedule estimates for development of the new radiation 

monitoring instruments are shown in Table 1. 

Table 1. ARI Project Cost and Schedule Increases

2008 2009 2010 2011 

Cost 

(millions)

Completion 

Date 

Cost 

(millions)

Completion 

Date

Cost 

(millions)

Completion

Date

Cost 

(millions)

Completion Date

IVTEPC $6.3 September 

2010 $9.0 

March 

2011 $10.0 July 2011 $14.0 

August 

2011a

RAD $7.3 May 2011 $13.7 

Contract 

Award plus 

30 Monthsb $12.4c March 2014 $12.4 

March

2014d

EVTEPC $2.1 September 

2010 $3.0 

March 

2011 Cancelede

Total $15.7 $25.7 $22.4 $26.4 a The IV-TEPC was completed (built) and certified in August 2011. In December 2011, NASA will ship the unit 

to the European Space Agency’s French Guiana launch site for delivery to the ISS in March 2012 aboard a 

European Automated Transfer Vehicle. 

b Per Southwest Research Institute’s February 2009 proposal for the RAD. 

c Quantity decreased from two flight units and one qualification unit to one flight unit and spare parts. As a result, 

the estimated cost from the previous year decreased by $1.3 million.

d The RAD is scheduled to be completed (built and certified) by March 2014 and is planned to be delivered to the 

ISS by December 2014. Because delivery of the RAD will not occur for 3 years, NASA has not yet added the 

instrument to a launch vehicle manifest. 

e In April 2010, the ISS Program Office removed the EV-TEPC from the ARI Project.

ARI Project Cost Estimates and Schedule Milestones Not 

Supported by Reliable Data

Although NASA’s project management principles provide that managers base project 

planning on realistic cost and schedule estimates, the ISS Program approved and 

baselined the ARI Project in July 2008 using only on a Rough Order of Magnitude 

(ROM) estimate. Specifically, from February to May 2008 Johnson’s Avionic Systems 

Division determined the Project’s feasibility and developed a ROM estimate for an 

engineering change request to replace the ISS radiation monitoring hardware.14

 

14 NPR 7123.1A, “NASA Systems Engineering Processes and Requirements” ensures configuration control 

of NASA systems, such as those aboard the ISS, by requiring that requested engineering changes are 

evaluated prior to being implemented. Typically, a formal board is established to receive, review, and 

approve engineering change requests, such as the request that was made to replace the ISS radiation 

monitoring equipment. 

 
RESULTS

10 REPORT NO. IG-11-027 

However, the estimate was not based on reliable cost and schedule data. For example, 

the ROM assumed a Project start date of February 2008; however, the change request 

was not signed until June 2008. Accordingly, the Project was behind schedule from the 

start. Further, at change request submittal, the Avionic Systems Division was unsure 

whether Texas A&M University, with which the Division had partnered to design and 

develop the IV- and EV-TEPC detectors, could produce the hardware. As work on the 

detectors progressed, the Division discovered that the University’s quality control and 

production capabilities were insufficient to produce flight hardware. After evaluating 

several vendors, the Division determined the best course of action was to do the work 

in-house. Finally, NASA’s ROM estimate for the TEPCs did not account for: 

• the spare detectors the Agency decided were needed due to having limited access 

to the ISS after retirement of the Space Shuttle; 

• higher-than-expected subcontractor and manufacturing costs; or 

• cost reserves. 

In an internal document, the Project Manager acknowledged the shortcomings of the 

ROM: “The [TEPC] design prototyping effort has taken longer than initially planned, 

and the learning curve has been steeper than expected . . . . There were some big 

assumptions and unknowns that went along with our original ROM.”15

The estimate for the RAD was equally unreliable. NASA formulated the estimate prior 

to receiving a firm proposal from Southwest Research Institute, and the verbal ROM the 

Agency received from the Institute was based on an assumption that developing the ISS 

RAD hardware would be similar to developing the RAD for the MSL. However, the 

Institute did not fully understand the changes necessary to convert its MSL RAD design

and develop hardware for use on the ISS. Consequently, NASA’s ROM for the RAD 

incorrectly estimated the instrument could be delivered for about $7.3 million in May 

2011. As noted above, the Institute’s formal proposal was almost double the amount of 

NASA’s original cost projections and the instrument will not be completed until March 

2014. 

 

In addition, we found that the Program did not gain a true understanding of the scope of 

work required to deliver the replacement suite of instruments, when the instruments could 

be delivered, and how much they would cost until after the Preliminary Design Review in 

April 2009. However, contrary to NASA guidance, the Project was baselined before the 

Preliminary Design Review. Documentation shows that the Project asked for “partial 

implementation to PDR [Preliminary Design Review]” and to be allowed to come back at

Preliminary Design Review with “firm cost and schedule to completion.” Although the 

ISS Vehicle Control Board approved this approach, the Project was given “full and final 

approval” in July 2008 and the initial ROM “stuck.” In retrospect – and in keeping with 

 

15 “ISS Advanced Radiation Instrumentation Project State of the Project” presentation, dated July 13, 2009.
RESULTS

REPORT NO. IG-11-027 11

NASA’s project management guidance – baselining the Project after the Preliminary 

Design Review would have provided NASA with a better opportunity to deliver the 

Project within the planned cost, schedule, and scope. 

According to a Program official, the ISS Program Manager authorized the initial Project 

baseline using the ROM estimate because it was the best cost estimate available at the 

time. However, a ROM estimate is generally considered reliable only when the cost of 

the desired item is well known and based on previous experience with the vendor and 

product. Although Program officials believed they sufficiently understood the level of 

effort required to develop new ISS radiation monitoring instruments and modify 

Southwest Research Institute’s design for the MSL RAD to make it suitable for the ISS, 

the informal ROM estimate ultimately proved inaccurate. 

When the Program received an updated estimate for the TEPCs and a firm cost proposal 

for the work required to deliver the RAD, NASA was not able to obtain the replacement 

suite of instruments for the $15.7 million allocated in the baseline projection and 

therefore had to de-scope the ARI Project. Program managers de-scoped the Project by 

ending development of the EV-TEPC after spending an estimated $2.3 million. In 

addition, as mentioned previously, the de-scoping included reducing the RAD 

deliverables from an initially planned two flight units and a qualification unit to one flight 

unit and spare parts. 

The EV-TEPC Would Not Have Satisfied Current Program 

Requirements

The ISS Program approved development of an EV-TEPC as a replacement for the 

EV-CPDS, an instrument currently operational but not expected to perform through the 

end of the ISS’s life. As discussed previously, Johnson’s Avionic Systems Division was 

designing the EV-TEPC to measure the amount of radiation that would be absorbed by 

human tissue. However, the current MORD requires measurement of the spectra of 

charged particles outside the ISS. As a result, the EV-TEPC would not have met the 

Program’s current requirements as expressed in the MORD. 

According to Johnson’s Space Life Sciences Directorate, ISS Program officials 

determined that the lessons learned through continuous operation of the Space Station 

and data obtained from 10 years of operating the EV-CPDS resulted in the decision to 

replace the EV-CPDS with an EV-TEPC. Specifically, Program officials said they 

determined that, despite the MORD requirements, it is no longer necessary to 

characterize charged particles outside the ISS. Instead, according to an ISS Program 

official, the Program determined that the ISS needs an instrument to monitor the 

spacecraft’s EVA environment and a TEPC placed outside the vehicle (an EV-TEPC) 

would provide measurements of the real-time dose of radiation an astronaut conducting 

an EVA would receive. 
RESULTS

12 REPORT NO. IG-11-027 

As shown in Figure 4 (page 6), a fundamental first step in NASA’s accepted project 

management principles is to develop and define requirements. Therefore, the Space Life 

Sciences Directorate should have established what type of external radiation monitoring 

was required and, if necessary, properly initiated an official change to the MORD before 

beginning development of any instrument. Because responsibility for the safety of 

astronauts aboard the ISS is shared among the United States and its international partners, 

and because the MORD is the primary compendium of all health-related requirements for 

the ISS, NASA should have initiated a revision to the MORD through the established 

amendment process before changing the type of radiation monitoring instruments on the 

ISS. 

The ARI Project Has Been De-Scoped and Will Not Include All 

Planned Elements

As a result of NASA’s poor management of the ARI Project, the Project has been 

de-scoped and will not include all elements originally planned. In addition, the ISS 

Program has not timely addressed known concerns about failed or failing radiation 

monitoring equipment and key radiation monitoring requirements continue to go unmet. 

Specifically, due to the significant cost growth and schedule delays caused by reliance on 

unsupported initial cost and schedule estimates, the ISS Program directed Johnson’s 

Avionic Systems Division to stop work on the EV-TEPC and RAD instruments in April 

2010. Thereafter, the EV-TEPC, for which NASA had already spent about $2.3 million, 

was permanently removed from the Project. While development of the RAD resumed 

2 months later, delivery of the instrument, originally planned for May 2011, will be 

delayed until March 2014, almost 3 years behind schedule. This delay inhibits the ISS 

Program’s ability to restore the capability to measure astronaut exposure to charged 

particles inside the ISS – a requirement that has gone unmet since the IV-CPDS failed in 

2006 – and establish the capability to measure astronaut exposure to neutrons while 

aboard the ISS – a requirement that NASA has never met. Additionally, although 

NASA’s original plans for this important RAD instrument included two flight units and a 

qualification unit, the revised Project plan will result in only one flight unit and spare 

parts. 

During the course of our review, we did not identify any instances of crewmembers 

exceeding defined radiation exposure limits. However, improved project management 

would have enabled NASA to more effectively target its resources to protect astronaut 

health, ensure that astronaut radiation exposure is kept as low as reasonably achievable, 

and collect data needed for planning future long-duration exploration missions in which 

astronauts’ risks from radiation exposure will significantly increase. 
RESULTS

REPORT NO. IG-11-027 13

Recommendations, Management’s Response, and Evaluation of 

Management’s Response

Given the importance of radiation monitoring aboard the ISS and NASA’s challenges in the 

areas of acquisition and project management, we recommended that the Agency take the 

following actions to ensure ISS projects follow the tenets of NASA’s project management 

policy and that MORD requirements are kept current. 

Recommendation 1. We recommend that the ISS Program Manager ensure that future ISSrelated projects follow the tenets of NPR 7120.5D and do not proceed to the implementation 

stage until project managers demonstrate projects are properly anchored by firm 

requirements, realistic cost and schedule estimates, sufficient funding, and successful 

completion of a Preliminary Design Review. 

Management’s Response. The Assistant Associate Administrator for ISS concurred, 

stating that the ISS Program and JSC will follow NPR 7120.5 for future projects. 

Additionally, the ISS Program will initiate a lessons learned review of the ROM cost and 

schedule estimates and an assessment of the technology readiness level for the ARI 

Project to determine what improvements can be made for the benefit of future ISS and 

Johnson projects. A lessons learned review for the IV-TEPC will be completed by 

December 15, 2011. 

Although the Assistant Associate Administrator agreed with our recommendation and 

proposed corrective action, he indicated that “the ISS Program does not interpret 

NPR 7120.5D to mean that a project must be initiated only to Preliminary Design Review 

and then a subsequent authorization processed for implementation.” In addition, the 

Assistant Associate Administrator disagreed with our conclusion that the ARI Project 

was poorly managed. His full comments are reprinted in Appendix C. 

Evaluation of Management’s Response. We consider management’s proposed actions

to be responsive to the intent of our recommendation and will close the recommendation 

upon completion and verification of those actions. However, we reiterate our finding that 

the ISS Program did not comply with the requirements of NPR 7120.5D and our 

conclusion based on that finding that the Project was poorly managed. 

Specifically, Section 2.3 of the policy establishes the project life cycle; describes the 

activities that occur in the formulation and implementation phases; and states that, 

although projects are initiated in the formulation phase, approval marks the transition 

from project formulation to implementation.

16

 

16 NASA Procedural Requirements 7120.5D, “NASA Program and Project Management Processes and 

Requirements,” March 2, 2007. 

 The Section further states that project 

plans – which include technical, schedule, and cost objectives – are baselined after the 

Preliminary Design Review and before approval to proceed to full implementation. After 

all, the purpose of the Preliminary Design Review is to establish the basis for proceeding 
RESULTS

14 REPORT NO. IG-11-027 

with detailed design work by demonstrating that a project’s preliminary design meets all 

requirements within an acceptable level of risk and existing cost and schedule constraints. 

Furthermore, Section 2.5 of the policy specifically lists the Preliminary Design Review as 

one of the internal reviews that leads to project approval and, therefore, implementation. 

Contrary to these requirements, the ARI Project was baselined and given “full and final 

approval” 9 months before Preliminary Design Review using unreliable ROM cost and 

schedule estimates. As a result, the Project’s total estimated costs increased 

approximately 62 percent, from $16 million to $26 million; the Project will not include 

one of the three planned instruments intended to reduce uncertainties in crew exposure 

and corresponding health risk; and delivery of one of the two remaining instruments has 

been delayed by almost 3 years. We continue to believe that the assumptions and 

underestimations made by Project managers and now acknowledged by the Assistant 

Associate Administrator, along with the premature approval of the ARI Project based on 

inaccurate and incomplete data, constituted poor project management. Moreover, in light 

of these facts, we do not understand NASA’s rationale for insisting otherwise. 

Recommendation 2. We recommend that Johnson’s Director of the Space Life Sciences 

Directorate determine whether the current ISS medical operations requirement for external 

radiation monitoring of the spectra of charged particles is appropriate and, if not, formally 

initiate steps to update the MORD in coordination with the Mission Integration and 

Operations Control Board, the Multilateral Medical Policy Board, and any affected 

international partners.

Management’s Response. The Assistant Associate Administrator concurred, stating that 

the Director of the Space Life Sciences Directorate will provide the ISS Program with a 

plan to review and update the MORD by October 15, 2011. He noted that the Space Life 

Sciences Directorate’s understanding of the ISS radiation environment has improved over 

the years of ISS operations and that this has reduced the complexity of requirements and 

design solutions needed to safely manage overall crew risk. He also noted that the delay 

in updating the MORD “has not impacted the implementation of the necessary 

requirements on the ARI Project.” 

Evaluation of Management’s Response. The Assistant Associate Administrator’s 

comments are responsive to our recommendation. Accordingly, we will close the 

recommendation upon completion and verification of the proposed corrective action. 

Although we understand that NASA’s understanding of radiation monitoring 

requirements has evolved over the years of ISS operations, we believe it is imperative 

that NASA and its international partners update the MORD to reflect this understanding. 

The MORD is the primary compendium of all health-related requirements for the ISS. 

Therefore, the MORD should have driven the formulation of the ARI Project. If the 

Project believed that the MORD no longer reflected the most current knowledge, it 

should have initiated a revision to the document through the established amendment 

process.
RESULTS

REPORT NO. IG-11-027 15

ISS RISK MANAGEMENT FOR NEUTRON 

MONITORING WAS INADEQUATE 

To accurately track astronaut exposure and assess risks to crew health, the MORD 

requires the ISS Program to monitor astronaut exposure to neutron radiation.17

The ISS Program uses the ISS Integrated Risk Management Application (IRMA) to 

manage risks related to the Program. Although we identified an entry in the database 

related, in part, to the lack of a neutron monitoring instrument on board the ISS, we found 

that the Program had not clearly and comprehensively explained the context of the risk 

posed to crews by this lack of monitoring.

 

Monitoring such exposure is important because neutrons can affect blood-forming 

marrow in bones and may represent 10 to 30 percent of the total radiation dose an 

astronaut aboard the ISS receives. However, the ISS Program has never met this 

requirement and will not be able to do so until at least December 2014, when the RAD is 

scheduled to be delivered to the ISS. In the interim, the ISS Program had not adequately 

analyzed, planned, tracked, or controlled the risk posed by the Program’s inability to 

measure neutrons. 

18 Further, the Program had not developed or 

documented in IRMA a plan to address the risk.

19

NASA requires that all project risks be managed until they are mitigated or resolved.

 

20

When we informed the Assistant Associate Administrator for ISS about this issue during 

fieldwork for this audit, he acknowledged that the Program had not fully developed the 

risk of its inability to monitor astronaut exposure to neutron radiation and directed the 

ISS Program to take immediate corrective action. Subsequently, the Program updated 

IRMA to reflect: (1) that the ISS is not equipped with an instrument designed to monitor 

neutrons; (2) that data provided by the TEPC instrument provides some insight into 

neutron radiation exposure, but not neutron-specific information; (3) that the Program 

accepts the risk of not having a neutron-specific monitoring device because the RAD will 

 

Risk management is an organized, systematic decision-making process that identifies, 

reduces, or controls risks to achieve program and project goals. Failure to fully report the 

risk posed by NASA’s inability to measure crew exposure to neutrons while aboard the 

ISS meant that the issue did not receive the focused management attention required for 

timely resolution. 

 

17 Section 7.5.3.2.1.3 of the ISS MORD requires that “[r]adiation monitoring instruments . . . provide the 

capability to characterize the neutron contribution to crew exposures.” 

18 IRMA Watch Item 5686 “Tissue Equivalent Proportional Counter (TEPC) and Neutron Monitoring 

Devices Needed.”

19 The entry related to the neutron exposure issue reported an expected closure date of December 31, 

2011 – clearly inaccurate in light of the expected December 2014 delivery date of the RAD to the ISS.

20 NPR 8000.4A, “Agency Risk Management Procedural Requirements,” December 16, 2008.
RESULTS

16 REPORT NO. IG-11-027 

provide this capability; and (4) that the expected closure date for the neutron risk is 

December 31, 2014 – after the RAD is expected to have been successfully installed on 

board the ISS. 

As a result of these corrective actions, we are not making any formal recommendations 

related to this issue. 

Management’s Comments on the Finding and Evaluation of 

Management’s Comments

Management’s Comments on the Finding. Although we did not make any 

recommendations based on this finding, the Assistant Associate Administrator noted in 

his response that NASA is currently controlling the radiation exposure risk to 

crewmembers to 95 percent confidence levels and that the current lack of neutronspecific monitoring does not prevent NASA from controlling the risk of the neutron 

component of radiation exposure. (See Appendix C for additional details.)

Evaluation of Management’s Comments. As acknowledged in the Assistant Associate 

Administrator’s response, the ISS Program currently lacks the capability to monitor the 

neutron portion of ionizing radiation as required by the MORD. Research suggests that 

neutron radiation, which can deeply penetrate the body and damage blood-forming 

organs, may contribute as much as 10 to 30 percent of the total radiation dose received by 

astronauts inside the ISS and other spacecraft. We believe installation of the ISS RAD in 

2014 will enhance NASA’s ability to track radiation exposure and risks to astronaut 

crews. In the interim, we support the actions NASA took during the course of our audit 

to more fully report the risk posed by NASA’s current inability to measure crew exposure 

to neutrons. 
APPENDIXES

REPORT NO. IG-11-027 17

APPENDIX A 

Scope and Methodology

We performed this audit from December 2010 through August 2011 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 objective. We believe that the 

evidence obtained provides a reasonable basis for our findings and conclusions based on 

our audit objective. 

Initially, we focused our review on processes used by the ARI Project to manage the 

development and implementation of Space Life Sciences radiation monitoring equipment 

needs. We interviewed key NASA Headquarters and Johnson Space Center personnel 

involved in the radiation monitoring program. We interviewed the Manager, ISS Vehicle 

Integration Office, to obtain background information on the ARI Project. We held 

multiple meetings with the ARI Project Manager to evaluate whether technical, cost, and 

schedule requirements were being met and to discuss the hardware content, cost, and 

schedule estimates.

Additionally, we compared the ARI Project’s initial cost and schedule estimates with the 

current cost and schedule estimates. We also compared the Project’s planned hardware 

content with the hardware content being built in 2011.

We identified and reviewed relevant Federal laws and regulations; NASA policies, 

procedures, plans, and guidance; and other criteria. We reviewed NASA and Johnson 

policies and procedures that prescribe the project management processes that should be 

followed to effectively meet a project’s approved technical, cost, and schedule goals. 

Specifically, we reviewed: 

• Johnson Space Center Engineering Directorate Work Instruction (EA-WI-023), 

“Project Management of Government Furnished Equipment (GFE) Flight 

Projects,” Revision E, February 2006; 

• NPR 7120.5D, “NASA Program and Project Management Processes and 

Requirements,” March 2, 2007; 

• NM 7120-81, “NASA Space Flight Program and Project Management 

Requirements,” NASA Interim Directive for 7120.5D; and

• NPR 8000.4A, “Agency Risk Management Procedural Requirements,” 

December 16, 2008. 
APPENDIX A 

18 REPORT NO. IG-11-027 

We identified the ARI Project’s baseline cost, schedule, and technical requirements and 

assessed the extent that Johnson’s Avionic Systems Division and Space Life Sciences 

Directorate planned and took actions that would result in effectively developing and 

delivering a suite of replacement radiation monitoring instruments to the ISS.

We interviewed experts from Johnson’s Space Radiation Analysis Group to identify and 

understand radiation monitoring requirements for the ISS, the extent these requirements 

are currently met, and how the proposed replacement suite of radiation monitoring 

instruments will meet the requirements. Also, we interviewed the Computer Resources 

Manager, Avionic Systems Division, to obtain an overview of the Avionics and Software 

Office responsibilities for the IV-TEPC development. 

In addition to interviews, we obtained and reviewed documents to include: 

• life-cycle documents; 

• technical requirements, cost, and schedule data; Feasibility Assessment made by 

the Avionic Systems Division for the ARI Project, dated May 6, 2008, to obtain 

original hardware content, cost, and schedule estimates; 

• Independent Government Cost Estimate made by Assessments, Cost Estimates 

and Schedules Office for ISS ARI Project dated May 12, 2008, to obtain 

independent cost and schedule estimates; 

• ISS Change Directive 011073, dated July 3, 2008, and Revision 1, dated April 19, 

2010, to obtain formal cost and schedule estimate and deliverables;

• internal task agreements between the ISS Vehicle Office and the Avionic Systems 

Division for fiscal years 2008, 2009, 2010, and 2011 to obtain formal cost and 

schedule estimate and deliverables; and

• financial data for work breakdown structure 401769.06.05.02.02.27 for 

ARI/IV-TEPC development from NASA’s “Core Financial” system to compare 

with the Project Manager’s current cost estimates.

From our interviews and analysis, we identified:

• the ISS radiation monitoring requirements contained in SSP 50260, “International 

Space Station Medical Operations Requirements Document (ISS MORD),” 

Revision C, February 2006;

• the extent that current instruments on board the ISS are satisfying the radiation 

monitoring requirements; 

• whether NASA will have the replacement suite on board the ISS to prevent any 

gaps in continuously measuring and monitoring crew exposure to radiation; 
APPENDIX A 

REPORT NO. IG-11-027 19

• the capabilities of the TEPC currently on board the ISS, including its estimated 

useful life and whether the ISS Program has a backup plan should the TEPC fail; 

and 

• the impact for a delayed development and delivery of the IV-TEPC.

Use of Computer-Processed Data. We did not use computer-processed data to perform 

this audit. 

Review of Internal Controls 

We reviewed internal controls that related to project management principles required by 

NPR 7120.5D and EA-WI-023; the ISS MORD requirements for measuring and 

monitoring astronaut radiation exposure; and NPR 8000.4A risk management 

requirements. We found instances where NASA’s project and risk management 

requirements and internal controls were not followed. Specifically: (1) NASA’s baseline 

cost estimate and schedule milestones for the ARI Project were not supported by reliable 

data; (2) the ISS Program expended funds developing a replacement radiation monitoring 

instrument that did not meet existing ISS medical operations requirements; (3) NASA has 

never met the requirement to monitor astronaut exposure to neutrons while aboard the 

ISS; and (4) NASA had not adequately reported the neutron risk in the ISS risk database. 

Our recommendations, if implemented, will correct the identified control weaknesses. 

Prior Coverage

During the last 5 years, NASA and the NASA OIG have issued two reports of particular 

relevance to the subject of this report. Unrestricted NASA OIG reports can be accessed 

over the Internet at http://oig.nasa.gov/audits/reports/FY11. 

NASA Office of Inspector General

“NASA’s Management of the Mars Science Laboratory Project” (IG-11-019, June 8, 

2011) 

James Webb Space Telescope (JWST) - Independent Comprehensive Review Panel 

(ICRP)

JWST-ICRP Final Report (October 29, 2010), accessible at 

http://www.nasa.gov/pdf/499224main_JWST-ICRP_Report-FINAL.pdf
APPENDIX B 

20 REPORT NO. IG-11-027 

RADIATION EXPOSURE LIMITS AND 

HEALTH EFFECTS

Terrestrial radiation guidelines are considered too restrictive for space activities. For 

space flight activities, NASA has adopted the recommendations of the National Council 

on Radiation Protection. Based on the Council’s recommendations, NASA has 

established career limits for ISS crewmembers’ exposure to space radiation. Specifically, 

the Agency limits individual risk to 3 percent Risk of Exposure-Induced Death (REID) 

from cancer.21 The acknowledged risk for the population at large of developing and 

dying of cancer is 20 out of every 100 people. NASA requires that astronauts’ increased 

risks due to space radiation exposure will not be more than 3 percent above the estimate 

for the general population, or no more than 23 out of every 100 people. Each year, a 

NASA Radiation Specialist generates the Astronaut’s Annual Radiation Exposure Report, 

which tracks astronauts’ career exposures. Due to privacy issues, we did not review 

astronauts’ medical records. However, at our request, the NASA Radiation Health 

Officer provided non-specific summary medical data that showed 12 astronauts have 

flown to the ISS in the last 2 years. All 12 astronauts were below 3 percent REID, with 

the maximum only at about 0.52 percent REID.22

Table 2 shows NASA’s astronaut radiation exposure limits by organ and exposure 

interval. These limits are considerably higher than those for terrestrial radiation workers, 

which are 5 rem per year.

 Therefore, all crewmembers who flew 

in the last 2 years were below the career risk limit stated in the NASA standard.

23

 

21 REID is the lifetime risk that an individual in the population will die from cancer caused by his or her 

radiation exposure. 

 

22 The data does not include the 10 astronauts who flew on the final two Space Shuttle missions: STS-134 

in May 2011 and STS-135 in July 2011.

23 Rem (or Roentgen Equivalent Man) is a standard unit for measuring the effective radiation dose, which 

combines the amount of energy from any type of ionizing radiation that is deposited in human tissue 

along with the medical effects of the given type of radiation. 
APPENDIX B 

REPORT NO. IG-11-027 21

Table 2. Organ Specific Radiation Exposure Limits for Astronauts 

Exposure 

Interval Blood Forming Organs Eye Skin

30 Days 25 rem 100 rem 150 rem 

Annual 50 rem 200 rem 300 rem 

Career 150 – 400 rem [200 + 7.5(age - 30) for men] 

100 – 300 rem [200 + 7.5(age - 38) for women] 

400 rem 600 rem 

Source: Space Radiation Analysis Group, Johnson Space Center website, accessed at 

http://srag.jsc.nasa.gov/SpaceRadiation/Why/Why.cfm, accessed April 25, 2011. 

Exposure to a dose of 25 to 100 rem will produce mild weakness and changes in blood 

count. A dose of 100 to 650 rem will cause vomiting and changes to the blood but 

prognosis is still good at the upper range. Doses of 650 to 1,000 rem will completely 

destroy bone marrow and survival may depend on intense medical intervention. A dose 

of more than 1,000 rem is almost invariably fatal. Table 3 shows radiation doses that 

astronauts receive in space and exposure one might receive from terrestrial activities. 

Table 3. Comparison of Radiation Exposure in Space and on Earth 

Type of Exposure Dose Equivalent* 

ISS (Maximum Blood Forming Organ Dose in 

U.S. Segment) 

16 rem/year 

Space Shuttle (Maximum Skin Dose) 7.9 rem/mission 

Apollo 14 (Maximum Skin Dose) 1.4 rem/mission 

CT Scan (Chest) .7 rem/event 

Barium Enema .4 rem/event 

Airline Flight Crew .2 rem/year

Houston Background .1 rem/year * The amount of biological damage caused by radiation varies with the amount of energy absorbed (dose). 

Radiation “dose equivalent” is a measurement that relates the amount of energy actually absorbed by 

human tissue to the effective biological damage of the radiation. 

Source: Space Radiation Analysis Group, Johnson Space Center website, http://sragnt.jsc.nasa.gov/SpaceRadiation/FAQ/FAQ.cfm, accessed July 6, 2011; and NASA Public Lessons Learned 

Database Entry 1071, “ISS Program/Radiation Exposure/Effects on Crew,” February 1, 1998. 
APPENDIX C

22 REPORT NO. IG-11-027 

MANAGEMENT COMMENTS
APPENDIX C

REPORT NO. IG-11-027 23
APPENDIX C

24 REPORT NO. IG-11-027 
APPENDIX C

REPORT NO. IG-11-027 25
APPENDIX D 

26 REPORT NO. IG-11-027 

REPORT DISTRIBUTION

National Aeronautics and Space Administration

Administrator

Deputy Administrator

Chief of Staff

Chief Health and Medical Officer

Associate Administrator for the Human Exploration and Operations Mission Directorate

Assistant Associate Administrator for International Space Station 

NASA Advisory Council’s Audit, Finance, and Analysis Committee 

Director, Johnson Space Center 

Program Manager, International Space Station 

Manager, International Space Station Vehicle Office

Director, Space Life Sciences

Director, Engineering Directorate

Chief, Avionic Systems Division

Non-NASA Organizations and Individuals

Office of Management and Budget

Deputy Associate Director, Energy and Science Division

Branch Chief, Science and Space Programs Branch

Government Accountability Office 

Director, NASA Financial Management, Office of Financial Management and 

Assurance 

Director, NASA Issues, Office of Acquisition and Sourcing Management 

Congressional Committees and Subcommittees, Chairman and 

Ranking Member

Senate Committee on Appropriations 

Subcommittee on Commerce, Justice, Science, and Related Agencies

Senate Committee on Commerce, Science, and Transportation

Subcommittee on Science and Space

Senate Committee on Homeland Security and Governmental Affairs

House Committee on Appropriations 

Subcommittee on Commerce, Justice, Science, and Related Agencies

House Committee on Oversight and Government Reform 

Subcommittee on Government Organization, Efficiency, and Financial Management

House Committee on Science, Space, and Technology 

Subcommittee on Investigations and Oversight 

Subcommittee on Space and Aeronautics
REPORT NO. IG-11-027 27

Major Contributors to the Report: 

Rebecca Sharek, Director, Space Operations 

Kenneth Sidney, Project Manager 

Ellis Lee, Lead Auditor 

Dennis Clay, Auditor 

Connia Webb, Management Analyst 
SEPTEMBER 29, 2011

REPORT No. IG-11-027 

OFFICE OF AUDITS

OFFICE OF INSPECTOR GENERAL

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