NUCLEAR 

NONPROLIFERATION

Stronger Planning and 

Evaluation Needed for 

Radiological Security 

Zone Pilot Project

Report to Congressional Committees

March 2014

GAO-14-209

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-209, a report to 

congressional committees 

March 2014 

NUCLEAR NONPROLIFERATION

Stronger Planning and Evaluation Needed for 

Radiological Security Zone Pilot Project

Why GAO Did This Study

U.S. and international security experts 

have raised concerns that certain types 

of radioactive material could be used to 

make a terrorist weapon, known as a 

radiological dispersal device or a “dirty 

bomb.” Such material, which is 

typically sealed in a metal capsule 

known as a sealed radiological source, 

is commonly used worldwide in

medical and industrial settings. To help 

secure these sources, in 2012, NNSA 

began an RSZ pilot project in two 

countries.

The National Defense Authorization 

Act for Fiscal Year 2013 mandated 

GAO to, among other things, assess 

efforts to establish RSZs. In this study, 

GAO (1) examined current federal 

efforts to secure radiological sources in 

the United States and in foreign 

countries and (2) assessed NNSA’s 

efforts to plan for and establish an RSZ 

pilot project. GAO reviewed relevant 

regulations and guidance for securing

U.S. and international radiological 

sources, as well as NNSA’s RSZ pilot 

project documents; examined GAO 

guidance and professional practices for 

planning and evaluating pilot projects; 

interviewed officials from NNSA, NRC, 

State, and the Department of 

Homeland Security; and obtained 

written responses to questions from 

IAEA.

What GAO Recommends

GAO recommends that NNSA, if it 

proceeds with further work beyond its 

current RSZ pilot project, (1) obtain 

stakeholder expertise and perspectives

and (2) develop a specific evaluation 

plan for RSZs. NNSA agreed with 

these recommendations.

What GAO Found

Two U.S. agencies—the Nuclear Regulatory Commission (NRC) and the 

National Nuclear Security Administration (NNSA)—have several ongoing efforts, 

both in the United States and internationally, to secure radiological sources that 

could be used to make a terrorist weapon. These efforts include strengthening 

regulatory requirements, upgrading security, and recovering unwanted or 

abandoned radiological sources. Domestically, NRC has worked to strengthen 

regulatory requirements to provide reasonable assurance that U.S. licensees 

protect high-risk radiological sources. In addition, at the request of licensees,

NNSA provides voluntary security upgrades designed to raise security to a level 

above existing regulatory requirements, consistent with best practices that NNSA 

has identified. These upgrades include, for example, motion sensors and alarms 

that are tracked by staff at remote monitoring centers. Internationally, NRC has 

spent about $12 million since 2002 to help countries establish and strengthen 

their regulatory frameworks. From fiscal year 2008 through March 2013, NNSA 

has spent about $304 million to help remove or secure radiological sources in 

foreign locations. However, NNSA officials said that applying the highest 

standards and best practices used for domestic security upgrades may not be 

feasible in some other countries, in part, because some countries do not have 

the reliable communication systems needed to support the most up-to-date 

remote monitoring systems.

In 2012, NNSA established a radiological security zone (RSZ) pilot project that 

seeks to establish and sustain the highest standard of physical security 

measures and best practices at specific sites in Mexico City and Peru, but it did 

not complete some important planning and evaluation steps. NNSA undertook 

several planning steps, including identifying the scope of project activities and 

developing a project schedule to track the progress of project activities, which are 

expected to cost about $10 million. However, it did not engage some key 

stakeholders—such as NRC, the Department of State (State) and the 

International Atomic Energy Agency (IAEA)—early on while planning its pilot 

project or develop a specific evaluation plan for the project. By not following the 

professional practice of early engagement of key stakeholders, NNSA may have 

missed opportunities to obtain and leverage the expertise, perspectives, and 

resources of these agencies. For example, if IAEA had been involved early in the 

RSZ pilot project, it could have shared its expertise and perspectives based on 

its long-standing involvement in regional radiological security collaborations. 

Regarding the evaluation plan, NNSA officials told GAO that they will evaluate 

the completed pilot project to determine whether it was sufficiently successful to 

merit expanding RSZ projects to other countries. However, NNSA has not 

developed a specific plan to evaluate the pilot project’s success that includes 

several key features of a well-developed evaluation plan. For example, such a 

plan would include well-defined, clear, and measurable project objectives that 

would demonstrate the success of the project. Having a specific and welldeveloped evaluation plan could help NNSA enhance the credibility and 

effectiveness of future RSZ projects, if NNSA decides to continue beyond its 

current pilot project. View GAO-14-209. For more information, 

contact Steve D. Morris at (202) 512-3841 or 

morriss@gao.gov. 
Page i GAO-14-209 Radiological Security Zone 

Letter 1 

Background 4

Federal Agencies Have Several Ongoing Efforts to Secure 

Radiological Sources in the United States and in Foreign 

Countries 8

NNSA Established an RSZ Pilot in Two Countries, but It Did Not 

Complete Some Important Planning and Evaluation Steps 16

Conclusions 25

Recommendations for Executive Action 26

Agency Comments 26

Appendix I Scope and Methodology 29

Appendix II Probabilities and Potential Consequences of Terrorist Attacks with 

Nuclear or Radiological Weapons 33

Appendix III Estimates of Buildings outside the United States Housing High-Risk 

Radiological Sources over 1,000 Curies 37

Appendix IV International Coordination by NNSA and NRC to Secure Radiological 

Material Abroad 38

Appendix V Examples of Regional Collaboration to Improve Security of 

Radiological Sources 39

Appendix VI Comments from the National Nuclear Security Administration 41

Appendix VII Comments from the Nuclear Regulatory Commission 42

Contents
Page ii GAO-14-209 Radiological Security Zone 

Appendix VIII GAO Contact and Staff Acknowledgments 43

Tables

Table 1: Radionuclides and Associated Thresholds, Measured in 

Curies, Identified as Warranting Enhanced Security and 

Protection 6

Table 2: NNSA’s Key Objectives and Examples of Best Practices 

for Its Domestic Security Upgrades Program 11

Table 3: Estimates of Buildings outside the United States with 

High-Risk Radiological Sources in Excess of 1,000 Curies 

in 93 Other-Than-High-Income Countries, by Region 37

Table 4: Regional Collaboration Project Summaries and 

Participating Countries 39

Figure

Figure 1: Example of a Radiological Source That Contains 

Americium-241 8
Page iii GAO-14-209 Radiological Security Zone 

Abbreviations

AFRA African Regional Cooperative Agreement for Research,

 Development, and Training Related to Nuclear Science

 and Technology

ANSTO Australian Nuclear Science and Technology Organization

DHS Department of Homeland Security

DOE Department of Energy

GTRI Global Threat Reduction Initiative

IAEA International Atomic Energy Agency

IND improvised nuclear device

NNSA National Nuclear Security Administration

NRC Nuclear Regulatory Commission

OSRP Off-site Source Recovery Project

RDD radiological dispersal device

RED radiological exposure device

RSZ radiological security zone

RTG radioisotope thermoelectric generator

State Department of State

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Page 1 GAO-14-209 Radiological Security Zone 

441 G St. N.W.

Washington, DC 20548

March 6, 2014

Congressional Committees

U.S. and international security experts have raised concerns that certain 

types of commercially available sources of radioactive materials could be 

combined with an explosive device and used by terrorists to construct a 

crude but potentially dangerous weapon known as a radiological dispersal 

device or a “dirty bomb.” For commercial uses, radioactive material—such 

as cesium-137, cobalt-60, and americium-241—is typically sealed in a 

capsule made of metal—such as stainless steel, titanium, or platinum—to 

prevent its dispersal; these capsules are often referred to as sealed 

radiological sources.1

An attack with a dirty bomb would not likely cause many deaths; however,

it could have significant impacts. For example, in 2002, the Federation of 

American Scientists concluded that an attack with a dirty bomb composed 

of an americium source combined with 1 pound of explosives would 

require that the population of an area 10 times larger than the area hit by 

the immediate blast receive medical supervision and monitoring. A dirty 

bomb explosion could also cause significant social and economic impacts 

from public panic, decontamination costs, and prolonged denial of access 

to the explosion area while the area is being decontaminated. A 2004 

study by the National Defense University noted, for example, that the 

economic impact on a major populated area from a successful dirty bomb 

attack is likely to equal, or perhaps exceed, that of the September 11, 

2001, terrorist attacks on New York City and the Pentagon.

Radiological sources are commonly used 

throughout the United States and other countries for many beneficial 

purposes, such as diagnosing and treating cancer, sterilizing blood, 

preserving food, detecting flaws in pipeline welds, and exploring for oil 

and gas. Such radiological sources are often located in hospitals and 

universities, which are typically open environments. The small size and 

portability of many radiological sources also makes them vulnerable to 

theft or misuse when they are not adequately secured.

 

1

This report focuses on radioactive material used for commercial applications, which is 

typically found in sealed radiological sources, hereafter referred to as radiological sources. 

For the purposes of this report, the term “radioactive material” excludes nuclear material 

(i.e., highly enriched uranium and plutonium), which could be used for a nuclear weapon.
 

Page 2 GAO-14-209 Radiological Security Zone 

Past accidents involving radiological sources illustrate the types of health 

and decontamination problems that could occur in the case of a dirty 

bomb attack. For example, a serious radiological accident occurred in 

Goiânia, Brazil, in September 1987, which resulted in four deaths and the 

contamination of 249 people. Moreover, the accident and its aftermath 

caused about $36 million in damages to the region, and the 

decontamination process, which required the demolition of homes and 

other buildings, generated about 3,500 cubic meters of radioactive waste.

Concerns about thefts of radiological sources and the possible 

consequences of a dirty bomb attack persist. For example, their potential 

vulnerability to theft was highlighted in December 2013 when a truck in 

Mexico carrying a dangerous cobalt-60 source formerly used in medical 

treatment was stolen, but it was recovered a few days later. According to 

officials at the National Nuclear Security Administration (NNSA),2 the 

incident is still under investigation by Mexican officials, and it is currently 

uncertain whether the intended target of the theft was the truck or the 

source. Moreover, according to a nonproliferation expert writing in the 

Bulletin of the Atomic Scientists, had the pressure cooker explosive 

devices used in the April 2013 Boston bombing contained radioactive 

material, every aspect of the emergency and law enforcement response 

would have been significantly more complicated.3

Given the concerns that radiological sources could be used in a dirty 

bomb, the President of the Partnership for Global Security

Among other things, a 

radioactively contaminated crime scene could have hampered immediate 

assistance to victims and delayed acquisition of the photos and video that 

helped identify the bombers.

4

 

2

NNSA was created by title XXXII the National Defense Authorization Act for Fiscal Year 

2000, Pub. L. No. 106-65 (1999). It is a separate semiautonomous agency within the 

Department of Energy (DOE), with responsibility for the nation’s nuclear weapons, 

nonproliferation, and naval reactors programs.

proposed 

3

George M. Moore, “If the Boston Marathon Attack Had Involved Dirty Bombs,” Bulletin of 

the Atomic Scientists, Web edition, May 1, 2013, accessed June 13, 2013. 

http://www.thebulletin.org/web-edition/features/if-the-boston-marathon-attack-hadinvolved-dirty-bombs. 

4

The Partnership for Global Security is a nonprofit research organization that conducts a 

global, cooperative effort to keep nuclear and radioactive materials safe and secure. The 

organization works closely with many governments and international experts to develop 

new security initiatives and to ensure the timely and effective implementation of existing 

nonproliferation programs.
 

Page 3 GAO-14-209 Radiological Security Zone 

during a congressional hearing in March 2012 that the United States 

assist in efforts to secure these sources by establishing a U.S.–

international initiative to create “radiological security zones” (RSZ) in key 

regions around the world.5

In this context, Section 3150 of the National Defense Authorization Act for 

Fiscal Year 2013 mandated GAO to study U.S. efforts to secure 

radiological sources, both domestically and abroad, and assess certain 

aspects of regional radiological security zones.

Under the Partnership for Global Security 

proposal, NNSA would work with foreign countries to, among other things, 

review national regulations and discuss security upgrade options. 

According to the Partnership for Global Security, the establishment of 

RSZs, if successful, could be a stepping stone to new regional 

collaborations on nuclear security.

6

To conduct this work, we reviewed relevant literature, regulations, and 

guidance for overseeing radiological sources, including NNSA’s 

documentation for its RSZ pilot project. We interviewed agency officials at 

NNSA, the Nuclear Regulatory Commission (NRC), the Department of 

Homeland Security (DHS), and the Department of State (State). We also 

interviewed the President of the Partnership for Global Security, who 

proposed the concept of RSZs, and obtained written responses to 

questions that we submitted to the International Atomic Energy Agency 

(IAEA).

Specifically, this report 

(1) examines current federal efforts to secure radiological sources in the 

United States and in foreign countries and (2) assesses NNSA’s efforts to 

plan for and establish an RSZ pilot project in foreign countries.

7

 

5

The Nuclear Security Summit and Global Nuclear Security Governance for the 21st 

Century: Hearing Before the S. Comm. on Homeland Security and Governmental Affairs, 

Subcomm. on Oversight of Government Management, the Federal Workforce, and the 

District of Columbia, 112th Cong., (2012) (statement of Kenneth N. Luongo, President, 

Partnership for Global Security). 

To examine current federal efforts to secure radiological sources 

in the United States and in foreign countries, we reviewed documents and 

program guidance and interviewed officials responsible for overseeing or 

6

Pub. L. No. 112-239, § 3150, 126 Stat. 1632, 2201 (2013).

7

Based in Vienna, Austria, IAEA is an independent international organization that is 

affiliated with the United Nations. It has the dual mission of promoting the peaceful uses of 

nuclear energy and verifying that nuclear materials intended for peaceful purposes are not 

diverted to military purposes. IAEA also assists other countries with the safety and 

security of their radiological sources.
 

Page 4 GAO-14-209 Radiological Security Zone 

securing radiological sources domestically and in foreign countries at 

NRC, NNSA, and DHS. We reviewed prior GAO reports on U.S. efforts to 

secure radiological sources domestically and in foreign countries. We 

obtained information from IAEA about U.S. efforts to work with IAEA on 

radiological security programs. To assess NNSA’s efforts to plan for and 

establish an RSZ pilot project in foreign countries, we interviewed officials 

at NNSA responsible for overseeing and implementing the agency’s RSZ 

pilot project. We reviewed documents and guidance on the RSZ pilot 

project and analyzed cost data pertaining to both the RSZ pilot project 

and past efforts to implement radiological security upgrades at the pilot 

project locations. We assessed the reliability of these data and found the 

data to be sufficiently reliable for our reporting purposes. We also 

identified and reviewed prior GAO reports and practices used by 

professional evaluators for planning and evaluating pilot projects. We 

interviewed representatives from the Partnership for Global Security and 

agency officials from NNSA, NRC, DHS, and State to discuss potential 

challenges to establishing RSZs internationally. Appendix I presents the 

scope and methodology of our review in more detail.

We conducted this performance audit from February 2013 to March 2014 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The IAEA Code of Conduct on the Safety and Security of Radioactive 

Sources (Code of Conduct)—which, as of October 2013, had received 

political commitments for implementation from the United States and 118 

other countries—is a well-established international norm for identifying 

high-risk radiological sources.8 The Code of Conduct lists 16 

radionuclides9

 

8

IAEA, Code of Conduct on the Safety and Security of Radioactive Sources (Vienna, 

Austria: 2004). 

that are commonly used in radiological sources, classifying 

9

Radionuclides are unstable isotopes of an element that decay or disintegrate 

spontaneously, thereby emitting radiation.

Background
 

Page 5 GAO-14-209 Radiological Security Zone 

the most dangerous as Category 1 and Category 2.10

The United States uses IAEA’s Code of Conduct as guidance to define 

high-risk radiological sources that warrant enhanced security and 

protection in light of potential terrorist threats, including the use of a 

radiological dispersal device. Because terrorists could use radioactive 

material from one or more radiological sources to construct a weapon, the 

United States also uses the Code of Conduct as guidance to identify highrisk quantities of radioactive material. More specifically, a U.S. 

interagency task force,

The categories are 

based upon the relative health hazards for each radionuclide at certain

threshold levels. If not managed safely or securely, according to the Code 

of Conduct, Category 1 radiological sources could lead to permanent 

injury (such as burns requiring surgery) to an individual in contact or in 

close proximity to the source for more than a few minutes and death to an 

individual in contact or in close proximity for more than a few minutes to 

an hour. For a Category 2 radiological source, permanent injury could 

result to an individual in contact or in close proximity to the source for 

minutes to hours, and death could result from exposure for a period from 

hours to days.

11

 

10In IAEA’s Categorization of Radioactive Sources (Vienna, Austria: 2005), it describes 

five categories of radiological sources in terms of their hazards, ranging from the most 

dangerous, Category 1, to least dangerous, Category 5, which is defined as the most 

unlikely to be dangerous if close to a person. IAEA’s categorization concentrates on 

dangers that immediately threaten lives or cause permanent injuries, and it does not 

consider possible delayed health effects such as radiation-induced cancer that exposed 

persons might later develop.

which was mandated in 2005 to help protect and 

secure radiological sources, has examined security concerns for 

Category 1 or Category 2 quantities of radioactive material—namely, 

radioactive material aggregated in a location that in total meets or 

exceeds the Category 1 or Category 2 thresholds in the Code of Conduct. 

11Under the Energy Policy Act of 2005, a U.S. interagency task force is required—not less 

than once every 4 years—to evaluate and provide recommendations to the President and 

Congress related to securing U.S. radiological sources from terrorist threats. The Task 

Force is composed of representatives from the NRC (Chair), DHS, Department of 

Defense, DOE and NNSA, Department of Transportation, Department of Justice, State, 

Office of the Director of National Intelligence, Central Intelligence Agency, Federal 

Emergency Management Agency, Federal Bureau of Investigation, Environmental 

Protection Agency, Office of Science and Technology Policy, and Department of Health 

and Human Services. The task force includes a nonvoting member representing two 

professional organizations that work on radiation protection and with NRC on regulatory 

issues. 
 

Page 6 GAO-14-209 Radiological Security Zone 

In its 2010 report,12 the task force evaluated high-risk radionuclides based 

on their health hazards—the same basis as in the Code of Conduct—as 

well as on their potential economic, social, and psychological 

consequences if used in a radiological dispersal device (e.g., a dirty 

bomb) or a radiological exposure device.13

Table 1: Radionuclides and Associated Thresholds, Measured in Curies, Identified 

as Warranting Enhanced Security and Protection

(See app. II for a discussion of 

the different probabilities and consequence of a terrorist attack using 

radiological sources versus nuclear material.) The task force concluded 

that Category 1 and Category 2 quantities of 16 radionuclides listed in the 

Code of Conduct pose the highest risk and thus warrant enhanced 

security and protection. (See table 1 for the high-risk radionuclides 

identified by the task force.)

Radionuclide

International Atomic 

Energy Agency (IAEA) 

Category 2 threshold

(curies)

IAEA Category 1 

threshold

(curies)

Americium (Am)-241 16 1,600

Americium (Am)-241/beryllium 16 1,600

Californium (Cf)-252 5 500

Curium (Cm)-244 14 1,400

Cobalt (Co)-60 8 800

Cesium (Cs)-137 27 2,700

Gadolinium (Gd)-153 270 27,000

Iridium (Ir)-192 22 2,200

Promethium (Pm)-147 11,000 1,100,000

Plutonium (Pu)-238 16 1,600

Plutonium (Pu)-239/beryllium 16 1,600

Radium (Ra)-226 11 1,100

Selenium (Se)-75 54 5,400

 

12Radiation Source Protection and Security Task Force, The 2010 Radiation Source 

Protection and Security Task Force Report (Washington, D.C.: 2010).

13A radiological dispersal device is designed to radioactively contaminate people and an 

area by spreading radioactive materials, such as through a dirty bomb explosion or other 

means. In contrast, a radiological exposure device is designed to expose people to 

harmful doses of ionizing radiation as they pass by a partially or fully unshielded 

radiological source that might be concealed in a populated location.
 

Page 7 GAO-14-209 Radiological Security Zone 

Radionuclide

International Atomic 

Energy Agency (IAEA) 

Category 2 threshold

(curies)

IAEA Category 1 

threshold

(curies)

Strontium (Sr)-90 (yttrium-90) 270 27,000

Thulium (Tm)-170 5,400 540,000

Ytterbium (Yb)-169 81 8,100

Source: GAO analysis of The 2010 Radiation Source Protection and Security Task Force Report.

Note: The threshold for Category 1 sources is 100 times that for Category 2 sources, as defined by 

the IAEA. 

A 2008 National Research Council report indicates some of these 

radionuclides raise greater security concerns because of their prevalence 

in the United States or their physical characteristics.14

 

14National Research Council, Radiation Source Use and Replacement: Abbreviated 

Version. (Washington, DC: The National Academies Press, 2008). The National Research 

Council is the operating arm of the National Academy of Sciences and National Academy 

of Engineering. Through its independent, expert reports; workshops; and other scientific 

activities, its mission is to improve government decision making and public policy, 

increase public understanding, and promote the acquisition and dissemination of 

knowledge in matters involving science, engineering, technology, and health.

According to the 

report, four of these—americium-241, cesium-137, cobalt-60, and iridium192—account for nearly all (over 99 percent) of the radiological sources 

that pose the highest security risks in the United States. (Fig. 1 illustrates 

an americium-241 radiological source.) The National Research Council 

report stated that cesium-137 in the form of cesium chloride raises special 

security concerns because it is a dispersible powder, soluble in water, 

and present in large population centers across the country. The U.S. 

interagency task force periodically reassesses whether factors such as 

the threat environment have changed and whether the list of 

radionuclides warranting enhanced security and protection needs to be 

changed.
 

Page 8 GAO-14-209 Radiological Security Zone 

Figure 1: Example of a Radiological Source That Contains Americium-241

In the United States, radiological sources for commercial applications are 

licensed and regulated by NRC or Agreement States, that is, by states 

that have a signed agreement with NRC authorizing them to regulate 

certain uses of radioactive materials within their borders. As of July 2013, 

there were 37 Agreement States. NRC and Agreement States work 

together to create a U.S. regulatory framework designed to prevent 

unauthorized use of radioactive material; the framework includes 

licensing, inspection, and enforcement. NRC and state regulators conduct 

periodic inspections to ensure that those licensed to possess radiological 

sources are meeting security requirements.

NRC and NNSA—the two federal agencies primarily involved in securing 

radiological sources in the United States and foreign countries—have 

several ongoing efforts to do so, including strengthening regulatory 

requirements, upgrading security, and recovering unwanted or 

abandoned radiological sources. NNSA is using the lessons learned from 

its domestic efforts as a model for its current international assistance, but 

NNSA officials said that applying the highest standards and best practices 

used for domestic security upgrades may not be feasible in some other 

countries because of certain constraints.

NRC and regulators in the 37 Agreement States have sought to 

strengthen regulatory requirements and oversight of licensees, with a 

focus on the high-risk radioactive material—that is, Category 1 and 

Federal Agencies 

Have Several 

Ongoing Efforts to 

Secure Radiological 

Sources in the United 

States and in Foreign 

Countries

NRC Regulatory 

Requirements
 

Page 9 GAO-14-209 Radiological Security Zone 

Category 2 sources and quantities. These changes are intended to 

provide reasonable assurance of preventing the theft or diversion of highrisk material. The regulatory framework contains requirements governing: 

(1) access to and use of high-risk radioactive materials; (2) background 

investigations on individuals who are to be allowed unescorted access to 

high-risk radioactive materials; (3) the monitoring, detection, assessment 

of and response to actual or attempted unauthorized access to high-risk 

radioactive materials; (4) reporting of actual or attempted theft, sabotage 

or diversion of high-risk radioactive materials; (5) coordination with local 

law enforcement officials; and (6) protection of high-risk radioactive 

materials during transport. In addition, to improve regulators’ oversight of 

the possession of the currently more than 75,000 Category 1 and 

Category 2 radiological sources in the United States, NRC deployed the 

National Source Tracking System in 2009 to track these sources over 

their life cycles.15

In 2012, we found that NRC had taken a risk-based approach that 

allowed licensees to develop security programs specifically tailored to 

their U.S. hospitals and medical facilities.

Licensees are required by regulation to enter 

information on the manufacture, receipt, transfer, or disposal of these 

sources into NRC’s database.

16

 

15 In addition, NRC expanded the list of nationally tracked radiological sources by adding 

four radionuclides (i.e., actinium-227, polonium-210, thorium-228, and thorium-229) not 

included in IAEA’s list of Category 1 and 2 radionuclides.

However, we found NRC’s 

approach was not based on facility-specific security risks and had 

resulted in a wide variety of security measures implemented by the 

medical facilities we visited. Licensees had implemented these broad 

requirements in various ways, leaving some facilities’ radiological sources 

more vulnerable than others. The risk-based requirements did not 

consistently ensure the security of high-risk radiological sources as 

several of the medical facilities we visited did not have adequate security 

measures in place, which left the sources more at risk for sabotage and 

theft. One reason we found for the inconsistent security was that NRC 

security controls did not prescribe the specific measures that licensees 

should take to secure their sources, such as specific direction on the use 

of cameras, alarms, and other physical security measures. We 

recommended that NRC (1) strengthen security requirements by 

16GAO, Nuclear Nonproliferation: Additional Actions Needed to Improve Security of 

Radiological Sources at U.S. Medical Facilities, GAO-12-925 (Washington, D.C.: Sept. 10, 

2012). 
 

Page 10 GAO-14-209 Radiological Security Zone 

providing hospitals and medical facilities with specific measures they 

must take to develop and sustain a more effective security program, (2) 

ensure that federal and state inspectors receive more comprehensive 

training to improve their security awareness and ability to conduct related 

security inspections, and (3) supplement existing guidance for facility 

officials who may be responsible for implementing NRC’s security 

controls. In its response to these recommendations, NRC said that it 

disagreed that its security requirements needed strengthening through 

more prescriptive security measures, stating that its performance-based 

approach provides adequate protection and gives licensees the flexibility 

to tailor effective security measures across a wide variety of licensed 

facilities. However, in response to the other two recommendations, NRC 

stated that inspectors would receive updated training after it reviewed and 

revised its inspector qualification program and that it plans to develop 

additional guidance to licensees on how to comply with regulatory 

requirements.

NNSA conducts a domestic program that provides voluntary security

upgrades when requested by licensees that use radiological sources in 

the United States. These upgrades are designed to raise security at U.S. 

facilities with high-risk radiological sources to a level above NRC and the 

Agreement State’s regulatory requirements, which are intended to be the 

minimum requirements that reasonably assure adequate protection. 

When requested by the licensee, NNSA assesses existing security 

conditions, recommends security upgrades, funds the procurement and 

installation of jointly agreed-upon security measures that are consistent 

with best practices NNSA has identified, and provides a 3- to 5-year 

warranty period for maintaining the security upgrades. The upgrades are 

intended to constitute a security system that serves NNSA’s key program 

objectives of detecting, delaying, and responding to thefts of radiological 

sources. (Table 2 describes key objectives and best practices identified 

by NNSA.)

NNSA’s Domestic Security 

Upgrades Program
 

Page 11 GAO-14-209 Radiological Security Zone 

Table 2: NNSA’s Key Objectives and Examples of Best Practices for Its Domestic Security Upgrades Program

Key objectives Examples of best practices

Delay access to radiological sources Security upgrades—such as security doors, bulletproof glass, and grating over 

windows—are designed to increase the time needed by a potential adversary to enter a 

room or building containing radiological sources. The National Nuclear Security 

Administration (NNSA) also funds the installation of hardware (known as an in-device 

delay kit) for certain devices to slow access to the radiological sources within them.

Prompt detection and reliable notification of 

unauthorized access

A suite of detection upgrades—such as iris scanners, door alarms, motion sensors, 

cameras, wireless electronic tamper-indicating seals, and area radiation monitors—are 

intended to promptly alert an armed-response force to unauthorized access to 

radiological sources and thereby increase the likelihood of a timely response. A key 

feature of enhanced notification for response forces is a remote monitoring system that 

transmits detection alarms and information to on-site and off-site monitoring stations. 

Remote monitoring systems are intended to address two key security vulnerabilities: (1) 

reliable transmission of alarms to the responders and (2) the insider threat from site 

personnel, who may possess knowledge of security procedures and weaknesses.

Well-trained and equipped responders A well-trained and well-equipped response force is expected to better interrupt and 

neutralize a potential adversary. NNSA has developed an alarm response training course 

run by the Y-12 National Security Complex in Oak Ridge, Tennessee, to help prepare 

responders to protect themselves and the public when responding to a security incident. 

Source: GAO analysis of NNSA data.

NNSA’s program has some structural and budgetary limitations. First, as 

we noted in our 2012 report, the program is voluntary and, therefore, 

NNSA’s upgrades are made only if requested by licensees.17

 

17

As of July 

2012, 14 hospitals and medical facilities had declined to participate in 

NNSA’s security upgrades program. At that time, these 14 facilities 

contained over 41,000 curies of high-risk radioactive material, and 4 are 

located in large urban areas that NNSA officials consider high-risk 

targets. Second, we reported that there are sustainability concerns. For 

example, NNSA asks facilities to commit to sustaining upgrades but, 

according to the agency, it does not have the authority to require that 

facilities maintain the installed security upgrades beyond the agency’s 3- 

to 5-year warranty period. As we stated in our 2012 report, several 

hospitals and law enforcement officials told us that not having a 

requirement to sustain NNSA’s upgrades limits the program’s impact. 

Third, NNSA officials told us that, since our 2012 report, NNSA has 

postponed the estimated completion of its U.S. security upgrades from 

2025 until 2044 because NNSA faces significant budget constraints. As a 

GAO-12-925. 
 

Page 12 GAO-14-209 Radiological Security Zone 

result, some sites with high-risk radiological sources will not receive 

security upgrades for decades.

As of the end of June 2013, NNSA officials reported spending about $140 

million to complete security upgrades on 491 of a projected 2,917 

buildings with high-risk radiological sources. NNSA estimates the 

completion of additional security upgrades for all the buildings will cost 

between $519 million and about $690 million. However, NNSA is still 

determining whether certain security building upgrades are within its 

program scope, which creates uncertainty about the program’s eventual 

costs. Specifically, NNSA officials told us that they have not fully 

assessed storage buildings for mobile devices, such as radiography 

cameras used in field operations to inspect the integrity of pipeline welds 

and, therefore, have not decided whether to upgrade security at these 

buildings. We are currently reviewing federal security efforts for these 

mobile devices and other industrial radiological sources and plan to report 

on this issue in 2014.

NNSA’s domestic security program also supports remote monitoring 

systems for radiological sources in some existing monitoring centers, 

which may be established by law enforcement agencies or can be 

operated by a commercial monitoring company. These centers provide 

off-site monitoring of alarm and video data from facilities housing 

radiological sources and allow law enforcement agencies to monitor and 

respond to security incidents. NNSA has helped support remote 

monitoring in New York City, Hawaii, and at 10 Department of Agriculture 

irradiator facilities located in the United States and Central America. 

According to NNSA, as of March 2013, the agency had spent about 

$500,000 to provide remote monitoring software development and alarm 

signal integration, among other things, at these facilities in the United 

States. Because participation in this program is also voluntary, NNSA 

officials told us that they have no plan to integrate the existing remote 

monitoring centers into a comprehensive regional structure within the 

United States.
 

Page 13 GAO-14-209 Radiological Security Zone 

NNSA operates the Off-site Source Recovery Project (OSRP) in the 

United States, which is designed to collect certain disused and unwanted 

or abandoned (“orphan”) radiological sources that pose a potential risk to 

national security or public health or safety.18 This recovery project 

includes collecting Category 1 or 2 sources, which are of most concern 

for national security, but it is not limited to these radiological sources. The 

interagency task force has raised the concern that licensees are keeping 

radiological sources in long-term storage because of a lack of a disposal 

path, particularly as a result of the limitations on disposal at facilities 

formed through compacts between states, or because of the high costs of 

disposal.19 For radiological sources that have commercially available 

disposal pathways, NNSA awards a grant to the Conference of Radiation 

Control Program Directors,20

 

18A radiological source that is no longer being used for its authorized purpose is called 

disused. It is generally considered an orphan if it is no longer under regulatory control, 

such as when the responsible licensee cannot be identified or its possessor is not 

licensed.

which works with state regulators to educate 

owners of disused sources about disposal options, guide them through 

the process of commercial source disposal and, in some cases, share 

costs, as incentives to licensees to give up their disused sources. For 

certain other disused or abandoned sources that present public health 

and safety or national security concerns and that do not have a 

commercial disposal pathway, NNSA prioritizes their recovery according 

to threat reduction criteria developed in coordination with NRC. According 

to NNSA officials, sources that have been recovered by NNSA to date 

have been consolidated and disposed of at DOE facilities. NNSA officials 

reported that, from 2009 until June 2013, about 2 percent of the almost 

14,000 collected radiological sources were Category 1 or 2. These 

collected Category 1 and 2 sources accounted for around 98 percent of 

the activity recovered. NNSA officials also reported spending an average 

of about $15 million annually from 2009 through 2012 on the grants and 

OSRP collections. According to NNSA officials, OSRP does not have a 

projected final cost or end date because the total number of disused and 

unwanted or abandoned radiological sources is not fully known, and it is 

19Radiation Source Protection and Security Task Force, 2010 Task Force Report. 

20The Conference of Radiation Control Program Directors is a nonprofit organization 

dedicated to radiation protection. Its members are primarily radiation professionals in state 

and local government that regulate the use of radiological sources.

Domestic Recovery of 

Unwanted or Abandoned 

Radiological Sources
 

Page 14 GAO-14-209 Radiological Security Zone 

uncertain when disposal options that would end the need for the project 

will become available.21

NRC has assisted certain countries in the former Soviet Union since the 

early 2000s and is currently also assisting countries in Latin America, 

Africa, and the Middle East to establish and strengthen regulatory 

controls over the safety and security of radiological sources. Specifically, 

NRC assists these countries’ regulatory authorities to adopt and 

implement key provisions of IAEA’s Code of Conduct, such as developing 

and maintaining a national registry for radiological sources. For instance, 

in early 2013, NRC provided training on developing a national registry of 

radiological sources to staff of the Radiation Protection Authority in 

Zambia and to staff of the nuclear regulatory commission in Jordan. 

According to NRC officials, since 2002, NRC has spent about $12 million 

to assist regulators in over 35 countries.

NNSA has assisted with securing or removing radiological sources in 

more than 85 countries since the inception of its international security 

program in 2002.22

 

21For additional information on the OSRP, see GAO, Nuclear Security: DOE Needs Better 

Information to Guide Its Expanded Recovery of Sealed Radiological Sources, 

(App. III discusses NNSA’s estimate of locations 

outside the United States housing high-risk radiological sources.) Working 

in cooperation with foreign counterparts and international agencies, 

NNSA has conducted site-level security assessments and installed 

physical security upgrades such as access controls, surveillance 

cameras, motion sensors and alarms, and hardened windows and doors. 

NNSA also has provided warranty service, maintenance service, and 

preventative maintenance activities for an initial period of at least 3 years 

after installing the security equipment. NNSA also has provided training 

and workshops for regulatory authorities and response forces on topics 

such as how to develop regulations to strengthen security of radiological 

sources, securely manage radiological sources, and respond to alarms. 

GAO-05-

967 (Washington, D.C.: Sept. 22, 2005) and GAO, Nuclear Nonproliferation: DOE Action 

Needed to Ensure Continued Recovery of Unwanted Sealed Radioactive Sources, GAO03-483 (Washington, D.C.: Apr. 15, 2003).

22In 2007, GAO reported on NNSA’s international efforts to secure radiological sources in 

foreign countries. See GAO, Nuclear Nonproliferation: DOE’s International Radiological 

Threat Reduction Program Needs to Focus Future Efforts on Securing the Highest Priority 

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

NRC and NNSA Assist 

Foreign Countries with 

Strengthening 

Regulations, Upgrading 

Security, and Recovering 

Radiological Sources
 

Page 15 GAO-14-209 Radiological Security Zone 

From fiscal year 2008 through March 2013, NNSA reported spending 

about $220 million on securing radiological sources in foreign countries.

In addition, NNSA has supported the removal of disused and unwanted or 

abandoned sources in foreign countries. This assistance has focused 

primarily on the removal and disposition of radioisotope thermoelectric 

generators (RTG) from Russia. RTGs—large devices designed to provide 

electric power to navigational facilities such as lighthouses and weather 

stations—present a particularly high security risk because they hold highactivity radiological sources containing from 25,000 to 250,000 curies of 

strontium-90. During fiscal year 2012, NNSA removed 34 RTGs. In limited 

cases, NNSA also has repatriated disused sources of U.S. origin, or 

helped recover disused sources and secure them in centralized storage 

facilities within the country they were most recently used. From fiscal year 

2008 through March 2013, NNSA reported spending about $84 million to 

help remove or dispose of radiological sources in foreign countries. (See 

app. IV for a fuller discussion of NRC’s and NNSA’s international 

coordination to help secure radiological sources.)

NNSA is using the lessons learned from its domestic radiological source 

security program as a model for its current international efforts, but it 

faces constraints in applying this model. In 2010, NNSA revised its 

security-upgrade guidance to incorporate lessons learned from its 

domestic program and established a set of what it considers to be best 

practices for radiological security upgrades at all facilities worldwide. 

NNSA officials told us that the best practices added to its 2010 guidance 

primarily include remote monitoring systems, in-device delay kits, and 

alarm response training. To be consistent with these updated best 

practices, according to NNSA officials, NNSA is providing additional 

assistance at overseas sites where security improvements were made 

prior to the new guidance.

NNSA officials told us that the additional security upgrades are intended 

to raise each country’s security to a common standard to the extent 

possible. However, they said that establishing the highest standards and 

best practices used for domestic security upgrades may not be feasible 

when assisting some other countries because of certain constraints. For 

instance, in-device delay kits are not widely available for many devices 

internationally because NNSA has mainly developed kits for blood and 

research irradiators in the United States, which are devices rarely used in 

other countries where NNSA provides assistance. Further, NNSA officials 

told us the installation of the most up-to-date remote monitoring systems 

Constraints on NNSA’s 

Efforts to Raise 

International Radiological 

Security to a Common 

Standard
 

Page 16 GAO-14-209 Radiological Security Zone 

may not be feasible in countries without reliable communications systems 

to support the use of the Internet, which is needed to send alarm and 

video data to monitoring stations. Consequently, they said the security 

upgrades they provide at some sites may be limited to less advanced 

technology, which can still provide an adequate level of security but may 

not be equal to the upgrades that can be used in the United States.

In 2012, NNSA established an RSZ pilot project in two Latin American 

countries, but the agency did not engage some key stakeholders early on 

while planning its pilot project and has not developed a specific evaluation 

plan, thereby potentially missing opportunities to obtain and leverage the 

expertise, perspectives, and resources of those stakeholders and limiting 

its ability to evaluate the final results of the project.

NNSA took steps to establish an RSZ pilot project at sites in Mexico and 

Peru in 2012 after the Partnership for Global Security proposed that the 

United States could showcase an RSZ project as a successful 

nonproliferation project at the 2014 Nuclear Security Summit.23

NNSA defines an RSZ as a geographical area, such as a city, state, 

country, or region, in which stakeholders are committed to establishing 

and sustaining the highest standard of physical security measures and 

best practices. According to NNSA, these best practices should include 

the following, among others:

The 

President for the Partnership for Global Security, as well as officials from 

NRC and State, considered NNSA as the agency most likely to lead the 

RSZ project because of its long experience with international radiological 

source security.

• a robust and holistic regulatory framework that governs secure 

radiological source transportation, possession, and disposition;

 

23As part of the U.S. President’s 2009 pledge to launch a new international effort to secure 

all vulnerable nuclear material around the world, the President hosted world leaders in 

Washington, D.C., at the first Nuclear Security Summit, in 2010. At the 2012 Nuclear 

Security Summit in Seoul, South Korea, world leaders urged countries to secure 

radioactive materials as well as nuclear materials.

NNSA Established an 

RSZ Pilot in Two 

Countries, but It Did 

Not Complete Some 

Important Planning 

and Evaluation Steps

NNSA Is Implementing an 

RSZ Pilot Project in 

Mexico and Peru
 

Page 17 GAO-14-209 Radiological Security Zone 

• multiple access controls that use biometric technology, such as iris 

scanners, to restrict access to radiological sources;

• redundant alarms and video feeds from multiple sites that are sent to 

a centralized monitoring facility;

• enhanced delay measures to allow response forces to arrive in time 

with sufficient strength to contain an adversary; and

• the ability to locate and recover orphan sources.

NNSA’s definition incorporates the physical security measures and best 

practices in its 2010 security-upgrade guidance, and assumes that the 

highest standards possible in the United States—such as a mature 

regulatory framework, remote monitoring systems, and delay measures 

such as in-device delay kits—might also be implemented in foreign 

countries through an RSZ project. As a result, NNSA’s current RSZ 

framework represents an extension of its ongoing international 

radiological security assistance, with more emphasis on helping to bring 

countries’ physical security measures and best practices to the highest 

standards possible.

NNSA officials said that they selected Mexico and Peru among a pool of 

possible locations because the officials believed NNSA could complete 

the pilot project in these locations before the 2014 Nuclear Security 

Summit, for several reasons. First, NNSA officials said Mexico and Peru 

did not have potential access issues presented by some higher-priority 

countries that were considered less politically stable. 24 For example,

NNSA officials told us the political instability in North Africa and the 

Middle East following the events of the Arab Spring hindered NNSA from 

gaining access to countries in those regions.25

 

24Aside from Mexico and Peru, the initial list of 12 candidate countries included 4 

countries in North Africa and the Middle East, 3 in the former Soviet Union, and 3 in 

Southeast Asia. NNSA prioritized the candidate countries, in part, by considering the 

factors specified in its 2010 security-upgrade guidance. The factors include the type of the 

radioactive material being stored at sites within the country, the existing security 

conditions of those sites, and whether the sites are in close proximity to potential highvalue targets and U.S. strategic interests. NNSA also takes into consideration the 

prevalence of terrorist-related activities in the country or surrounding region, among other 

things.

Second, NNSA officials 

said that proximity to the United States, as well as travel costs, became 

25The Arab Spring began in December 2010 in Tunisia. The social unrest in Tunisia soon 

spread across other North African and Middle East countries, including Bahrain, Egypt, 

Jordan, Morocco, Syria, and Yemen. By January 2012, the social unrest had led to the 

ousting of government leaders in Tunisia, Egypt, and Yemen.
 

Page 18 GAO-14-209 Radiological Security Zone 

an important factor in selecting Mexico and Peru because of agency 

budget constraints. Third, according to NNSA officials, both countries 

already had relatively mature regulatory frameworks in place, and NNSA 

had established good working relations with the governments of Mexico 

and Peru based on past radiological security projects. For instance, 

Mexico and Peru had already received about $11.4 million of radiological 

security assistance from NNSA from fiscal year 2008 through fiscal year 

2012.26

Following the selection of Mexico and Peru, NNSA officials worked with 

government officials in both countries to identify specific sites within each 

country to include in the pilot project. According to NNSA officials, they 

limited project sites to those housing at least 1,000 curies of radioactive 

material because of budget constraints that restricted the number of sites 

that could be upgraded. Moreover, NNSA officials told us that, in Mexico, 

budget constraints also led them to limit their project to sites in Mexico 

City because it would be too expensive to include all sites throughout the 

country that meet the threshold of 1,000 curies. NNSA ultimately selected 

nine sites in Mexico City and nine sites in Peru for inclusion in the pilot 

project. Of the nine sites in Peru, seven are located in and around Lima, 

and two are located in other cities. The sites in Mexico City and Peru 

include medical, agricultural, and research facilities.

Based on site assessments completed in Mexico City in September 2012 

and in Peru in November 2012, NNSA determined the upgrades needed 

to bring each site’s security up to the highest standards possible. The 

types of upgrades, which vary by site, included advanced access-control 

systems using biometric technology such as iris scanners; enhanced 

delay measures such as in-device delay kits; and tamper-detection 

devices. NNSA officials said that these types of upgrades could 

strengthen sites’ abilities to delay and detect malevolent activities, such 

as theft or sabotage. In addition, NNSA officials said they have completed 

the initial installations of remote monitoring systems at all sites in the pilot 

 

26NNSA officials said that, from fiscal year 2008 to fiscal year 2012, NNSA spent 

approximately $9.1 million in Mexico, of which about $3.4 million was for Mexico City, and 

$2.3 million in Peru on radiological source security upgrades. NNSA captures its 

international radiological source protection cumulative costs at the country level. As a 

result, NNSA officials estimated the costs for Mexico City based on several assumptions, 

including attributing 40 percent of the security upgrades completed in Mexico to Mexico 

City. The total costs for work completed in Mexico City, therefore, could be higher or lower 

than the estimate provided by NNSA. 
 

Page 19 GAO-14-209 Radiological Security Zone 

project and identified the locations where off-site monitoring will be 

performed. According to NNSA officials, the remote monitoring systems, 

which will improve the sites’ capability to respond to security incidents in a 

timely manner, are expected to be completed in early 2014.

NNSA has also assisted regulators in each country with the drafting of 

national security regulations. According to NNSA officials, Peru’s national 

security regulation has been enacted, and collaboration continues with 

Mexico on finalizing the current draft regulations. In addition, NNSA has 

been working with each country’s regulators to conduct response force 

and transportation security training and develop a national response plan. 

NNSA has also conducted the first of two training courses focused on 

searching for and securing orphan sources in Mexico and Peru. NNSA 

plans to complete this training and national-level assistance in 2014.

NNSA expects to spend approximately $10 million during fiscal years 

2013 and 2014 to implement the RSZ pilot project, about half of which are 

surplus funds from NNSA work on other nonproliferation projects that was 

either delayed or canceled for political or technical reasons. Of the 

estimated $10 million, about $4.5 million is allocated to the Mexico City 

projects and about $5.5 million to Peru. However, NNSA officials told us 

that the final costs will not be known until the pilot project is completed in 

2014.

NNSA officials acknowledged that the RSZ pilot is not regional in the 

sense proposed by the Partnership for Global Security, which called for 

engaging two or more countries in regional collaboration. Specifically, the 

pilot independently assists Mexico and Peru and does not involve any 

regional collaboration between the two countries. However, NNSA 

officials said that regional collaboration might take place after the pilot is 

completed. For example, NNSA officials said that a meeting or workshop 

may be convened so that representatives from the United States, Mexico, 

and Peru can discuss any successes and lessons learned from the RSZ 

pilot project. NNSA officials also said that Mexico and Peru could serve 

as role models for other countries in Latin America and the Caribbean by 

sharing lessons learned and best practices during regional workshops 

that Mexico and Peru could potentially host or attend. In addition, the RSZ 

pilot project does not address the merit or potential value of creating 

cross-country regional remote monitoring of radiological sources, as 

envisioned in the Partnership for Global Security’s original RSZ concept, 

in part because such monitoring may not be feasible. Specifically, officials 

from both NNSA and NRC said that countries would generally be 
 

Page 20 GAO-14-209 Radiological Security Zone 

unwilling to share specific information about their radiological sources 

because this information is often viewed as sensitive or classified.

Outside this current pilot project, there have been other past instances of 

regional radiological security collaboration. During the course of our 

review, we identified at least seven other regional collaborations to 

improve the security of radiological sources, with some dating back to the 

early 1990s. For example, in 2012, IAEA established an interregional 

project, partly funded by NNSA, to assist participating countries in the 

Mediterranean region to strengthen their national management and 

regulatory infrastructure on the control of radiological sources. (For 

additional information on these other regional collaborations on 

radiological security, see app. V.)

NNSA used its existing project planning process for implementing the 

RSZ pilot project, according to NNSA officials, but it did not engage with 

some key stakeholders during this planning or develop a specific 

evaluation plan for the project. In planning the RSZ pilot, NNSA undertook 

several steps, including identifying the scope of project activities to be 

conducted in both Mexico and Peru, developing a project schedule to 

track the progress of project activities, and setting milestones for 

completion. NNSA officials said that the project activities and milestones 

are similar to those for its ongoing domestic and international radiological 

security upgrade projects. As with the RSZ pilot project, these project 

activities and milestones are guided by NNSA’s 2010 guidance for 

radiological security improvements. Therefore, the planning done by 

NNSA for the RSZ pilot largely mirrored its previous planning for its 

domestic and international radiological security efforts and relied upon the 

experience gained from those prior planning efforts.

However, the agency did not engage some key stakeholders—including 

some other agencies that are actively involved in international radiological 

security efforts—early on when defining an RSZ and planning its pilot 

project. As we have previously reported and according to professional 

practices, stakeholders should be engaged early in the process of 

NNSA Did Not Engage 

with Some Key 

Stakeholders When 

Planning Its RSZ Pilot 

Project or Develop a 

Specific Evaluation Plan
 

Page 21 GAO-14-209 Radiological Security Zone 

planning and developing a pilot project.27

 

27GAO, Federal Employees: Opportunities Exist to Strengthen Performance Management 

Pilot, 

Early stakeholder engagement 

in pilot projects can ensure that multiple perspectives are considered; 

build ownership; and help generate political commitment, including 

support for any potential expansion of project activities. Activities to 

engage stakeholders early include, for example, seeking stakeholder 

input on the design of the project and obtaining stakeholder feedback on 

the implementation process. When planning the RSZ pilot project in late 

2012, NNSA officials said they engaged with stakeholders in Mexico and 

Peru at the national level—including the countries’ national regulators and 

federal police—and with staff at the sites participating in the pilot project. 

However, the officials acknowledged that they did not have early 

discussions or agreements with other key stakeholders, such as NRC and 

State, on the RSZ definition, an essential element of the project’s design;

the pilot project plan; implementation of the pilot; potential challenges; 

and potential opportunities for resource sharing related to the RSZ pilot 

project. IAEA officials also confirmed to us that NNSA had exchanged 

little information with them on the RSZ pilot project. According to NNSA 

officials, because the RSZ pilot project fell within the scope of their 

existing security assistance mission, they did not need to seek other 

agencies’ perspectives, consensus, or permission early on to proceed 

with the pilot. In addition, NNSA officials stated that because the pilot 

project needed to be implemented under a condensed schedule in order 

to be completed before the 2014 Nuclear Security Summit, there was 

limited opportunity to engage stakeholders early in the planning process. 

NNSA officials said that when they did discuss the RSZ pilot project with 

other agencies, such as NRC and State, it was after they had planned 

and started the project.

GAO-13-755 (Washington, D.C.: Sept. 12, 2013); GAO, Program Evaluation: 

Strategies to Facilitate Agencies’ Use of Evaluation in Program Management and Policy 

Making, GAO-13-570 (Washington, D.C.: June 26, 2013); World Health Organization, 

Beginning with the End in Mind: Planning Pilot Projects and Other Programmatic 

Research for Successful Scaling Up (Geneva, Switzerland: 2011); Project Management 

Institute, A Guide to the Project Management Body of Knowledge (PMBOK ® Guide), 5th 

Edition, (Newtown Square, Penn.: 2013); and FHI 360, Eight Strategies for Research to 

Practice (Durham, NC: September 2012).
 

Page 22 GAO-14-209 Radiological Security Zone 

Nonetheless, by not engaging early with key stakeholders such as NRC,

State,28

NNSA officials told us that they will evaluate the pilot project when 

completed in 2014 to determine whether the project was sufficiently 

and IAEA, NNSA may have missed opportunities to obtain and 

leverage the expertise, perspectives, and resources of these agencies. 

For example, NRC, which helps foreign countries to strengthen their 

regulatory framework, could have shared lessons learned from its 

interactions with other countries’ regulatory authorities. Moreover, IAEA 

could have shared expertise based on its long-standing involvement in 

regional collaborations regarding radiological security. In addition, 

engaging key stakeholders could have allowed NNSA to obtain different 

perspectives and ideas on how to address some of the potential 

challenges to establishing RSZs that officials from U.S. agencies and 

IAEA identified during our review or to identify potential opportunities for 

resource sharing. For instance, officials from both NNSA and NRC said 

that some countries may face challenges sustaining the physical security 

and technological upgrades provided under an RSZ project. In particular, 

countries that are economically challenged may be unable to sustain the 

costs of operating and maintaining high-technology security upgrades 

over the long-term. However, by not engaging NRC on this issue, NNSA 

did not obtain NRC officials’ ideas on how to address the potential 

sustainability challenges. For example, NRC officials told us that they 

believed that NNSA’s reliance upon an approach requiring hightechnology security upgrades, such as biometric access controls and 

advanced remote monitoring systems, may create unsustainable costs 

and that a less high-technology approach is more appropriate and 

sustainable for less prosperous countries. Moreover, NNSA officials 

acknowledged that gaining access to some of the high-priority countries 

or regions of the world could be challenging. In particular, they said that it 

may not be feasible for the United States to gain access to every highpriority country because some of these countries are unwilling to partner 

with the United States. In such cases, IAEA, which provides security 

assistance to more than 100 member states, might be in a position to 

partner with NNSA to implement an RSZ project in a country or region 

where NNSA does not have access.

 

28State has nonproliferation programs to reduce radiological, nuclear, and other threats, 

conducts bilateral and multilateral diplomacy to address proliferation threats around the 

world and provides support to NNSA and other U.S. agency nonproliferation programs 

working overseas.
 

Page 23 GAO-14-209 Radiological Security Zone 

successful to merit expanding RSZ projects to other countries. However, 

NNSA did not develop a specific plan to evaluate the pilot project’s 

success. As we have previously reported, for pilot projects, a welldeveloped evaluation plan can help ensure that agencies obtain the 

information necessary to make effective program and policy decisions.29

• well-defined, clear, and measurable objectives for the pilot project;

A well-developed evaluation plan should include, at a minimum, several 

key features, including the following:

• criteria or standards for determining pilot project performance;

• a clearly articulated evaluation methodology and strategy for 

comparing the pilot project results with those of other efforts;

• a clear plan that details the type and source of data necessary to 

evaluate the pilot project, methods for data collection, and the timing 

and frequency of data collection; and

• a detailed data-analysis plan to track the program’s performance and 

evaluate the final results of the pilot project.

NNSA officials said they did not develop a specific evaluation plan for the 

RSZ pilot project because they intend to evaluate the pilot project’s 

results using a standard evaluation tool that NNSA applies to all of its 

international security upgrades projects. However, the features of NNSA’s 

evaluation tool do not fully constitute a well-developed evaluation plan. As 

discussed below, NNSA’s intended evaluation of its RSZ pilot has some 

key features of a well-developed evaluation plan, but other key features 

are only partially developed or not developed.

• Project objectives—partially developed. NNSA’s pilot project activities 

to implement its best practices, such as completing the installation of 

remote monitoring systems or assisting with regulations, serve as a 

list of measureable project objectives. However, NNSA has not 

defined or clarified the extent to which these project objectives 

conform to the corresponding objectives in its definition of RSZs. For 

example, it is not clear whether completing the regulatory assistance 

in Mexico meets the objective of a “robust and holistic regulatory 

 

29GAO, Aviation Security: A National Strategy and Other Actions Would Strengthen TSA’s 

Efforts to Secure Commercial Airport Perimeters and Access Controls, GAO-09-399 

(Washington, D.C.: Sept.30, 2009) and GAO, Tax Administration: IRS Needs to 

Strengthen Its Approach for Evaluating the SRFMI Data-Sharing Pilot Program, GAO-09-

45 (Washington, D.C.: Nov. 7, 2008). See also P.H. Rossi, M.W. Lipsey, and H.E. 

Freeman, Evaluation: A Systematic Approach (Thousand Oaks, Calif.: 2004).
 

Page 24 GAO-14-209 Radiological Security Zone 

framework” in NNSA’s RSZ definition, or whether Mexico would need 

additional regulatory changes to meet that objective. Moreover, clear 

and measurable objectives help ensure that the appropriate 

evaluation data are collected and that performance can be measured 

against the objectives.

• Performance standards—not developed. NNSA did not develop and 

document criteria or standards for determining pilot project 

performance, which are necessary for determining the extent to which 

the pilot project is effective. Specifically, NNSA officials were unable 

to state what results—e.g., what threshold of security improvements 

—would demonstrate a successful RSZ pilot. NNSA officials 

subsequently told us they believe that the uniform and complete 

implementation of all the best practices articulated in the agency’s 

RSZ definition at the participating RSZ sites would demonstrate a 

successful pilot. However, to have a clear performance standard, 

NNSA would have to clarify how each of the planned project 

objectives would be assessed as successfully achieved and how they 

would cumulatively constitute the uniform and complete 

implementation of all the best practices of its RSZ definition.

• Evaluation methodology—developed. NNSA has developed an 

evaluation strategy for comparing the pilot project results with other 

efforts. NNSA officials told us that they intend to compare (1) 

measurement of security levels before and after the pilot for the 18 

participating RSZ sites and (2) the pilot countries’ results (such as 

developing national regulations) to the results of other countries 

receiving radiological security upgrades from NNSA outside of the 

RSZ project.

• Data collection plan—developed. NNSA has a plan to collect data for 

the pilot project. According to NNSA officials, they are applying an 

evaluation tool, composed of 75 questions, which NNSA routinely 

applies when assisting with radiological security internationally. 

Responses to the questions are used to measure, among other 

things, the effectiveness of NNSA-provided security upgrades and 

training and whether a country’s regulatory authority is effective at 

adopting regulations for the security of radiological sources. However, 

NNSA officials told us it is not easy to quantify the strength and 

completeness of language in regulations, which is more adequately 

measured by observing future enforcement successes and by using 

formal reports or anecdotal comments from the country’s regulators. 

NNSA may not, however, have timely data for reasonably assessing 

its regulatory assistance at the completion of the RSZ pilot project.

• Data analysis plan—not developed. NNSA has not developed a data 

analysis plan detailing how project performance will be tracked and 

criteria for how the final results of the project will be evaluated, and 
 

Page 25 GAO-14-209 Radiological Security Zone 

the standard evaluation tool that NNSA applies to all of its 

international security upgrades does not include such criteria. It is not 

clear, therefore, what NNSA can conclude, for instance, from 

measured changes in security levels before and after the RSZ pilot 

project without having criteria to determine successful performance. It 

is also unclear what it can conclude about the likely results of 

additional RSZ projects in other countries that may not have the 

positive characteristics of Mexico and Peru, which partially determined 

their selection for the pilot project.

Not having all the key features of a well-developed evaluation plan 

specific to the RSZ pilot project limits NNSA’s ability to evaluate the final 

results of the project and use those results to enhance the credibility and 

effectiveness of future RSZ projects, if any.

NNSA has worked to rapidly complete an RSZ pilot project in advance of 

the 2014 Nuclear Security Summit and to determine whether the highest 

standards of security for radiological sources can be implemented in 

foreign countries. While working to meet a condensed schedule for pilot 

project completion, however, NNSA did not engage some key 

stakeholders when planning the project or develop a specific evaluation 

plan for its project. In particular, NNSA did not engage with some key 

stakeholders, such as NRC, State, and IAEA, early in the process in order 

to seek their perspectives on defining RSZs and planning the pilot project 

before its implementation. By not engaging early with such key 

stakeholders, NNSA may have missed opportunities to obtain and 

leverage the expertise, perspectives, and resources of these agencies. 

For example, if IAEA had been involved early in the RSZ pilot project, it 

could have shared its expertise and perspectives, as well as ideas on 

how to address some of the potential challenges to establishing RSZs, 

based on its long-standing involvement in regional radiological security 

collaborations. Moreover, engaged stakeholders are more likely to 

support any potential expansion of RSZ projects than those who had little 

input.

Implementing and evaluating a pilot project can be challenging, especially 

given the individual characteristics of the sites and countries involved in 

NNSA’s international security efforts. Using a well-developed and 

documented evaluation plan that includes key features can help ensure 

that a pilot project is implemented and evaluated in ways that generate 

reliable information to inform future program development decisions. 

NNSA plans to evaluate the pilot project after it is completed in 2014 and 

Conclusions
 

Page 26 GAO-14-209 Radiological Security Zone 

then to decide whether it was sufficiently successful to warrant expanding 

RSZ projects to other countries, but the agency has not developed a 

specific plan with well-defined, clear, and measurable project objectives, 

among other things, to evaluate the pilot project’s success. A specific 

evaluation plan for the pilot project that includes all the key features of a 

well-developed plan can help ensure that agencies obtain the information 

necessary to make effective program and policy decisions. Having such a 

plan could also help NNSA enhance the credibility and effectiveness of 

future RSZ projects, if NNSA decides to continue beyond its current pilot 

project.

If NNSA proceeds with further work on RSZs beyond its current pilot 

project, we recommend that the Administrator of NNSA take the following 

two actions:

• Ensure that the perspectives of key stakeholders, such as NRC, 

State, and IAEA, are fully considered when planning and 

implementing any future RSZ projects. Specifically, obtain and 

incorporate stakeholder expertise and perspectives on the definition of 

RSZs, planning of future RSZ projects, potential challenges, and 

opportunities for resource sharing.

• Develop a specific evaluation plan for RSZs that includes the key 

features of a well-developed plan, such as

• well-defined, clear, and measurable objectives for the pilot project;

• criteria or standards for determining pilot project performance; and

• a detailed data-analysis plan to track the program’s performance 

and evaluate the final results of the pilot project.

We provided a draft of this report to the Administrator of NNSA, the 

Chairman of NRC, the Secretary of Homeland Security, and the Secretary 

of State. NNSA and NRC provided written comments, which are 

presented in appendixes VI and VII. NRC also provided technical 

comments, which we incorporated as appropriate. DHS and State did not 

provide comments.

In its written comments, NNSA stated that initial RSZ activities were part 

of a limited pilot project. As a result, not all of the broader planning 

principles typically implemented for long-term projects were applied. 

However, if NNSA decides to consider implementing the RSZ concept on 

a larger scale, NNSA agreed to implement our recommendations. NRC 

generally agreed with the report.

Recommendations for 

Executive Action

Agency Comments 
 

Page 27 GAO-14-209 Radiological Security Zone 

We are sending copies of this report to appropriate congressional 

committees; the Administrator of the National Nuclear Security 

Administration; the Secretaries of the Departments of Energy, Homeland 

Security, and State; the Chairman of the Nuclear Regulatory Commission; 

and other interested parties. In addition, the report is available at no 

charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, please 

contact me at (202) 512-3841 or morriss@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix VIII. 

Steve D. Morris

Acting Director, Natural Resources and Environment
 

Page 28 GAO-14-209 Radiological Security Zone 

List of Committees

The Honorable Carl Levin

Chairman

The Honorable James M. Inhofe

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Thomas R. Carper

Chairman

The Honorable Tom Coburn

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Robert Menendez

Chairman

The Honorable Bob Corker

Ranking Member

Committee on Foreign Relations

United States Senate

The Honorable Howard P. “Buck” McKeon

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

The Honorable Edward R. Royce

Chairman

The Honorable Eliot L. Engel

Ranking Member

Committee on Foreign Affairs

House of Representatives

The Honorable Michael T. McCaul

Chairman

The Honorable Bennie G. Thompson

Ranking Member

Committee on Homeland Security

House of Representatives
Appendix I: Scope and Methodology

Page 29 GAO-14-209 Radiological Security Zone 

We focused our review primarily on the Department of Energy’s National 

Nuclear Security Administration (NNSA) and the Nuclear Regulatory 

Commission (NRC) because they are the principal federal agencies with 

responsibility for securing radiological sources in the United States and 

both provide assistance to foreign countries to help secure their 

radiological sources. We also performed work at the Department of 

Homeland Security (DHS) and the Department of State because they, 

too, are involved in securing radiological sources. In addition, we obtained 

written responses to questions we submitted to the International Atomic 

Energy Agency (IAEA) regarding their experience in securing radiological 

sources in foreign countries and to obtain their views on how radiological 

sources could be secured under the concept of radiological security 

zones (RSZ). We also interviewed representatives from the Partnership 

for Global Security about the RSZ concept.

We limited the scope of our work to radioactive materials used in 

radiological sources in commercial applications, as these sources are the 

main focus of federal efforts. In particular, we focused our review on 16 

radionuclides that are commonly used in radiological sources and that 

may pose a significant risk to individuals, society, and the environment 

according to IAEA’s Code of Conduct on the Safety and Security of 

Radioactive Sources.1 A U.S. interagency task force established under 

the Energy Policy Act of 2005 confirmed in a 2010 report that these 16 

radionuclides warrant enhanced security and protection.2

 

1

IAEA, Code of Conduct on the Safety and Security of Radioactive Sources (Vienna, 

Austria: 2004). The Code of Conduct serves as a guide in developing policies, laws, and 

regulations on maintaining the safety and security of radiological sources. It is not, 

however, legally binding. The code, which was revised during 2003, includes, among 

other things, enhanced guidelines for the security of sources. Further, in September 2004, 

IAEA’s Board of Governors approved new guidance on the import and export of sources, 

which is designed to help countries ensure that high-risk sources are supplied only to 

authorized end-users. 

Our review 

does not examine 7 additional radionuclides that the task force found 

could be of concern in limited situations when the radionuclides are 

aggregated because they are infrequently shipped or possessed in 

quantities likely to cause a significant impact if used in a radiological 

2

Radiation Source Protection and Security Task Force, The 2010 Radiation Source 

Protection and Security Task Force Report (Washington, D.C.: 2010). 

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 30 GAO-14-209 Radiological Security Zone 

dispersal device.3

In addition, we did not assess the feasibility, desirability, and cost of (1) 

establishing RSZs in high-priority areas worldwide; (2) establishing 

remote regional monitoring centers staffed by personnel from countries 

participating in an RSZ; or (3) using regional monitoring centers in the 

United States to secure radiological sources. We agree with NNSA 

officials that it is premature to assess the feasibility, desirability, and costs 

of these scenarios for several reasons. First, NNSA’s RSZ pilot project is 

ongoing and has not yet been evaluated to determine whether it was 

successful or cost-effective. Second, NNSA is not establishing remote 

regional monitoring centers that would be staffed by personnel from two 

or more countries participating in an RSZ. Third, NNSA indicated that 

remote monitoring centers are being used in some capacity to assist with 

securing radiological sources in the United States, but there is no plan to 

use remote monitoring centers more widely in domestic efforts to secure 

radiological sources. Moreover, we did not develop an estimate of the 

costs associated with NNSA’s implementation of an RSZ program 

because it is premature to do so; NNSA has neither completed its RSZ 

pilot project nor evaluated the results, so it is not yet clear whether NNSA 

will pursue implementing an RSZ program.

We also did not examine other radioactive material, 

such as spent nuclear fuel or high-level radioactive waste, because these 

sources present different security concerns from radiological sources. 

Further, we did not include nuclear materials, such as highly enriched 

uranium or plutonium, in the scope of our review as these materials also 

raise different security concerns because of their potential use in an 

improvised nuclear device.

To examine current federal efforts to secure radiological sources in the 

United States, and in foreign countries, we reviewed documents and 

guidance and interviewed NRC and NNSA officials responsible for 

overseeing these efforts. Concerning efforts in the United States, we 

reviewed NRC regulations, security orders, and guidance for the security 

of domestic radiological sources and information on NRC’s National 

Source Tracking System. In addition, we reviewed information about 

NNSA’s Domestic Material Protection program, which provides voluntary 

 

3

These seven additional radionuclides are iron (Fe)-55; polonium (Po)-210; carbon (C)-14; 

strontium (Sr)-82; iodine (I)-125 and I-131; and tungsten (W)-188. The task force 

proposed no recommendation about these radionuclides and enhanced security and 

protection. 
Appendix I: Scope and Methodology

Page 31 GAO-14-209 Radiological Security Zone 

security upgrades to facilities with high-risk radiological sources. We 

gathered cost data from NNSA to determine both the amount of money 

spent by the agency on the voluntary security upgrades and the projected 

costs to complete its upgrades at all participating facilities. We discussed 

the reliability of these data with NNSA officials and a GAO methodologist 

and determined that they were sufficiently reliable to summarize both the 

program’s costs to date and its projected total costs at completion. 

Additionally, we reviewed how NNSA assists existing remote monitoring 

centers in the United States that conduct off-site alarm and video data 

monitoring of facilities using or housing radiological sources. We also 

interviewed DHS officials to learn how the department collaborates with 

NNSA to support these centers. We also examined program information 

and cost data for NNSA’s Off-site Source Recovery Project, which is 

designed to remove certain disused and unwanted or abandoned 

(“orphan”) radiological sources that pose a potential risk to national 

security or public health or safety. To further inform our work, we 

reviewed prior GAO reports on efforts to secure radiological sources 

domestically, including our September 2012 report on federal efforts to 

secure radiological sources at U.S. medical facilities.4

Concerning efforts in foreign countries, we reviewed information about 

NRC’s assistance to other countries, which primarily focuses on helping 

those countries with establishing and strengthening their regulatory 

controls for radiological sources. We obtained estimated cost data 

illustrating how much money NRC has spent providing radiological source 

security assistance to other countries since 2002. We also reviewed 

information, including prior GAO reports, about NNSA’s efforts to secure 

or remove radiological sources in other countries. We gathered and 

analyzed cost data to determine how much NNSA spent on its efforts to 

secure or remove radiological sources in foreign countries from fiscal year 

2008 through March 2013. We discussed the reliability of these data with 

NNSA officials and determined that they were sufficiently reliable for the 

purposes of our review. We also examined information and interviewed 

NRC and NNSA officials regarding U.S. efforts to coordinate with 

international partners on radiological security efforts. Additionally, we 

obtained written responses to questions we submitted to IAEA to learn 

more about U.S. efforts to work with IAEA on radiological security 

programs. Further, we reviewed NNSA’s revisions to its radiological 

 

4 GAO-12-925. 
Appendix I: Scope and Methodology

Page 32 GAO-14-209 Radiological Security Zone 

security-upgrades guidance, which documents what the agency considers 

to be its best practices for radiological source security, to determine how 

NNSA applies these practices to its international efforts. We also 

interviewed NNSA officials to determine how, if at all, NNSA applies these 

updated best practices to its international radiological security efforts.

To assess NNSA’s efforts to plan for and establish RSZs in foreign 

countries, we collected and analyzed documents and guidance on the 

RSZ pilot project and interviewed officials at NNSA responsible for 

overseeing and implementing the project. We obtained and analyzed 

budget data, including estimated costs for the pilot project, as of 

September 2013, and the estimated total costs of prior radiological 

security upgrades implemented at those sites in Mexico City and Peru 

participating in the pilot project from fiscal year 2008 to fiscal year 2012. 

To assess the reliability of these data, we discussed their reliability with 

knowledgeable NNSA officials and questioned them about the system’s 

internal controls to verify the accuracy and completeness of the data. We 

found the data to be sufficiently reliable for our reporting purposes. In 

addition, we identified and reviewed past GAO reports and practices used 

by professional evaluators for planning and implementing pilot projects, 

including communicating with relevant stakeholders. In addition, we 

identified key features of a well-developed evaluation plan for pilot 

projects identified by previous GAO reports and practices used by 

professional evaluators for planning and evaluating pilot projects. We 

found these key features to be relevant to NNSA’s RSZ pilot project and 

analyzed NNSA’s evaluation plan to determine the extent to which it had 

these key features. To obtain agency views about establishing RSZs in 

foreign countries, we interviewed agency officials at NNSA, NRC, DHS, 

and State and obtained written responses to questions we submitted to 

IAEA. We also spoke with representatives from the Partnership for Global 

Security, including its president, who had proposed the concept of RSZs 

at a congressional hearing in March 2012.

We conducted this performance audit from February 2013 to March 2014 

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.
Appendix II: Probabilities and Potential 

Consequences of Terrorist Attacks with 

Nuclear or Radiological Weapons 

Page 33 GAO-14-209 Radiological Security Zone 

The terrorist attacks against the United States on September 11, 2001, 

heightened concerns within the United States and international 

community about the risk of terrorists pursuing potentially more 

dangerous avenues of attack, such as the use of nuclear or radiological 

weapons.1

• Improvised nuclear device (IND): An IND is a crude nuclear bomb 

made with fissile materials, such as highly enriched uranium or 

plutonium, acquired by purchase, diversion, or force.

The probabilities and potential consequences of an attack by 

terrorists using a nuclear or radiological weapon vary; however, if either 

type of attack were carried out successfully, it could cause not only loss of 

life but also enormous psychological and economic damage. Terrorists 

could seek to carry out a nuclear or radiological attack using the following 

means:

2

• Radiological dispersal device (RDD): An RDD is designed to 

radioactively contaminate people or deny the use of any area by 

spreading radioactive materials into the environment, such as through 

a dirty bomb explosion or other means.

• Radiological exposure device (RED): An RED is designed to expose 

people to harmful doses of ionizing radiation as they pass by a 

partially or fully unshielded radiological source that might be 

concealed in a populated location such as under a subway seat, in a 

food court, or in a sports arena.3

In light of these threats, the 2011 U.S. National Strategy for 

Counterterrorism cited the danger of nuclear terrorism as the greatest 

 

1

One resulting concern was how major U.S. cities, which are assumed to be the preferred 

targets of such terrorist attacks, might respond to them. See GAO, Nuclear Terrorism 

Response Plans: Major Cities Could Benefit from Federal Guidance on Responding to 

Nuclear and Radiological Attacks, GAO-13-736 (Washington, D.C.: Sept. 30, 2013). 

2

Fissile material is also referred to as weapon-usable nuclear material or strategic special 

nuclear material. Nuclear material can include highly enriched uranium and plutonium. For 

the purposes of this appendix, we use both fissile material and nuclear material.

3

Ionizing radiation is any radiation capable of displacing electrons from atoms, thereby 

producing ions, which are atoms that have fewer or more electrons than protons, which 

causes them to have an electrical charge and, therefore, be chemically reactive. High 

doses of ionizing radiation may produce severe skin or tissue damage. Gamma-emitting 

sources, such as cobalt-60 and cesium-137, pose a threat mainly because even a fraction 

of a gram emits a huge number of high-energy gamma rays, which are harmful whether 

outside or inside the body.

Appendix II: Probabilities and Potential 

Consequences of Terrorist Attacks with 

Nuclear or Radiological Weapons
Appendix II: Probabilities and Potential 

Consequences of Terrorist Attacks with 

Nuclear or Radiological Weapons 

Page 34 GAO-14-209 Radiological Security Zone 

threat to global security.4 Moreover, a senior official in the Department of 

Energy’s (DOE) National Nuclear Security Administration (NNSA) said 

that, historically, nuclear security has been given priority over radiological 

security, which has a much smaller budget within NNSA.5

However, according to a 2011 Congressional Research Service report, it 

is difficult to know what priority should be given to countering nuclear 

terrorism using fissile material, as opposed to radiological terrorism, 

because nuclear and radiological incidents will likely have differing 

probabilities and consequences.6 For example, one of the challenges 

faced by terrorists is obtaining the amount of fissile material necessary for 

constructing an IND.7 In addition, it may be difficult for terrorists to obtain 

the financial and technical assets needed to build, transport, and carry out 

a successful IND attack. According to nuclear security experts, the 

probability of terrorist use of an IND is low, but the consequences of a 

successful IND attack would be devastating.8

 

4

The White House, National Strategy for Counterterrorism (Washington, D.C.: June 28, 

2011).

A successful IND attack 

could produce the same force as the bomb that destroyed Nagasaki, 

Japan, in 1945. Specifically, the explosion would produce extreme heat, 

powerful shock waves, and intense radiation that would be immediately 

lethal to individuals within miles of the explosion; it could also spread 

radioactive fallout over thousands of square miles. As a result, the 

explosion could cause hundreds of thousands of deaths and injuries and 

pose long-term cancer risks to those exposed to the radioactive fallout. A 

successful IND attack would also cause severe economic impacts—such 

as those resulting from deaths; illnesses; loss of jobs; and destruction of 

5

As we similarly reported in 2007, DOE officials told us that securing radiological sources 

in other countries is a lower priority than securing more dangerous nuclear materials, such 

as highly enriched uranium and plutonium. As a result, DOE reduced funding for 

radiological security activities. See GAO-07-282. 

6

Congressional Research Service, “Dirty Bombs”: Technical Background, Attack 

Prevention and Response, Issues for Congress (Washington D.C.: June 24, 2011).

7

According to IAEA, 25 kilograms of highly enriched uranium or 8 kilograms of plutonium 

would be needed to manufacture a weapon. 

8

For example, see M. Bunn, A. Wier, and J. P. Holdren, Controlling Nuclear Warheads 

and Materials: A Report Card and Action Plan (Washington, D.C.: Nuclear Threat Initiative 

and the Project on Managing the Atom, Harvard University, March 2003) and C. Wirz and 

E. Egger, “Use of Nuclear and Radiological Weapons by Terrorists?,” International Review 

of the Red Cross 87, no. 859 (2005).
Appendix II: Probabilities and Potential 

Consequences of Terrorist Attacks with 

Nuclear or Radiological Weapons 

Page 35 GAO-14-209 Radiological Security Zone 

workplaces, homes, and other infrastructure—that could total hundreds of 

billions of dollars and take years for recovery.9

In contrast, terrorist use of a radiological weapon, such as an RDD or 

RED, is thought to be more probable but could have less severe 

consequences than use of an IND. More specifically, according to 

security experts, the likelihood of terrorist use of a radiological weapon is 

considered greater given the prevalent commercial use of radiological 

sources containing radioactive material and because certain types of 

radioactive material, such as cesium-137 found in the form of cesium 

chloride, could be dispersed in a relatively easy way.10 However, 

compared with a nuclear weapon, a radiological weapon would arguably 

kill many fewer people and spread radioactive contamination over a much 

more limited area. For example, depending on the type of RDD, the area 

contaminated could range from part of a building or city block to several 

square miles. In the case of a dirty bomb attack, hundreds of individuals 

might be killed or injured from the explosion or face the risk of later 

developing cancer induced by exposure to radiation and radioactive 

contamination. In addition, according to nuclear security experts, the 

successful use of an RDD, particularly a dirty bomb, could potentially 

result in billions of dollars of damage. For instance, the local economy of 

the area attacked by an RDD will be severely affected due to the 

disruption of commercial activities and the extremely expensive 

decontamination measures needed for both buildings and land. An attack 

using an RED could lead to debilitating injuries or fatalities, but the 

severity of the attack will depend on, among other things, the source 

used, the proximity of each person to the source, and the duration of 

exposure. REDs are generally thought of as less of a concern than RDDs 

because they would likely harm only the people who remained near them 

for a length of time and would contaminate little to no area.11

 

9

The National Academies and the U.S. Department of Homeland Security, Nuclear Attack: 

A Fact Sheet (Washington, D.C.: National Academies of Sciences, 2005) and Homeland 

Security Council, National Planning Scenarios, Final Version 21.3 (Washington, D.C.: Mar. 

1, 2006).

10Radiological sources are used in medical, industrial, agricultural, and research 

applications and can be found in a variety of locations, such as hospitals, medical and 

industrial irradiation facilities, and universities. Cesium-137 is commonly found in the form 

of cesium chloride, a crystalline salt that is soluble in water and can be readily dispersed if 

intentionally or accidentally removed from its container. 

11Congressional Research Service, “Dirty Bombs.”
Appendix II: Probabilities and Potential 

Consequences of Terrorist Attacks with 

Nuclear or Radiological Weapons 

Page 36 GAO-14-209 Radiological Security Zone 

Nevertheless, radiation is an especially powerful terrorism weapon 

because it instills considerable fear. As a result, the mental health 

consequences of a terrorist attack using a radiological weapon would 

include effects on those victims directly impacted by the event, as well as 

the fear, terror, and demoralization transmitted to those not directly 

affected by the event.
Appendix III: Estimates of Buildings outside 

the United States Housing High-Risk 

Radiological Sources over 1,000 Curies 

Page 37 GAO-14-209 Radiological Security Zone 

As we have previously reported, the total number of radiological sources 

in use worldwide is unknown because many countries do not 

systematically account for them.1 According to an NNSA estimate, which 

is summarized in table 3 below, there are about 920 buildings in 93 

countries housing high-risk radiological sources in excess of 1,000 curies, 

but this estimate is limited to locations within other-than-high-income 

countries as defined by the World Bank.2

Table 3: Estimates of Buildings outside the United States with High-Risk 

Radiological Sources in Excess of 1,000 Curies in 93 Other-Than-High-Income 

Countries, by Region

Regiona Number of countries

Estimated number of

buildingsb

Europe and Central Asia 24 330

Latin America and the 

Caribbean

24 250

East Asia and the Pacific 10 140

Middle East and North Africa 9 90

Sub-Saharan Africa 20 60

South Asia 6 50

Total 93 920

Source: GAO analysis of NNSA data.

a

Regional categories are based on the World Bank’s regional country classification. 

b

We have rounded the estimated number of buildings to avoid a false sense of precision because the 

number of buildings is not precisely known. According to National Nuclear Security Administration 

(NNSA) officials, their estimated number of buildings is based on NNSA staff visits to sites, 

information provided to NNSA by national regulators of the host-countries, and approximations of the 

number of buildings in other countries based on observable population trends, among other things. 

 

1 GAO-07-282. 

2

The World Bank classifies countries according to per capita Gross National Income into 

four groups: low income, lower-middle-income, upper-middle-income, and high-income.

Appendix III: Estimates of Buildings outside 

the United States Housing High-Risk 

Radiological Sources over 1,000 Curies
Appendix IV: International Coordination by 

NNSA and NRC to Secure Radiological Material 

Abroad

Page 38 GAO-14-209 Radiological Security Zone 

The National Nuclear Security Administration (NNSA) and the Nuclear 

Regulatory Commission (NRC) coordinate with other international 

partners on radiological security efforts as part of their international work. 

Coordination includes working bilaterally with host countries on improving 

their security, sometimes with financial assistance from donor countries; 

regionally with several countries; or in partnership with the International 

Atomic Energy Agency (IAEA), Europol,1 and other organizations. Several 

countries have contributed funds to NNSA’s nonproliferation programs, 

including its efforts to secure radiological sources, as well as nuclear 

material. Since 2007, for example, NNSA has received funding from 

Canada, the Czech Republic, the Netherlands, New Zealand, South 

Korea, and the United Kingdom to use for, among other things, securing 

or removing of radiological sources in other countries. For instance, in 

2013, the Netherlands agreed to contribute $650,000 to support NNSA’s 

projects related to searching for and removing or protecting radiological 

sources in Kazakhstan. In addition, NNSA has been working regionally 

with the Australian Nuclear Science and Technology Organisation2

 

1 Europol is the European Union’s law enforcement agency that tracks terrorist networks 

in Europe.

since 

2004 to ensure countries in Southeast Asia have the tools to develop and 

implement secure management, use, and storage of radiological sources. 

NNSA also provides funding and technical experts to support IAEA’s 

development of guidance and technical documents, IAEA-led training in 

countries, and IAEA’s effort to assist countries with securing sites with 

radiological sources. NNSA also provides funding to the World Institute 

for Nuclear Security, a nongovernmental organization, to develop best 

practices and host workshops with international partners on nuclear and 

radiological source security. With regard to NRC, it cooperates with IAEA 

on developing nuclear safeguards, nonproliferation, and international 

regulatory standards for radioactive material, as well as providing bilateral 

safety and safeguards advice, training, and other assistance to countries 

that seek U.S. help to improve their regulatory programs.

2

The responsibilities of the Australian Nuclear Science and Technology Organisation, an 

Australian government agency, include advising the Australian government on global 

nuclear issues and providing expertise for international discussions on nuclear 

nonproliferation and safety.

Appendix IV: International Coordination by 

NNSA and NRC to Secure Radiological 

Material Abroad
Appendix V: Examples of Regional 

Collaboration to Improve Security of 

Radiological Sources 

Page 39 GAO-14-209 Radiological Security Zone 

The idea of using regional collaboration to improve the security of 

radiological sources, which is one of the main tenants of the radiological

security zone concept as originally envisioned, has been previously 

applied. During the course of our review, we identified several additional 

examples of regional collaboration projects to improve participating 

countries’ security of radiological sources, as summarized in table 4 

below.

Table 4: Regional Collaboration Project Summaries and Participating Countries

Project Summary Participating countriesa

Strengthening Cradle-toGrave Control of Radiological 

Sources in the Mediterranean 

Region

In 2012, the International Atomic Energy Agency (IAEA) 

established an interregional project, partly funded by the 

National Nuclear Security Administration (NNSA) and the 

European Union, to assist participating countries in the 

Mediterranean region to strengthen their national management 

and regulatory infrastructure for the control of radiological 

sources. The project also seeks to foster international 

cooperation between the participating countries and to 

encourage development of a harmonized regional “cradle-tograve” approach to managing radiological sources.

Albania, Bosnia and Herzegovina, 

Croatia, Cyprus, Egypt, Ghana, 

Greece, Jordan, Lebanon, 

Macedonia, Malta, Montenegro, 

Morocco, Nigeria, Slovenia, Tunisia, 

Turkey, United Republic of 

Tanzania, and the United States.

NNSA’s Global Threat 

Reduction Initiative (GTRI) 

Search and Secure Training

In January 2009, GTRI conducted training in Tunisia on how to 

search for and secure orphan radiological sources. Afterward, 

GTRI provided the Arabic and French versions of the training 

material to Tunisian authorities, allowing them to host training 

on this material for countries in North Africa and the Middle 

East. The training hosted by Tunisia was funded by the Arabic 

Atomic Energy Commission.

Countries participating in the training 

hosted by Tunisia included eight 

countries from North Africa and the 

Middle East.

Latin American Regional 

Partnership with IAEA

In 2007, GTRI joined with IAEA and the U.S. Department of 

State in a Latin American Regional Partnership to, among other 

things, identify and dispose of disused and unwanted 

radiological sources that could be used by terrorists for 

malicious purposes. Moreover, the effort sought to initiate 

cooperative efforts within the region to return unwanted, 

vulnerable radiological sources to their country of origin or to 

the United States for secure storage and disposition. The 

partnership, which included five Latin American countries, has 

since ended.

Argentina, Brazil, Colombia, United 

States, Uruguay, and Venezuela.

Southeast Asia Regional 

Radiological Security 

Partnership 

In 2004, the Australian Nuclear Science and Technology 

Organization (ANSTO), NNSA, and IAEA formed the Southeast 

Asia Regional Radiological Security Partnership. The effort 

aims to take a regional approach to improving the security of 

high-risk radiological sources in participating countries by better 

protecting and controlling such sources, among other things.

Australia, Bangladesh, Brunei, 

Canada, Cambodia, Indonesia, 

Laos, Malaysia, Myanmar, Nepal, 

New Zealand, Philippines, 

Singapore, Sri Lanka, Thailand, 

United Kingdom, United States, and 

Vietnam.

Appendix V: Examples of Regional 

Collaboration to Improve Security of 

Radiological Sources
Appendix V: Examples of Regional 

Collaboration to Improve Security of 

Radiological Sources 

Page 40 GAO-14-209 Radiological Security Zone 

Project Summary Participating countriesa

Ibero-American Forum of 

Radiological and Nuclear 

Regulatory Agencies

The Ibero-American Forum, established in 1997, provides a 

mechanism for the nuclear regulatory bodies of participating 

countries to share their experiences and knowledge in order to 

improve nuclear and radiological security in their respective 

countries. The forum has held plenary sessions, and it works to 

share knowledge and initiate activities focused on the safety 

and security of nuclear and radioactive material. For example, 

one activity focuses on the safe management of radiological 

sources. The objective of this activity is to ensure the practical 

implementation of control procedures for the import and export 

of radiological sources in Ibero-American countries by following 

the guidelines of IAEA’s Code of Conduct on the Safety and 

Security of Radioactive Sources and Guidance on the Import 

and Export of Radioactive Sources.

Argentina, Brazil, Chile, Cuba, 

Mexico, Peru, Spain, and Uruguay.

IAEA Model Project on 

Upgrading Radiation 

Protection Infrastructure

The Model Project, initiated in 1994, focused on establishing 

and/or upgrading national radiation safety infrastructure in 

various IAEA member states. The project focused on five 

project milestones that comprised the establishment of (1) a 

regulatory framework; (2) occupational exposure control; (3) 

medical exposure control; (4) public exposure control; and (5) 

emergency preparedness and response. By the end of 2004, 

IAEA chose to pursue the project through five thematic safety 

areas, which reflected the five original milestones, and 

emphasized a more regional approach. This new approach was 

based on growing recognition that each region—Africa, Asia 

and the Pacific, Europe, and Latin America—faced unique 

challenges and that it was imperative to find ways to increase 

sharing of knowledge and experience at the regional level to 

keep pace with technological evolution and standards 

development.

The Model Project was originally 

envisioned as an interregional 

project with five participating 

countries, but by 2004, the project 

finished with 91 participating 

countries in Africa, Asia and the 

Pacific, Europe, and Latin America.

African Regional Cooperative 

Agreement for Research, 

Development, and Training 

Related to Nuclear Science 

and Technology (AFRA)

AFRA is an intergovernmental agreement established in 1990 

by IAEA and IAEA member states in Africa to further strengthen 

and enlarge the contribution of nuclear science and technology 

to socioeconomic development on the African continent. NNSA 

has also provided funding to IAEA and technical expertise to 

support AFRA activities. One activity focuses on radiation and 

waste safety and nuclear security. Under this activity, AFRA 

promotes member states’ self-assessment of their regulatory 

infrastructure and radiation protection services, among other 

things. AFRA also provides training through regional workshops 

focusing, for example, on using IAEA methodology to develop a 

national strategy in radiation safety and on the protection of 

radiological sources.

Algeria, Angola, Benin, Botswana, 

Burkina Faso, Burundi, Cameroon, 

Central African Republic, Chad, 

Côte d’Ivoire, Democratic Republic 

of the Congo, Egypt, Ethiopia, 

Gabon, Ghana, Kenya, Lesotho, 

Libya, Madagascar, Malawi, Mali, 

Mauritania, Mauritius, Morocco, 

Mozambique, Namibia, Nigeria, 

Seychelles, Sierra Leone, South 

Africa, Sudan, Tunisia, Uganda, 

United Republic of Tanzania, and 

Zimbabwe.

Sources: GAO analysis of AFRA, ANSTO, IAEA, Ibero-American Forum, and NNSA documents.

a

In some cases, countries that played a role in providing funding, training, and/or technical expertise 

are considered participating countries. 
Appendix VI: Comments from the National 

Nuclear Security Administration 

Page 41 GAO-14-209 Radiological Security Zone 

Appendix VI: Comments from the National 

Nuclear Security Administration
Appendix VII: Comments from the Nuclear 

Regulatory Commission

Page 42 GAO-14-209 Radiological Security Zone 

Appendix VII: Comments from the Nuclear 

Regulatory Commission 
Appendix VIII: GAO Contact and Staff 

Acknowledgments

Page 43 GAO-14-209 Radiological Security Zone 

Steve D. Morris, (202) 512-3841 or morriss@gao.gov

In addition to the individual named above, Glen Levis (Assistant Director), 

Terry Hanford, and Kevin Remondini made key contributions to this 

report. Other assistance was provided by Jeffrey Barron, Alisa Beyninson, 

Kevin Bray, Pamela Davidson, and Cynthia Norris.

Appendix VIII: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(361472)
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