Combating Nuclear Smuggling: Megaports Initiative Faces Funding and Sustainability Challenges
Published: 2012-10-31T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: NNSA established the Megaports Initiative in 2003 to deter, detect, and interdict nuclear or other radiological materials smuggled through foreign seaports. The Initiative funds the installation of radiation detection equipment at select seaports overseas and trains foreign personnel to use this equipment to scan shipping containers entering and leaving these seaports—regardless of destination. NNSA provides partner countries with maintenance and technical support for about 3 years, after which it transfers the equipment and all related responsibilities to partner countries. GAO was asked to examine (1) the status of the Megaports Initiative and NNSA’s plans for completing and sustaining it and (2) the benefits of the Initiative and factors that reduce its effectiveness. GAO analyzed key documents; interviewed agency officials; and visited eight Megaports in five countries, selected on the basis of port size and unique characteristics, among other things.
section_title: What GAO Found
paragraphs: As of August 2012, the National Nuclear Security Administration (NNSA) had completed 42 of 100 planned Megaports projects in 31 countries and, as of December 2011, NNSA had spent about $850 million on the Megaports Initiative (Initiative). NNSA’s Initiative has equipped these seaports with radiation detection equipment, established training programs for foreign personnel, and created a sustainability program to help countries operate and maintain the equipment. However, the administration’s fiscal year 2013 budget proposal would reduce the Initiative’s budget by about 85 percent, and NNSA plans to shift the Initiative’s focus from establishing new Megaports to sustaining existing ones. As a result, NNSA has suspended ongoing negotiations and cancelled planned deployments of equipment in five countries.
Officials from the five countries GAO visited reported benefits of the Megaports Initiative, including increased capacity to interdict nuclear and radiological materials. However, GAO identified several factors that reduce the Initiative’s effectiveness. For example, NNSA has not finalized a long-term plan for ensuring the sustainability of Megaports operations after NNSA transfers radiation detection equipment to partner countries. Without a long-term plan for ensuring countries’ ability to continue Megaports operations, NNSA cannot be assured that its $850 million investment will be sustained. Moreover, the Initiative’s performance measures do not provide sufficient information for decision making because they do not evaluate the impact and effectiveness of the Initiative. GAO has previously reported that agencies successfully assess performance when they use measures that demonstrate results, cover multiple program priorities, and provide useful information for decision making. GAO also found that the Megaports Initiative and the Department of Homeland Security’s (DHS) Container Security Initiative (CSI)—a related program that examines high-risk shipping containers for weapons of mass destruction before they are shipped to the United States—are not sufficiently coordinating. The two Initiatives are co-located at 29 foreign seaports. In two countries, DHS officials told GAO that they were using personal radiation detectors—a type of equipment intended for personal safety but not appropriate for scanning containers—to inspect containers if their radiation detection equipment is broken. However, in both countries, the Megaports Initiative had more suitable equipment that DHS officials could have used.
section_title: What GAO Recommends
paragraphs: GAO recommends that NNSA take actions, including (1) finalizing its long-term plan for ensuring the sustainability of Megaports operations after NNSA’s final transfer of equipment to partner countries and (2) developing and maintaining useful and reliable measures to assess the performance of the Initiative. GAO also recommends that NNSA and DHS jointly assess the extent to which the two Initiatives are effectively coordinating. NNSA and DHS agreed with GAO’s recommendations.

section_title: Letter
paragraphs: Over the past decade, the United States has become increasingly  concerned about the threat posed by unsecured weapon-usable nuclear  material, which could be stolen and fall into the hands of terrorists or  countries seeking weapons of mass destruction. According to the  International Atomic Energy Agency, from 1993 to 2011, there were 2,164  confirmed incidents of illicit trafficking in nuclear and radiological  materials. Even small amounts of nuclear materials are of concern—as  little as 25 kilograms of highly enriched uranium or 8 kilograms of  plutonium could be placed inside containers aboard cargo ships and  ultimately be used to build a nuclear weapon known as an improvised  nuclear device. An improvised nuclear device could create an explosion  producing extreme heat, powerful shock waves, and intense radiation that  would be immediately lethal to individuals within miles of the explosion, as  well as radioactive fallout over thousands of square miles. Radiological  materials, such as cobalt-60, cesium-137, and strontium-90, also pose a  significant security threat. These materials are used worldwide for many  legitimate medical and industrial purposes. However, they could also be  used by a terrorist to produce a simple and crude, but potentially  dangerous weapon, known as a radiological dispersion device, or dirty  bomb. Experts believe that a dirty bomb detonation could result in a  limited number of deaths but that it could have severe economic,  psychological, and social consequences.
Seaports are critical gateways for international commerce, and maritime  shipping containers play a vital role in the movement of cargo between  global trading partners. In 2009, for example, world maritime container  traffic (loaded and empty) was estimated at over 432 million twenty-foot  equivalent units. The Department of Energy’s (DOE) National Nuclear  Security Administration (NNSA) established the Megaports Initiative in  2003 so that foreign personnel at select seaports could use radiation  detection equipment to scan shipping containers entering and leaving  these seaports—regardless of the containers’ destination—for nuclear or  radiological material. The Megaports Initiative (Initiative) is implemented  by NNSA’s Office of the Second Line of Defense (SLD), which aims to  strengthen foreign countries’ capability to deter, detect, and interdict illicit  smuggling of nuclear and radioactive materials across international  borders. Through the Initiative, NNSA partners with foreign governments  to fund the installation of radiation detection equipment at foreign  seaports and train foreign personnel to operate this equipment. In some  cases, partner countries also contribute funding to the design,  construction, or installation of radiation detection equipment. The installed  radiation detection equipment is then operated by foreign personnel. In  addition, the Initiative provides maintenance and technical support for the  equipment for about 3 years, after which NNSA transfers all  responsibilities—including operations and maintenance of the equipment  and all related financial responsibilities—to partner countries. NNSA  selects seaports for participation in the Initiative using a prioritization  model that ranks seaports on the basis of scannable shipping volume and  threat factors, such as the origin and destination of container movement  through a port and proximity to special nuclear material.
We reported in March 2005 that the Megaports Initiative had limited  success in initiating work at seaports identified as high priority.
Among  other things, we reported that it was difficult to gain the cooperation of  foreign governments, in part because some countries were concerned  that scanning large volumes of containers would create delays, thereby  inhibiting the flow of commerce at their ports. Moreover, the Initiative did  not have a comprehensive long-term plan to guide the Initiative’s efforts  and faced several operational and technical challenges in installing  radiation detection equipment at foreign seaports. We recommended that  DOE (1) develop a comprehensive long-term plan for the Initiative that  identifies criteria for deciding how to strategically set priorities for  establishing Megaports and (2) reevaluate cost estimates and adjust  long-term projections as necessary. DOE has implemented both  recommendations.
In this context, you asked us to update information on the Megaports  Initiative since our 2005 report. Accordingly, we examined (1) the status  of the Megaports Initiative and NNSA’s plans for completing and  sustaining it and (2) the benefits of the Initiative and factors, if any, that  reduce its effectiveness.
For both objectives, we obtained and analyzed relevant NNSA  documentation, including program plans and implementation strategies,  memorandums of understanding, and cost-sharing arrangements  between NNSA and partner countries, as well as sustainability plans. We  interviewed NNSA officials about the status of the program, its future  plans, and challenges associated with its implementation. Moreover, we  interviewed contractors who help implement the Initiative at two DOE  national laboratories—Pacific Northwest National Laboratory (PNNL) and  Oak Ridge National Laboratory. In addition, we visited a nonprobability  sample of eight seaports in five countries—Belgium, the Dominican  Republic, Jamaica, Panama, and Spain—to observe scanning operations  and interview foreign government and port officials. We selected these  seaports on the basis of port size, NNSA’s priority ranking, NNSA’s  expenditures at the port, history of cost-sharing with NNSA, length of time  in the Megaports Initiative, joint presence with the Department of  Homeland Security’s (DHS) Container Security Initiative (CSI),unique characteristics of specific locations. Because we used a  nonprobability sample to select the eight Megaports we visited, the  observations we made are not generalizeable to other Megaports but  serve as examples of challenges and concerns that may affect Megaports  operations and sustainability. At the seaports visited, we interviewed  foreign government officials and terminal operators using a standard set  of questions about their participation in and perspective on the Megaports  Initiative. We also interviewed DHS officials co-located at these seaports  and U.S. embassy officials in these countries.
To assess the status of the Megaports Initiative and NNSA’s plans for  completing and sustaining it, we analyzed the Megaports Initiative’s  budget information and expenditures for fiscal years 2003 through 2012,  as well as projected costs through fiscal year 2018. We interviewed  knowledgeable NNSA officials to assess the reliability of the data,  including the issues of data entry, access, quality control procedures, and  the accuracy and completeness of the data. We determined that the data  were sufficiently reliable for our purposes. We also requested and  analyzed data on Megaports partner countries’ cost-sharing contributions.  These cost-sharing data are of undetermined reliability because we did  not have a way to verify NNSA’s and partner countries’ estimates. We  also reviewed NNSA’s budget request and related budget documents for  fiscal year 2013 and spoke with Office of Management and Budget (OMB)  staff about proposed changes to the Megaports Initiative’s fiscal year  2013 budget. To assess the benefits of the Initiative and any factors that  may reduce its effectiveness, we also interviewed NNSA headquarters,  PNNL, and foreign officials about the benefits and challenges they have  encountered in implementing the Initiative. Additional details on our  objective, scope, and methodology can be found in appendix I.
We conducted this performance audit from August 2011 to October 2012  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.
subsections: section_title: Background
paragraphs: SLD manages three programs: the Megaports Initiative, the Core  Program, and the Sustainability Program. The Core Program funds the  installation of radiation detection equipment at land borders, airports, and  strategic seaports—primarily in Russia, other former Soviet Union  countries, and Eastern Europe. The Sustainability Program supports both  the Megaports Initiative and the Core Program by overseeing the  transition of radiation detection equipment from NNSA to partner  countries. Figure 1 shows the organization of SLD.
The Megaports Initiative is part of a broader U.S. government effort to  prevent terrorists from acquiring, smuggling, and using special nuclear  and other radioactive materials to develop a weapon of mass destruction  or a dirty bomb. The Megaports Initiative coordinates with and  complements DHS’s Container Security Initiative (CSI), a related program  that targets and examines high-risk containers for weapons of mass  destruction before they are shipped to the United States. CSI began  operating in January 2002 and is active at 58 seaports around the world,  including 29 seaports where the Megaports Initiative had completed  Megaports as of August 2012. Under CSI, DHS places U.S. Customs and  Border Protection officials at foreign seaports to review the cargo  manifests of U.S.-bound shipping containers and identify high-risk  containers for scanning with nonintrusive imaging systems—which use   X-rays or gamma rays to scan a container and create images of the  container’s contents without opening it. In some cases, CSI officers use  handheld radiation detection equipment to collect additional information  about the selected shipping containers. The Megaports Initiative and the  CSI programs have some similarities, but they also have key differences,  which are outlined in table 1.
The Megaports Initiative 2011 Program Plan states that the Initiative has  committed to providing radiation detection capability at all CSI ports,  which will give CSI officials additional information in assessing high-risk  containers.
SLD, numerous DOE national laboratories,play a role in implementing the Megaports Initiative, as described in    table 2.
The Megaports team generally implements the Initiative at foreign  seaports in three phases: (1) engagement, (2) implementation, and (3)  sustainability.
Engagement: Before installing equipment at a seaport, NNSA and the  appropriate agency in the partner country enter into an arrangement  that outlines the expectations, roles, and responsibilities of all  stakeholders involved. When possible, NNSA attempts to establish a  cost-sharing arrangement with partner countries.
Implementation: This phase involves several different activities. The  Megaports team surveys the port to help plan for the installation of  radiation detection equipment. Moreover, the Megaports team begins,  among other things, training foreign officials on operating radiation  detection equipment, resolving alarms, and maintaining this  equipment. During this phase, the Megaports team also (1) hires one  of three approved private contractors that will lead the construction  and communications services at the new Megaport, (2) drafts a  sustainability and a joint transition plan, and (3) installs and tests the  radiation detection equipment and prepares the equipment for  operations.
Sustainability: The Megaports team works with the partner country to  develop the capabilities needed to sustain equipment operations and  maintenance over the long-term. For example, the Megaports  Initiative funds the maintenance of equipment during this phase and  conducts additional training of foreign officials. NNSA officials also  regularly visit the port to ensure that the equipment is properly  calibrated and being used as intended. NNSA typically transfers  ownership of and responsibility for radiation detection equipment  operations and maintenance to partner countries after about 3 years.
The Megaports Initiative provides partner countries with several types of  radiation detection equipment that is used to scan shipping containers in  primary or secondary scanning inspections. NNSA’s goal is to scan as  much container traffic as possible with primary radiation detection  equipment—including Radiation Portal Monitors (RPM), which are large  stationary systems through which cargo containers and trucks pass as  they are entering or exiting the port; Mobile Radiation Detection and  Identification Systems (MRDIS), which are mobile radiation detection  systems that can be driven to different locations at a seaport; and  Radiation Detection Straddle Carriers (RDSC), which are mobile radiation  detection systems that can scan rows of containers stacked up to three  high. These types of equipment detect both gamma and neutron  radiation, which is important for detecting the presence of highly enriched  uranium and plutonium. When a container is scanned with primary  equipment, an alarm will sound if the equipment detects the presence of  radiation. However, during primary scanning, the equipment cannot  identify what type of material triggered the alarm. If they determine it is  necessary, foreign customs officials will then conduct a secondary  inspection with a handheld Radioisotope Identification Device (RIID) or a  Spectroscopic Portal Monitor (SPM) to specifically identify the source and  location of the radiation. If the foreign customs officials cannot determine  the content of the container after the secondary inspection, they may  manually inspect the container or request assistance from other agencies  within their government. NNSA also provides partner countries with  Personal Radiation Detectors (PRD), or pagers, which are small detectors  that can be worn on an individual’s belt to continuously monitor radiation  levels in the immediate area. PRDs help to ensure personal safety. For  more detailed information about and photographs of the equipment NNSA  provides partner countries, see appendix II.
section_title: NNSA Plans to Complete 45 Megaports, but Future Implementation Is Uncertain Because of Administration- Proposed Budget Cuts
paragraphs: NNSA completed 42 Megaports as of August 2012 and plans to complete  work at 3 additional ports by the end of fiscal year 2012, for a total of 45  Megaports at a cost of about $850 million. However, if proposed budget  cuts are enacted, the Initiative’s plans to establish new Megaports would  cease. As a result, NNSA has halted the implementation of new  Megaports and is working with an interagency work group to determine  an appropriate future scope for the program.
subsections: section_title: NNSA Plans to Complete 45 Megaports and Has Spent about $850 Million
paragraphs: NNSA had completed 42 Megaports as of August 2012 and plans to  complete 3 additional ports by September 2012, according to NNSA  officials, bringing the total to 45 operational Megaports by the end of fiscal  year 2012. To ensure that countries are able to independently operate  and maintain the radiation detection equipment after NNSA transfers the  equipment, NNSA has (1) implemented a training program for foreign  personnel operating the radiation detection equipment, (2) developed a  sustainability program, and (3) developed new technology to address  challenges faced at some ports. As of December 2011, NNSA had spent  about $850 million on Megaports Initiative activities.
The 42 completed Megaports and the 3 additional Megaports that are  planned for completion by September 2012 are located in 33 countries  throughout Europe, Asia, Latin America, Africa, and the Middle East.  Figure 2 shows the countries where NNSA has either established a  Megaport or plans to have completed work for one by the end of fiscal  year 2012. (See app. III for a complete list of the Megaports and  information about each port.)
To help decision makers identify and prioritize foreign seaports for  participation in the Megaports Initiative, NNSA uses a model that ranks  foreign ports according to their relative attractiveness to potential nuclear  smugglers. Currently, the model scores 1,100 foreign seaports on the  basis of two categories: (1) scannable shipping volume, which accounts  for 75 percent of the score, and (2) potential threat, which accounts for 25  percent of the score. Potential threat is determined on the basis of several  factors, including the capabilities of terrorist groups within a country,  amount of special nuclear material within a country, and the freedom of  criminal groups to operate within a country. This information is then  combined to provide each port with an overall score. Ports receiving  higher scores are considered more attractive to a nuclear material  smuggler and, therefore, of potentially higher interest for inclusion in the  Initiative. The model is also updated regularly to incorporate new  information. After the model produces a ranked list of ports that takes into  consideration these factors and assumptions, NNSA officials work with  the Department of State to ensure that U.S. diplomatic concerns are  considered. For example, NNSA may not pursue ports in countries that  do not have diplomatic relations with the United States.
According to our analysis of NNSA’s priority list of ports, 18 of the 45  Megaports that are completed or under way (or 40 percent) are ranked  lower in priority than the top 100 highest priority seaports NNSA  identified. NNSA officials told us that the Initiative uses the priority list  generated by the model as a targeting guide but noted that various  factors affect which ports they can equip with radiation detection  equipment. For example, some foreign governments with seaports  identified as being of high-priority have been unwilling to participate in the  Initiative because of internal political sensitivities. NNSA officials also told  us that the DHS CSI ports are always added to the list regardless of  ranking because of an arrangement between NNSA and DHS for the  Megaports Initiative to provide radiation detection equipment at these  ports. In addition, NNSA officials said that they choose some lower  ranked ports if there are cost-sharing opportunities, if partner countries  specifically request partnerships, or if NNSA is given an opportunity to  demonstrate a new scanning approach—such as using the MRDIS to  scan transshipped containers in Salalah, Oman.
We last reported on the Megaports Initiative in March 2005. At that time,  NNSA had completed work on two Megaports and faced diplomatic and  other impediments that limited its ability to complete more Megaports in  its first 2 years. In addition, we reported that NNSA officials faced  difficulties reaching agreement with foreign countries due to political  considerations outside of NNSA’s control. In October 2011, NNSA  officials told us they continue to face these same limitations. For example,  NNSA officials said that they had been negotiating with one country’s  government on installing a Megaport when one of that country’s citizens  was killed by U.S. armed forces in Iraq. According to NNSA officials, this  incident prompted that country’s government to cease negotiations. After  9 months, negotiations resumed, but the progress previously made was  lost, and NNSA and the officials in that country had to start negotiations  over.
To ensure that countries are able to independently operate and maintain  the radiation detection equipment after NNSA transfers it, PNNL  implements a training program for foreign personnel operating the  radiation detection equipment. PNNL officials told us that, as of  December 2011, they had trained 1,038 foreign officials at DOE’s  Hazardous Materials Management and Emergency Response training  facility in Washington State, as well as 1,521 foreign officials in their  respective countries. These training courses include instruction on,  among other things, operating radiation detection equipment at ports,  responding to alarms generated by radiation detection equipment, using  handheld instruments for secondary inspections, and maintaining the  radiation detection equipment.
Through the SLD Sustainability Program, NNSA works with foreign  partners to develop a joint transition and a sustainability plan that lays out  actions needed at the port before NNSA transfers the equipment. These  plans may include, among other things, steps for scheduled maintenance  and refresher training. NNSA also provides ongoing support for the  Megaports equipment through the SLD help desk managed by PNNL.  The help desk provides partner countries with access to technical  expertise—even after the equipment is transferred—so that they can  resolve problems they may experience with the radiation detection  equipment.
The Megaports Initiative has developed new technologies to address  transshipment challenges, as well as to improve overall scanning  effectiveness and minimize the impact on seaport operations. According  to the Initiative’s program plan, transshipped cargo presents a significant  challenge to a port’s ability to scan containers because of the (1) shorter  transfer time for those containers to be at the seaport before they are  moved to another location or port, (2) space constraints, (3) lack of  shipping data, and (4) difficulty of identifying fixed locations to place  RPMs within terminals that do not impede seaport operations. To address  these challenges at seaports with high transshipment volumes, NNSA  developed the MRDIS and the RDSC, which are two types of mobile  radiation detection equipment that can be driven to different locations  within a seaport (see figs. 3 and 4). Appendix II provides additional details  on these and other types of equipment used by the Megaports Initiative.
As of December 2011, NNSA had spent about $850 million on Megaports  Initiative activities, according to our analysis of NNSA expenditures. Of  this total, NNSA spent 64 percent, or about $547 million, in countries  where it has installed radiation detection equipment and 36 percent, or  about $303 million, on expenditures related to program integration  activities, secondary equipment, and outreach to countries. (See app. V  for information on the Initiative’s total budget and expenditures for fiscal  years 2003 through 2012.) Program integration activities include  expenditures for project management, technical support, equipment  testing, and equipment storage. NNSA officials told us the costs of  installing equipment at individual seaports vary and are influenced by  factors such as a seaport’s size, its physical layout, existing infrastructure,  and the type of radiation detection equipment deployed. Table 3 shows  the Initiative’s expenditures by country from fiscal year 2003 through  December 2011. We found that the amount of money NNSA spent per  country ranged from about $1 million to $59 million, with an average of  $16.6 million.
According to NNSA data, eight foreign countries have contributed an  estimated $44 million to support Megaports at 15 foreign ports (see table  4 for a list of these countries and their estimated contributions). According  to NNSA, partner country cost-sharing estimates are derived from  educated estimates and partner country-provided data. Cost-sharing  arrangements typically include the partner country funding the design,  construction, and installation of the radiation detection equipment and  NNSA providing equipment, training, and technical and maintenance  support. According to the Megaports Initiative 2011 Program Plan, NNSA  employs a formal cost-sharing approach with a partner country whenever  possible. Moreover, according to the Initiative’s program plan, when a  partner country contributes a percentage of the cost and work to install  the equipment, the country develops a greater sense of ownership for the  program and contributes to the Initiative’s success.
NNSA’s cost-sharing estimates do not, however, include informal  contributions by countries or other foreign partners, such as seaport  terminal operators. Both NNSA officials and foreign partners stated that  foreign partners have made contributions that were not specified in a  cost-sharing arrangement. In reviewing NNSA documents, we identified  at least nine instances where there were no formal cost-sharing  arrangements in place, but NNSA had acknowledged informal  contributions from foreign partners that could be identified as monetary  savings for the Initiative. For example, the Dominican Republic does not  have a formal cost-sharing arrangement in place, but the terminal  operator contributed fiber optic cables for the Megaports Initiative at the  port of Caucedo, which, according to NNSA officials, contributed to  monetary savings. In another case, a terminal operator in the Philippines  provided power and the infrastructure for fiber optic cables to support the  Initiative, which ultimately saved the Initiative both financial resources and  construction time.
In December 2011, we reported that NNSA does not systematically track  and verify foreign cost sharing for the Megaports Initiative and that a  NNSA official told us that the Megaports Initiative cost-sharing values are  estimates and are not validated or audited. In that report, we  recommended that NNSA develop ways to better track and maintain  information on foreign cost sharing for nuclear nonproliferation projects  overseas. NNSA neither agreed nor disagreed with this recommendation.
As the table shows, Mexico, Belgium, and Spain shared the most costs  with the Megaports Initiative, contributing about $19 million, $17 million,  and $5 million, respectively. Conversely, Panama and China contributed  the least amount of funding: $72,600 and $256,000, respectively. In  January 2007, we reported that nuclear nonproliferation is a shared  responsibility and that some countries should be willing to contribute more  resources to secure nuclear and radiological materials. We  recommended that DOE develop strategies to encourage cost sharing  with recipient countries. DOE stated that the recommendation was very  helpful and would further strengthen its program.
section_title: Due to Proposed Budget Cuts, NNSA Plans to Shift the Initiative’s Focus to Sustainment Rather than Expansion
paragraphs: NNSA had planned to establish a total of 100 Megaports by 2018, which  NNSA officials told us would cost an additional $1.26 billion. These  plans have been halted, however, because the administration’s fiscal year  2013 budget proposal would reduce the SLD program budget from  $262.1 million to $92.6 million, of which $19.6 million would be allocated  to the Megaports Initiative. This is an 85 percent reduction for the  Megaports Initiative—which had a $132.7 million budget in fiscal year  2012. As a result, DOE’s fiscal year 2013 Congressional Budget  Request states that DOE plans to shift the program’s focus from  establishing new Megaports to sustaining existing ones. See table 5 for a  summary of SLD’s budget for fiscal year 2012 and budget request for  fiscal year 2013.
NNSA has taken a number of actions as a result of proposed budget cuts,  including suspending ongoing negotiations for installing Megaports in 17  countries and cancelling planned deployments of new equipment in 5  other countries. NNSA officials told us that arrangements with 2 of these  countries were imminent, and the Initiative’s former program manager  stated that cancelling program activities would affect the agency’s  credibility. According to NNSA officials, it would also significantly diminish  countries’ trust in working with NNSA in the future. Moreover, NNSA  typically funds maintenance of Megaports in transition on a yearly basis,  but because of the expected budget cuts, NNSA has decided to fund  maintenance contracts up to 3 years in advance of transferring the  radiation detection equipment for some countries in order to honor its  commitments.
The Office of Management and Budget (OMB) staff, who examined the  SLD budget as part of their role in preparing the administration’s budget,  cited several reasons for reducing the Megaports budget, including the  following:
Diminishing impact: The Megaports Initiative generally follows a  prioritized scope of work for installing radiation detection equipment  and has already equipped many of the world’s most important  seaports. As the Megaports Initiative completes the installation of new  Megaports, the benefit of any significant expansion, except at certain  priority sites, diminishes.
Questionable program effectiveness: The technologies used in  radiation detection equipment may have some limitations because  they may not be able to detect nuclear or other radiological material  that has been shielded or masked, and terrorists could also bypass  the Megaports Initiative’s equipment.
Lack of performance measures: It is difficult to measure the  Megaports Initiative’s progress in achieving its mission using its  existing performance measures. Specifically, the program has limited  performance measures—the total number of foreign seaports where  NNSA has installed radiation detection equipment and the cumulative  number of Megaports with partner country cost-sharing. Moreover,  NNSA does not report on what has been interdicted as a result of the  Megaports Initiative, although it does internally collect this information  from willing partner countries. OMB staff said that reporting the  number of interdictions and what has been interdicted would be useful  to help assess the Initiative’s effectiveness in the future.
Limited monitoring of equipment: It is difficult for NNSA to monitor how  partner countries, as sovereign nations, are using the radiation  detection equipment once it transfers the equipment to a partner  country.
Potential duplication: The federal government has 21 nonproliferation  programs, including the Megaports Initiative. Because of the current  fiscally constrained environment, OMB staff examined national  security programs and identified priorities for funding according to  which programs are most effective in combating nuclear smuggling.  According to OMB staff, within the fiscal constraints of the Budget  Control Act of 2011, this strategic prioritization enabled the  administration to protect its highest priority nonproliferation activities,  most importantly those that directly secure or remove material.
Notwithstanding the reasons they identified for reducing the Initiative’s  budget, OMB staff told us that there are benefits to the Megaports  Initiative, such as providing a public health benefit. For example, they said  that using the Megaports radiation detection equipment, countries have  interdicted scrap metal contaminated with radiological material, thereby  preventing it from circulating within the country or beyond its borders.  Additionally, OMB staff told us that the Initiative helps deter terrorists from  smuggling nuclear materials through the global shipping network.  Furthermore, the Initiative has helped to build relationships with partner  countries and has demonstrated the U.S. commitment to combating  nuclear terrorism. OMB staff said that they weighed the program’s  benefits and potential repercussions from foreign partners resulting from  NNSA’s cancellation of arrangements. However, they determined that the  Initiative could not demonstrate that further expansion would have a  significant impact on preventing nuclear or radiological materials from  entering the United States.
section_title: Interagency Group Has Been Established to Review Megaports Initiative’s Future Role
paragraphs: The administration’s fiscal year 2013 budget proposes that NNSA, in  coordination with members of an interagency work group, conduct a  strategic review of SLD—including the Megaports Initiative—to determine  an appropriate future scope for the Initiative and how it may affect other  national security programs. NNSA officials told us that the interagency  work group is led by the White House National Security Staff and includes  officials from DHS’s Domestic Nuclear Detection Office, the Department  of State, the Department of Defense, and the National Counterterrorism  Center.
According to NNSA officials and OMB staff, NNSA is continuing its  strategic review of the Megaports Initiative to ensure that the Initiative,  under a constrained budget environment, is most effectively and  efficiently detecting, deterring, and interdicting nuclear and radiological  material. Through its strategic review, NNSA is assessing how to best  leverage and sustain existing capabilities, and whether installing  additional radiation detection systems at strategically selected ports is  warranted to further strengthen detection and deterrence at key hubs and  spokes in the global maritime shipping network. The strategic review is  assessing the threat of terrorists shipping nuclear materials through the  maritime shipping network. NNSA’s strategic review also includes an  assessment of the Megaports Initiative’s port prioritization methodology,  in which NNSA updated its model with 2011 data. To generate a list of  ports that would be realistic for consideration if expansion is warranted,  NNSA is also considering additional factors, including a country’s  likelihood of entering into an arrangement, the type of equipment  appropriate for each port, cost-sharing arrangements, and whether a  country participates in other nuclear nonproliferation programs. According  to NNSA’s strategic review, through technical exchanges, the Megaports  Initiative could provide assistance with technical aspects of the project  involving the transfer of knowledge only. The results of the strategic  review will be reflected in the fiscal year 2014 budget.
section_title: Countries Cite Benefits of the Megaports Initiative, but Several Factors Limit Its Effectiveness
paragraphs: Foreign officials from countries that we visited reported benefits of the  Megaports Initiative, such as gaining a greater capacity to interdict  radiological materials, but we also identified several factors that reduce  the Initiative’s effectiveness. These factors include partner countries that  are not fully using radiation detection equipment or fully participating in  the Initiative. The program also faces several management weaknesses,  including having insufficient performance measures and limited testing of  spectroscopic portal monitors and deployment of radiation detection  equipment.
subsections: section_title: Benefits of the Megaports Initiative Cited by Partner Countries
paragraphs: Foreign officials from the five countries we visited highlighted several  benefits of the Megaports Initiative. For example, foreign government  officials from four countries—Belgium, the Dominican Republic, Jamaica,  and Spain—told us that the Initiative has helped their respective countries  interdict radiological materials found in containers using the Megaports  radiation detection equipment. For example, Spanish customs officials  told us that they interdicted medical isotopes that had not been properly  disposed of, and Jamaican officials told us that they interdicted  contaminated scrap metal. Moreover, officials from these four countries  also told us that the radiation scanning equipment was used to ensure  that goods imported from Japan were not contaminated in the wake of the  2011 Fukushima Daiichi nuclear incident. For example, Belgian customs  officials told us that they interdicted 15 containers contaminated with  radioactive material originating from Japan. In addition, according to  foreign government officials, as part of the Initiative, NNSA officials  helped both Jamaica and Spain develop a response plan in the event that  their officials interdict nuclear or radiological material. Jamaican officials  told us that seven different government agencies play a role in  responding to a radioactive emergency and that the centralized response  plan will help them better coordinate a response if they interdict  radiological materials.
NNSA officials also identified other program benefits. For example,  according to NNSA officials, 13 countries with Megaports have reported  about 155 interdictions of radiological materials. In addition, 19 countries  have taken steps to supplement, or have expressed interest in  supplementing, the Megaports Initiative by acquiring their own radiation  detection equipment. According to the Initiative’s program plan, based on  the success of Megaports Initiative in the Netherlands, the Dutch  government replaced four U.S.-provided RPM units with more than 40  RPMs at that country’s expense to be able to scan all imports and exports  at the Port of Rotterdam—which is the largest seaport in Europe. Spanish  customs officials also told us that the Initiative provided a foundation for  beginning radiation detection scanning in Spain. Spanish customs  purchased handheld radiation detection equipment to use in airports and  scanning equipment for six other seaports after the Fukushima accident.
section_title: Several Factors Have Impeded the Initiative’s Effectiveness
paragraphs: Notwithstanding these benefits, we identified several factors that reduce  the Initiative’s effectiveness. Specifically, some partner countries are not  fully using radiation detection equipment, and some foreign partners are  not fully participating in the Initiative.
In four of the five countries we visited—and seven of the eight seaports— countries were using the Megaports-funded secondary radiation detection  equipment on a limited basis, and foreign officials told us that they are  conducting secondary scanning for a small percentage of the containers  that triggered an initial alarm. For example, customs officials from one  country that we visited told us that they limit the containers that they refer  for secondary scanning because they want to minimize interruptions to  port operations. According to these officials, the day before we visited in  January 2012, they referred one container for secondary scanning out of  17 containers that triggered alarms during primary scanning. Customs  officials from this country select containers for secondary scanning by  comparing the initial alarm information with a container’s shipping  information. For example, the shipping information should indicate what  cargo the container holds, and on the basis of the information, officials  assess whether that cargo naturally emits radiation. If the shipping  information matches the alarm information, they allow the container to  proceed. Similarly, customs officials in another country we visited stated  that if a container triggers a primary alarm, they compare the container’s  shipping information with the alarm information to determine whether the  container should be scanned by secondary equipment. According to the  Megaports Initiative 2011 Program Plan, one port in this country scans  about 73 percent of containers with primary equipment; however, foreign  officials from this port said that they conduct secondary scanning for only  a small number of containers—about 2 to 3 containers per day out of  about 200 primary alarms. (See fig. 5 for a photograph of a SPM radiation  detection scanning unit, which is used for secondary scanning.)
The Megaports Initiative encourages partner countries to conduct as  many secondary inspections as possible, according to NNSA officials.  However, NNSA officials also told us that they recognize that there are  practical challenges to conducting secondary inspections on 100 percent  of containers that trigger a primary alarm. For example, the flow of  commerce may be affected when a truck is diverted from its normal route  to a secondary inspection area or because of the time that it takes to  conduct a secondary inspection. As a result, NNSA trains partner  countries to set priorities for selecting containers for secondary inspection  by assessing a container’s shipping information, including, among other  things, the commodity being shipped, the shipper, and the country of  origin and destination.
In contrast, at U.S. ports of entry, 100 percent of containers that produce  an initial alarm must be verified with more precise secondary scanning  equipment, according to DHS guidance. DHS officials, who manage the  domestic radiation detection program, told us that secondary scanning is  important to reduce the risk that containers may be masking or shielding  nuclear material. In addition, the Megaports Initiative 2011 Program Plan  states that, although RPMs are the most sensitive radiation detection  technology deployed by the Megaports Initiative, they do not have the  ability to unambiguously characterize the location, distribution, and  identity of a radiation source in a container that triggers an alarm. The  program plan also states that this type of information is determined by a  secondary inspection. Furthermore, a senior official for a global terminal  operator told us that it is “very easy” for exporters to lie about the contents  of a shipping container. According to this official, smugglers could also  place materials into a container after it leaves an exporter’s facilities, and  the container’s shipping information would still appear to be legitimate.
Some partner countries are not fully participating in the Megaports  Initiative, which raises questions about their long-term commitment to the  Initiative and may compromise the security gains expected. For example,  Panamanian customs officials—who expressed support for the Initiative— told us that the four Megaports in Panama currently scan less than 1  percent of their container traffic, but terminal operators at two Megaports  in Panama stated that they are not willing to conduct additional scanning  because they do not believe there are economic benefits to participating  in the Initiative. Panamanian customs officials told us that about 85  percent of containers passing through the Panama Canal are  transshipped containers. According to the Initiative’s program plan, it is  difficult to scan transshipped containers because of space and  operational constraints. NNSA officials told us that they plan to add a  MRDIS unit—a type of mobile radiation detection equipment—to one of  the Megaports in Panama to help increase the volume of containers  scanned. However, a senior official for the terminal operator at this port  told us that they have not yet agreed to the placement of the MRDIS and  are concerned about it delaying port operations. Panamanian customs  officials told us that a nuclear or radiological incident affecting the  Panama Canal would take years to clean up and would cause worldwide  economic chaos.
Other Megaports partners are also not fully participating in the Megaports  Initiative. For example, the Chinese government has agreed to install  radiation detection scanning equipment at one port. However, 12 Chinese  seaports are ranked in the top 100 highest priority ports, according to  NNSA’s port prioritization model. NNSA officials told us that they have  discussed installing radiation detection equipment at additional seaports  in China with Chinese officials, but that future cooperation is uncertain  because of the proposed decreases to the Initiative’s budget. In addition,  China is one of the few countries that does not share scanning data with  the Initiative because, according to NNSA officials, the Chinese  government believes that trade information contained in the data is  proprietary. Oak Ridge National Laboratory analyzes scanning data for  Megaports countries on a monthly basis to assess, among other things,  whether the monitors are installed and working properly, as well as to  collect information on alarm rates and the number of containers scanned.  Furthermore, DOE laboratory officials told us that the Chinese  government has agreed to scan only exports—not imports, which most  other Megaports scan—and required NNSA to purchase Chinese  radiation detection equipment instead of U.S. equipment. The Initiative  tested the Chinese radiation detection equipment in 2006 with a budget of  $180,000 to certify it as reliable for use. In addition, Pakistan—a country  of significant nonproliferation concern—has not agreed to install  equipment at more than one seaport. NNSA officials told us that they  began negotiating in 2006 to expand the program in Pakistan.
section_title: Management Weaknesses Impede the Initiative’s Effectiveness
paragraphs: We also identified several management weaknesses that reduce the  Initiative’s effectiveness. Specifically, we have concerns that NNSA        (1) has not finalized a long-term plan for ensuring the Initiative’s  sustainability, (2) does not have sufficient performance measures, and   (3) has performed limited testing and deployment of SPM radiation  detection equipment. In addition, we found limited coordination between  the Megaports Initiative and the Container Security Initiative (CSI), which  is implemented by DHS.
NNSA has taken steps to help partner countries prepare to take  responsibility for Megaports operations after NNSA transfers the  equipment to them. However, NNSA does not have a long-term plan for  ensuring the ongoing sustainability of these Megaports operations. For  example, NNSA is not systematically following up with partner countries  to ensure that they are effectively operating and maintaining Megaports- funded equipment after NNSA’s final transfer of equipment, maintenance,  and related financial responsibilities. According to the Initiative’s program  plan, it is “critical” that the installed systems are appropriately overseen to  help counter possible corruption and to ensure that the systems are being  used as intended. During a July 2012 meeting with senior officials for the  Megaports Initiative, we discussed whether the Initiative had a long-term  sustainability plan. After that meeting, NNSA officials provided us with a  draft sustainability plan, which addresses how SLD will engage partner  countries after the final transfer of radiation detection equipment. For  example, the plan states that the Sustainability Program will use a list of  metrics to assess how well a country is maintaining its capacity to sustain  Megaports operations and that SLD will provide narrowly tailored support  to partner countries, if needed, to ensure continued sustainability of  operations. For example, SLD might provide technical advice, analyze  RPM scanning data, or provide help desk support. According to the  Initiative’s acting program manager, NNSA plans to finalize this plan in  October 2012.
We also found that several impediments could compromise the  sustainability of Megaports operations. According to NNSA officials,  several countries—including Bangladesh, Djibouti, and Kenya—will likely  require ongoing assistance at the end of their 3-year transition periods.  Other countries, including Sri Lanka and Colombia, have requested  extensions to their 3-year sustainability period, and NNSA officials expect  that additional training will be needed to fully transfer Megaports  operations to Pakistan. Officials in two countries we visited—the  Dominican Republic and Panama—reported concerns about funding the  operations and maintenance of Megaports equipment after NNSA  transfers responsibility. Furthermore, officials in the five countries we  visited reported staffing challenges, including recruiting, retaining, and  funding staff who operate Megaports equipment and respond to alarms.  For example, CSI officials in one Caribbean country told us that they  observed staffing shortages among the partner country’s customs officials  who work on the Megaports Initiative and that alarms for Megaports  RPMs periodically go off for several hours to a week without a response  from local customs officials. According to NNSA officials, the partner  country has taken steps to resolve these staffing issues by hiring a new  lead Megaports officer and new Megaports employees who are to be  trained in September 2012. However, a senior official who works for a  global terminal operator told us that he is not confident that countries will  continue operating the Megaports equipment if the Initiative is eliminated  because these countries would not have any diplomatic or economic  incentives to continue scanning containers. In fact, this official said that  this global terminal operator has already begun looking into the costs of  removing radiation scanning equipment in case some governments  decide not to continue Megaports operations.
Performance measures are important to ensure that NNSA can evaluate  the Initiative’s effectiveness and progress. We have previously reported  that agencies successfully assess performance when they use measures  that demonstrate results, cover multiple program priorities, and provide  useful information for decision making. According to DOE’s Fiscal Year  2011 Annual Performance Report, NNSA has two performance measures  for the Initiative—the total number of foreign seaports where it has  installed radiation detection equipment and the cumulative number of  Megaports with partner country cost-sharing.
These two performance measures, however, have limitations and do not  provide sufficient information for decision making. For example, using the  number of foreign seaports where the Initiative has installed radiation  detection equipment as a key performance measure does not evaluate  the impact and effectiveness of the Initiative. This measure does not, for  example, demonstrate whether the equipment is effective, account for the  volume of containers being scanned, or indicate whether countries are  continuing to use the equipment. As of August 2012, NNSA reported  having 42 operational Megaports, but NNSA decommissioned 1 of those  Megaports—Southampton in the United Kingdom—in June 2010. In  addition, Panamanian customs officials told us that the four Megaports in  Panama currently scan less than 1 percent of their container traffic. As  such, this performance measure does not provide NNSA decision-makers  with adequate information to assess the extent to which the Initiative is  fulfilling its mission to deter, detect, and interdict the illicit trafficking of  special nuclear and other radioactive materials in the global maritime  system.
Furthermore, using the cumulative number of Megaports with country  cost-sharing as a measure of the Initiative’s performance is not reliable  because, as we reported in December 2011, NNSA does not  systematically track and verify foreign cost-sharing for the Megaports  Initiative, and these estimates are neither validated nor audited. NNSA  officials told us that they do not have the authority to audit countries’ cost- sharing estimates. In our December 2011 report, we noted that NNSA  officials told us that this performance measure was difficult to quantify and  that it would be eliminated for fiscal year 2012 as a result of a DOE  “performance measures streamlining initiative.”
According to a 2011 House Committee on Appropriations report, the  committee is concerned that the Initiative’s performance measures are  not adequate to assess the effectiveness of SLD’s activities, and the  report states, “the true effectiveness of  detectors in preventing  proliferation is largely dependent on how well individual countries employ  these capabilities in their security operations.” that it is difficult to measure the Megaports Initiative’s outcomes because  of its limited performance measures and said that the Initiative does not  routinely report what materials it has successfully interdicted.
OMB staff also told us  In February 2012, we met with senior NNSA program officials to discuss  the status of the Megaports Initiative. These officials told us that the  Initiative’s current performance measures are insufficient and that they  need to develop more effective and useful metrics. For example, NNSA  officials told us that one of the primary benefits of the Initiative is deterring  terrorists from smuggling nuclear or radiological materials through  seaports, but it is difficult to measure the deterrent value of the Initiative.
H.R. Rep. No. 112-118 at 137 (accompanying H.R. 2354, Energy and Water  Development Appropriations Bill, 2012). not proven.DHS’s efforts to develop and procure ASPs was that initial testing was not  rigorous enough. Once the testing became more rigorous, ASPs did not  perform well enough to warrant development, and the DHS program was  subsequently canceled. NNSA officials told us that, after receiving the  ASPs from DHS, they changed the name of the equipment to SPMs to  avoid the negative connotations associated with the ASP program. NNSA  officials also said that they viewed the receipt of the SPMs as an  opportunity to test and evaluate this type of technology exclusively for  secondary scanning purposes at an actual seaport. However, we visited  one foreign seaport where NNSA had deployed an SPM, but the unit was  getting limited use as a secondary inspection tool. Local customs officials  in this country told us that they only use the SPM about two to three times  per day, even though the primary radiation detection equipment triggers  about 200 alarms each day.
One of the principal findings of our past work reviewing  The Megaports Initiative planned to spend $8.9 million to test and  evaluate radiation detection equipment from fiscal years 2006 through  2011, including about $5.2 million for SPM technology. NNSA officials told  us that the Initiative does not have a dedicated budget for testing and  evaluating radiation detection equipment because the program does not  have a technology development mission. However, NNSA also has a  program office—the Office of Nonproliferation Research and  Development—that, among other things, conducts research,  development, and testing of new technologies to improve U.S. capabilities  to detect nuclear weapon-usable materials. This office’s Proliferation  Detection program has an annual budget of more than $200 million,  which conducts research and provides technical expertise on next- generation detection capabilities for nuclear materials.
Moreover, the Megaports Initiative has not deployed a significant amount  of the equipment for testing, as evidenced by its storing unused radiation  detection equipment at a total cost of about $1.3 million each year in both  2010 and 2011. NNSA officials told us that, as of February 2012, NNSA  had deployed only 16 of the 44 SPMs to foreign seaports and DOE  national laboratories. The agency has not deployed any SPMs to Core  Program land border sites. NNSA placed the remaining 28 units in  storage along with other types of equipment. In August 2012, the  Megaports program manager told us that they were looking into options  for removing this equipment from storage by, for example, giving some of  the equipment to partner countries or by removing usable components  and declaring the rest as surplus inventory.
In addition, in 2008, NNSA purchased a new type of radiation detection  equipment—four RDSCs at a total cost of about $18 million—but two of  the units are not currently being used. According to NNSA officials, the  Initiative purchased these two units with the intention of deploying one to  Taiwan and giving one to DHS to address a scanning challenge at a U.S.  seaport. However, the Taiwanese port was reconfigured, and the new  layout was no longer suitable for using the RDSC. Moreover, DHS  decided that it did not want to use the RDSC after conducting an  alternatives analysis because DHS did not consider the RDSC to be a  viable system suitable for use by U.S. Customs and Border Protection. NNSA considered deploying one of the RDSCs to a port in Italy, but that  port lost a major shipping client and decided to reconfigure the port in a  way that would eliminate use of straddle carriers. As a result, NNSA is  spending an additional $33,000 in 2012 on storage fees for these two idle  RDSCs while NNSA officials explore other options for deploying them.
According to DHS officials, the department was undergoing an alternatives analysis for  the on-dock rail program, in which the RDSC was one of the alternatives. DHS decided  not to take the RDSC until the alternatives analysis was concluded and only if the RDSC  was determined to be a viable alternative. Through its analysis, DHS determined there  were cost and sustainability issues associated with the RDSC—including high acquisition,  operations, and maintenance costs, as well as costs associated with paying RDSC  drivers. DHS officials also said that U.S. Customs and Border Protection has since  developed cost-sharing initiatives with its stakeholders, which may allow the RDSC to  become a viable scanning solution.
subsections: section_title: Limited Coordination between Megaports and CSI
paragraphs: The Megaports Initiative 2011 Program Plan states that the Initiative has  committed to providing radiation detection capability at all CSI ports,  which will give CSI additional information in assessing the security risks of  maritime containers. (See fig. 6 for a photograph of CSI’s nonintrusive  imaging system and the Megaports Initiative’s radiation detection  scanning equipment at a Megaport.) From 2005 through 2008, DOE and  DHS signed eight joint declarations of principles with partner countries for  eight Megaports to establish coordination on enhancing the security of  cargo containers. NNSA officials told us that they provide CSI officials,  who are co-located with Megaports, with access to alarm information and  that the CSI officials are invited to participate in Megaports training.
However, we found two cases at ports in the Caribbean where the  Megaports Initiative and CSI programs were co-located but were not  coordinating their efforts to scan containers. DOE and DHS signed joint  declarations of principles with the local customs offices in both of these  countries. In both countries, CSI officials told us that they use their  personal radiation detectors—a type of equipment intended for personal  safety but not appropriate for scanning containers—to inspect containers  if their primary detection equipment is broken. However, in both countries,  the Megaports Initiative had functioning RPMs and handheld radiation  detection equipment that, according to the Megaports Initiative’s former  program manager, CSI officials could have used if they had asked  Megaports equipment operators. In addition, CSI officials in one of these  countries—who work in a room adjacent to Megaports equipment  operators—told us that they periodically observed Megaports alarms  going off for several hours to a week without answer. CSI officials told us  that they eventually became “annoyed” by the alarms and called the  partner country’s customs office to report the issue. Moreover, CSI  officials said that they do not know if the containers that triggered the  alarms were eventually inspected. CSI officials’ reluctance to resolve the  alarms or contact NNSA officials about this issue raises questions about  whether NNSA and DHS are leveraging resources of these two U.S.  programs with similar missions.
In an October 2005 report on practices that can help enhance and sustain  collaboration among federal agencies, we stated that a focus on results,  as envisioned by the Government Performance and Results Act of 1993,  implies that federal programs contributing to the same or similar results  should collaborate to ensure that goals are consistent and, as  appropriate, program efforts are mutually reinforcing. As we reported,  agencies can enhance and sustain collaborative efforts by identifying and  addressing needs by leveraging resources to support the common  outcome. It is unclear to what extent NNSA and DHS are coordinating  or collaborating at other seaports where they are co-located to ensure  that their program efforts are mutually reinforcing as envisioned by the  Government Performance and Results Act.
Furthermore, NNSA and DHS have entered into joint arrangements with  partner countries, but the two agencies do not have written policies or  procedures on how to coordinate their activities at ports to best leverage  their resources. Without written procedures, the two initiatives may not be  taking advantage of an opportunity to more effectively implement their  mutual goal of combating nuclear smuggling overseas. In June 2010, we  reported that agencies can strengthen their commitment to work  collaboratively by articulating their roles and responsibilities in formal  documents to facilitate decision making. Such formal documents can  include memorandums of understanding, interagency guidance, or  interagency planning documents, signed by senior officials in the  respective agencies.
section_title: Conclusions
paragraphs: Under its Megaports Initiative, NNSA has installed radiation detection  equipment at more than 40 foreign seaports since 2003 and has trained  foreign personnel in partner countries to scan shipping containers  entering and leaving these seaports—regardless of the containers’  destination—for nuclear or radiological material. However, recent  proposed budget cuts have created an uncertain future for the Megaports  Initiative. NNSA is working with an interagency work group to evaluate the  Megaports Initiative and adjust future plans accordingly. This evaluation  and adjustment period provides NNSA with an opportunity to address  management weaknesses that we identified during the course of our  review and seek to maximize the effectiveness and efficiency of the  Initiative whatever its construct in the future.
We found that several Megaports partner countries have not entered into  a formal cost-sharing arrangement with NNSA but nonetheless have  made contributions to the Initiative. However, NNSA is not systematically  tracking information on the amount of funding or other contributions that  partner countries informally contribute to the Initiative. We continue to  believe that our previous recommendation—that NNSA develop better  ways to track and maintain information on foreign cost-sharing—could, if  implemented, provide a tangible measure of foreign governments’  commitment to NNSA’s nuclear nonproliferation programs.
NNSA has not finalized a long-term plan for ensuring the sustainability of  Megaports operations after NNSA transfers all equipment maintenance,  operations, and related financial responsibilities to partner countries. As  we found, several countries have raised concerns about funding the  operations and maintenance of Megaports equipment after the United  States transfers responsibility. Without a plan in place to ensure the  sustainability of Megaports operations in the future, NNSA cannot be  confident that this equipment will continue to be used for the purposes  intended or if it will be used at all.
NNSA has also not developed performance measures that sufficiently  demonstrate the extent to which the Megaports Initiative is effectively  fulfilling its mission to deter, detect, and interdict the illicit trafficking of  special nuclear and other radioactive materials in the global maritime  system. Its current measures of performance—the total number of foreign  seaports where NNSA has installed radiation detection equipment and  the cumulative number of Megaports with partner country cost-sharing— are not useful or reliable for decision making. Specifically, these  measures do not demonstrate whether the equipment is effective,  account for the volume of containers being scanned, or indicate whether  countries are continuing to use the equipment. As a result, NNSA  decision makers and policymakers do not have the necessary information  to assess the nonproliferation and deterrent benefits of the Initiative.  Without meaningful performance measures, it is difficult to measure the  Megaports Initiative’s outcomes, which may have contributed to the  administration’s proposed budget cuts to it.
We found that the Megaports Initiative has planned more than $5 million  in spending to test and evaluate SPM radiation detection equipment,  which we previously reported is an unproven technology. The Megaports  Initiative also does not have a technology development mission; whereas,  another NNSA program office does have a mission specifically dedicated  to testing and evaluating radiation detection equipment. As a result, we  question whether this is an appropriate investment of the Initiative’s  limited funding, particularly given its uncertain future.
Furthermore, NNSA has not deployed a significant amount of the  Megaports Initiative’s equipment, as evidenced by the more than $1  million SLD spent in both 2010 and 2011 to store radiation detection  scanning equipment—including SPMs and other equipment—that it was  unable to install in foreign countries—either through the Megaports  Initiative or at Core Program land border sites. As of the time of our  review, NNSA officials had not taken steps to remove the remaining 28  SPMs and 2 RDSCs from storage, although they are considering options  to do so. Without deploying this equipment for the intended purposes,  providing it to other NNSA or DOE offices for research and further testing,  or declaring the equipment as surplus inventory, NNSA will continue  spending the Initiative’s limited resources to store idle equipment, even as  the Initiative expects significant budget cuts in fiscal year 2013.
Finally, the Megaports Initiative 2011 Program Plan states that the  Initiative has committed to providing radiation detection capability at all  CSI ports, but we found that NNSA and DHS have engaged in limited  coordination at two seaports that we visited where the Megaports  Initiative and CSI are co-located. CSI officials in two countries told us that  they were using personal radiation detectors—which is a type of  equipment intended for personal safety but not appropriate for scanning  containers—to scan containers, while more appropriate radiation  detection equipment that the Megaports Initiative has provided its  partners is located at the same port. It is unclear to what extent NNSA  and DHS are coordinating or collaborating at other seaports where they  are co-located to ensure that their program efforts are mutually reinforcing  as envisioned by the Government Performance and Results Act or how  localized the problem is. However, while NNSA and DHS have signed  joint arrangements with some partner countries, the two agencies do not  have written policies or procedures on how to coordinate at ports to best  leverage their resources. Without such written procedures, the Megaports  Initiative and CSI may not be taking advantage of an opportunity to more  effectively combat nuclear smuggling overseas.
section_title: Recommendations for Executive Action
paragraphs: We are making the following five recommendations.
To ensure that the Megaports Initiative is maximizing resources and  protecting its investments of $850 million, we recommend that the  Administrator of the National Nuclear Security Administration take the  following four actions:
Finalize its draft sustainability plan for ensuring ongoing sustainability  of Megaports operations after NNSA transfers all equipment,  maintenance, operations, and related financial responsibilities to  partner countries.
Develop and maintain useful and reliable measures to assess the  performance of the Megaports Initiative. These measures might  include the number and type of interdictions, percentage of global  maritime container traffic scanned, or length of time that countries  sustain operations of the Megaports equipment.
Terminate additional expenditures from the Megaports Initiative’s  budget for testing and evaluating SPMs. Additional testing and  evaluation activities, if warranted, should be funded through other  NNSA programs with a research and development mission.
Remove unused Megaports radiation detection equipment— particularly SPMs and RDSCs—from storage on an expedited basis.  This could be done, for example, by (1) providing the equipment to  DOE national laboratories for research and further testing or (2)  declaring the equipment as surplus inventory.
To strengthen efforts to combat nuclear smuggling overseas, we also  recommend that the Administrator of the National Nuclear Security  Administration and the Secretary of Homeland Security take the following  action:
On a periodic basis, jointly assess the extent to which the Megaports  Initiative and CSI are effectively leveraging resources and  coordinating at foreign seaports where the two Initiatives are co- located. If the agencies determine based on these joint assessments  that there is a need for increased coordination, they should develop  written policies or procedures that formally document how to  coordinate at ports to best leverage their resources.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided the Departments of Energy and Homeland Security and the  Office of Management and Budget a draft of this report for their review  and comment. In written comments, DOE and DHS agreed with our  recommendations; their comments on the draft report are presented in  appendixes VI and VII, respectively. DOE and DHS also provided  technical comments, which we incorporated as appropriate. On October  3, 2012, we received oral comments from OMB staff, including an OMB  branch chief, a program examiner, and staff from the Office of General  Counsel.  These staff agreed with the facts presented in this report and  stated that they concurred with our findings and recommendations. In  addition, OMB provided technical comments, which we incorporated as  appropriate.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to the  Secretaries of Energy and Homeland Security; the Director of the Office  of Management and Budget; the appropriate congressional committees;  and other interested parties. In addition, the report will be 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 trimbled@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 major contributions to  this report are listed in appendix VIII.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: The objectives of our review were to assess (1) the status of the  Megaports Initiative (Initiative) and the National Nuclear Security  Administration’s (NNSA) plans for completing and sustaining it and (2)  benefits of the Initiative and factors, if any, that reduce its effectiveness.
For both objectives, we obtained and analyzed relevant NNSA  documentation, including the Megaports Initiative Program Plans for 2011  and 2010, the 2011 Second Line of Defense Implementation Strategy,  and the 2006 Second Line of Defense Strategic Plan. We also reviewed  memorandums of understanding and cost-sharing arrangements between  the Department of Energy (DOE) and partner countries, as well as  sustainability and joint transition plans. Furthermore, we reviewed and  met with NNSA officials responsible for the Initiative’s prioritization model,  which NNSA developed to help prioritize and select ports for participation  in the Initiative. We also analyzed information about the ports NNSA has  completed thus far, including information about their cost-sharing,  transition dates, and rankings. In addition, we interviewed NNSA officials  responsible for implementing and managing the Megaports Initiative  about the status of the program, its future plans, sustainability activities,  and challenges associated with implementation. We also interviewed  NNSA country managers about operational Megaports. Moreover, we  interviewed contractors who help implement the Initiative at two DOE  national laboratories: (1) Pacific Northwest National Laboratory about  equipment, training, and procurement activities and (2) Oak Ridge  National Laboratory about its analysis of equipment performance data  and alarms. We interviewed officials at the Department of Homeland  Security (DHS) and the Department of State about coordination with the  Megaports Initiative. Furthermore, we interviewed officials from two global  terminal operators—DP World and Hutchinson Port Holdings—regarding  their perspectives on the Megaports Initiative.
In addition, we visited a nonprobability sample of eight seaports in five  countries—Belgium, the Dominican Republic, Jamaica, Panama, and  Spain—to observe scanning operations and interview foreign government  and port officials. We selected these seaports on the basis of port size,  NNSA’s priority ranking, NNSA’s expenditures at the port, history of cost- sharing with NNSA, length of time in the Megaports Initiative, joint  presence with DHS’s Container Security Initiative (CSI), and unique  characteristics of specific locations. At the seaports we visited, we  interviewed foreign government officials using a standard set of questions  about their participation in and perspective on the Megaports Initiative.  These officials included those from customs offices and offices who  handle the response to nuclear emergencies, as well as terminal  operators and port authorities. Because we used a nonprobability sample  to select the eight Megaports we visited, the observations we made are  not generalizeable to other Megaports but serve as examples of  challenges and concerns that may affect Megaports operations and  sustainability. We also interviewed DHS officials co-located at these  seaports and U.S. embassy officials in these countries.
To assess the status of the Megaports Initiative and NNSA’s plans for  completing and sustaining it, we analyzed the Megaports Initiative’s  budget information and expenditure data for fiscal years 2003 through  2012, as well as projected costs through fiscal year 2018. We interviewed  knowledgeable NNSA officials to assess the reliability of the data and  discussed such issues as data entry, access, quality control procedures,  and the accuracy and completeness of the data. We determined that the  data provided to us were of sufficient reliability for the purposes of this  review. Moreover, we reviewed NNSA’s budget request and related  budget documents for fiscal year 2013 and spoke with Office of  Management and Budget staff about proposed changes to the Megaports  Initiative’s fiscal year 2013 budget. We also requested and analyzed data  on Megaports partner countries’ cost-sharing contributions. Because  these contributions are a combination of NNSA and foreign country  estimates, we did not have a way to verify these data. As such, these  data are of undetermined reliability. We are nonetheless reporting these  cost-sharing data to provide some context on cost-sharing contributions  made by partner countries.
To assess the benefits of the Megaports Initiative and any factors that  reduce its effectiveness, we obtained and reviewed lessons learned that  NNSA officials document in a central database, performance measures in  DOE’s fiscal year 2011 Annual Performance Report, plans for radiation  detection equipment outlined in the Megaports Initiative’s 2012 Alternative  Detection Technology Strategy, and information on the Initiative’s costs  for storing radiation detection equipment. We also reviewed DHS’s U.S.  Customs and Border Protection’s directive on its domestic radiation  detection program. In addition to the interviews listed above, we also  interviewed NNSA headquarters, Pacific Northwest National Laboratory,  and foreign officials about the benefits and challenges they have  encountered in implementing the Initiative. We also conducted an  interview with officials from DOE’s Office of Intelligence and  Counterintelligence regarding the Megaports Initiative’s process for  selecting ports.
We conducted this performance audit from August 2011 to October 2012  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.
section_title: Appendix II: Radiation Detection Equipment Used by the Megaports Initiative
paragraphs: Appendix II: Radiation Detection Equipment  Used by the Megaports Initiative SPMs are formerly known as advanced spectroscopic portal (ASP) monitors.  NNSA has also deployed four SPM units to DOE’s national laboratories for testing and evaluation  purposes.
section_title: Appendix III: Information about NNSA Megaports
subsections: section_title: Megaport Manila
paragraphs: Percentage of total  container volume  scanned (estimated)
The priority ranking listed is NNSA’s prioritization ranking by countries’ adjusted score. NNSA  prioritizes countries with a raw score and then adjusts the rankings by removing countries from the list  that (1) have low container volume, (2) NNSA cannot work with for diplomatic or policy reasons, or (3)  NNSA or other organizations conduct similar work at that port. For security purposes, we have  clustered the rankings into tiers: 1-50, 50-100, 100-150, and 150-200.  NNSA estimates the size of the Megaports installation—small, medium, or large—based on the  number of RPM units needed to scan as many shipping containers as possible. This may be different  from the physical size of the port.  The operational date is the date that the partner country begins operating the Megaports radiation  detection scanning equipment.  The transition date is the date that NNSA currently plans to transfer all equipment, maintenance,  operations, and related financial responsibilities to partner countries.  These dates are NNSA’s current estimates.  From 2006 through 2010, NNSA tested a prototype of the RDSC in Freeport. NNSA began operating  a second generation RDSC in June 2010. NNSA had discussions with the Bahamian government in  June 2012 and intends to transfer responsibility for the RDSC in September 2014.  According to NNSA documents, these countries were added to the Megaports prioritization list  because they were (1) already operational prior to NNSA developing its prioritization model or (2) a  specific port of interest for the Megaports Initiative.  According to NNSA officials, the sustainability period was extended from 2009 through 2012 because  of political turmoil in Honduras.  The Megaports Initiative began a pilot project at the Port of Haifa in January 2008, which it  dismantled in January 2012. NNSA expects to complete full installation at Haifa in December 2012  and plans to transition the equipment in December 2015.  The Megaports Initiative has installed radiation detection equipment at two terminals in Kingston. The  first terminal began operations in June 2009, and NNSA transitioned the equipment to Jamaican  Customs in June 2012. The second terminal began operations in March 2012, and NNSA expects to  transition the equipment in March 2015.  NNSA installed radiation detection equipment at the Port of Salalah, Oman, in September 2008 but  has since updated some of the MRDIS radiation detection equipment with second generation units,  which NNSA expects to be operational by October 2012. NNSA intends to transfer the equipment to  the government of Oman in October 2015.  The Port of Qasim is the only port remaining under the Secure Freight Initiative and, according to  NNSA, there is no planned transition date at this time. The Secure Freight Initiative is a DHS and  DOE program at selected ports that aims to scan 100 percent of U.S.-bound container cargo for  nuclear and radiological materials overseas using non-intrusive imaging systems and radiation  detection equipment.  NNSA and DHS started the Secure Freight Initiative at the Port of Busan in March 2009, and DHS  decommissioned its equipment in March 2010. The Megaports Initiative signed a new Memorandum  of Understanding in September 2010 and restarted the radiation detection system in March 2011.  NNSA transitioned responsibility for RPM units at Algeciras to Spanish Customs in December 2010  and plans to transition responsibility for a SPM unit in July 2014.  NNSA began operations in Southampton in October 2007 through the Secure Freight Initiative, but  DHS concluded Secure Freight Initiative operations in June 2010. NNSA terminated operations of the  radiation detection equipment in June 2010 and gave an SPM unit to the United Kingdom Border  Agency, which relocated the equipment to another port.
section_title: Appendix IV: List of Operational Megaports and Megaports Being Implemented
paragraphs: Lisbon  NNSA expects these Megaports to become operational in September 2012.
section_title: Appendix V: Megaports Initiative’s Total Budget and Expenditures, Fiscal Years 2003 through 2012
subsections: section_title: Fiscal year 2003
paragraphs: Supplemental  funding  (constant  dollars)
Fiscal year 2012 expenditures are as of December 2011.
section_title: Appendix VI: Comments from the Department of Energy
subsections: section_title: GAO Comments
paragraphs: 1.  We agree that NNSA has made progress installing additional  Megaports, and we state several times throughout our report that  NNSA had completed 42 Megaports as of August 2012. However, we  also believe it is important to discuss challenges facing the Initiative,  such as foreign political considerations that are outside of NNSA’s  control and have affected the agency’s ability to implement the  Initiative.  2.  NNSA commented that it takes exception to five issues related to our  finding that China has not fully embraced the Megaports Initiative:   (1) the number of operational Chinese Megaports, (2) China’s  scanning of only exports, (3) the use of Chinese radiation detection  equipment instead of U.S. equipment, (4) China’s lack of sharing data  related to the performance of equipment with NNSA, and (5) China’s  limited cost-sharing. We continue to believe that, collectively, these  conditions we observed associated with the Chinese Megaport  indicate that the Chinese government is not fully participating in the  Initiative. Specifically:
As we state in our report, the Initiative has established only 1  Megaport in China out of the 12 Chinese ports that are ranked in  the Initiative’s top 100 highest priority ports. In our view, this  indicates that much more needs to be done in China to address  the potential risk of illicit trafficking of nuclear and radioactive  material. However, as NNSA states in its written comments, the  agency has discussed with the Chinese government adding  additional Megaports in the future and, as a result, we have  revised our report to include this information.
In its written comments, NNSA states that, as part of the pilot  Megaport in China, NNSA and the Chinese government had  agreed to equip 17 export lanes. Notwithstanding that fact, as we  state in our report, most other partner countries scan exports and  imports. As a result, it is important to scan both exports and  imports because the goal of the Megaports Initiative is to scan as  many shipping containers as possible, regardless of destination to  meet the Initiative’s most basic goal—combating nuclear  smuggling.
In its written comments, NNSA states that the Initiative does not  require partners to use a certain brand of radiation detection  equipment and that there are benefits to partners using  indigenous equipment, such as strengthening sustainability. While  we agree that there could be advantages to using indigenous  equipment, nearly all partner countries use Megaports-provided  equipment, which gives the United States greater assurance in the  capabilities and reliability of the equipment. In the case of China,  the Initiative had to spend additional funding to test and certify the  Chinese equipment. In fact, senior NNSA officials told us in  February 2012 that they believe the Initiative’s certification of this  equipment gives the Chinese company an advantage in the global  market. For these reasons, we stand by our finding that China’s  insistence that the Initiative uses Chinese equipment reflects a  lack of commitment to the Initiative.
In its written comments, NNSA states that its arrangement with  China allows for the sharing of information on the detection or  seizure of illicitly trafficked special nuclear material or other  radioactive materials. This may be true, but China is one of the  few Megaports partner countries that does not share scanning  data with the United States. Without these data, NNSA does not  have a consistent way to ensure that the equipment is being used  properly or being used at all. In our view, routinely sharing these  data is a gesture of goodwill, commitment, and cooperation on the  part of the partner country.
In its written comments, NNSA responds to our finding that the  Chinese provided a small amount of funding for the Megaports  Initiative—$256,000 as of February 2012. NNSA states in its  comments that the Chinese government has contributed $20  million to a training center for customs officers. The training  center, however, is not part of the Megaports Initiative, and it does  not help the Initiative in reaching its goals to scan shipping  containers for nuclear and radiological material. In addition, senior  NNSA officials told us that the Chinese contributions to the  training center were a rough estimate and that they did not have  great confidence in the accuracy or validity of the Chinese cost- sharing data.  3.  We modified our report to clarify that our finding regarding the testing  of radiation detection equipment is specific to SPMs and not radiation  portal monitors.  4.  In its comments, NNSA states that it wanted to clarify our finding that  some partner countries are not fully using radiation detection  equipment. We reiterate our finding that seven of the eight seaports  we visited were using the secondary radiation detection equipment on  a limited basis. As NNSA highlighted in its comments, we also state in  our report that NNSA recognizes that there are practical challenges to  conducting secondary inspections on 100 percent of containers that  trigger a primary alarm. However, as we state in our report, at U.S.  ports of entry, 100 percent of containers that produce an initial alarm  must be verified with more precise secondary scanning equipment.  Moreover, according to DHS officials who manage the domestic  radiation detection program, secondary scanning reduces the risk that  containers may be masking or shielding nuclear material.  5.  NNSA states in its comments that it takes exception to our finding that  Panama is not fully participating in the Megaports Initiative.  Specifically, NNSA stated that Panama is an example of a country  where NNSA signed a joint arrangement with DHS’s Container  Security Initiative. Moreover, according to NNSA, as implementation  plans were developed, Megaports agreed, as a first step, to place  radiation detection monitors near Container Security Initiative  equipment so that all of DHS’s targeted containers would be scanned  by RPMs. This resulted in a small fraction of containers being  scanned. Nevertheless, according to Panamanian officials, the four  Megaports in Panama scan less than 1 percent of container traffic.  Moreover, two terminal operators in Panama told us that they are not  interested in conducting additional scanning. Officials from the  terminal operator for the port where NNSA plans to add a MRDIS also  told us in March 2012 that they have not yet agreed to the placement  of the MRDIS and were concerned about it delaying port operations.  In its comments, NNSA stated that Panamanian Customs officials  support the Megaports Initiative—we agree. However, the example  that we give to show that the Panama is not a full participant in the  Initiative is that the terminal operators—who play a critical role in  implementing the Initiative—expressed strong reservations about  participating in the Initiative. As a result of our discussion with terminal  operators in Panama, we continue to believe that Panama’s four  Megaports are not fully participating in the Initiative, as evidenced by  the less than 1 percent of container traffic scanned—far from the  Initiative’s goal of scanning as many shipping containers as possible,  regardless of destination.  6.  NNSA states that SLD has taken several steps to help partner  countries with sustainability, such as providing partner countries with  3 years of maintenance and sustainability support and regularly  assessing countries’ progress in operations and management,  training, and maintenance and logistics. We state in the first section of  our report that NNSA has developed the SLD Sustainability Program,  and we discuss in detail the various components of this program.  7.  We continue to believe that sustainability is a challenge for the  Megaports Initiative. For example, officials in two of the countries we  visited reported concerns about funding the operations and  maintenance of Megaports equipment after NNSA transfers  responsibility, and officials in all five countries we visited reported  various staffing issues, such as recruiting, retaining, and funding staff  who operate Megaports equipment and respond to alarms.  Furthermore, a senior official who works for a global terminal operator  told us that he is not confident that countries will continue operating  the Megaports equipment if the Initiative is eliminated. As such, we  continue to believe that, without a plan in place to ensure the  sustainability of Megaports operations in the future, NNSA cannot be  confident that this equipment will continue to be used for the purposes  intended or if it will be used at all. NNSA agreed with this  recommendation and stated that it intends to finalize the sustainability  plan.  8.  NNSA commented that SLD began using the term SPM instead of  ASP because it is a general term for all spectroscopic portal monitors.  This statement is in direct contradiction to what we were told by NNSA  officials during the course of our review. At that time, NNSA officials  stated that they changed the name of spectroscopic equipment from  ASP to SPM to avoid the negative connotations associated with the  ASP program. As a result, we are not revising the text.  9.  In its comments, NNSA pointed out that we reported that one port we  visited uses its SPM unit as a secondary scanning tool on a limited  basis. To counter our finding, NNSA commented that Thailand uses  its SPM unit on 100 percent of alarming containers. We did not  independently verify that Thailand is using its SPM for 100 percent of  containers that trigger a primary alarm.   10. We have modified this statement in the report to clarify that NNSA’s  storage costs of over $1 million include SPMs, as well as other types  of equipment. However, the larger point remains that SPMs are part of  this unused inventory, and NNSA has agreed with our  recommendation to remove SPM units from storage on an expedited  basis.
section_title: Appendix VII: Comments from the Department of Homeland Security
section_title: Appendix VIII: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
paragraphs: David C. Trimble, (202) 512-3841 or trimbled@gao.gov.
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Gene Aloise; Glen Levis,  Assistant Director; Amanda Krause Kolling; Timothy Persons, Chief  Scientist; Emily Suarez-Harris; and Holly Williams made key contributions  to this report.
Technical assistance was also provided by Steve Caldwell, Antoinette  Capaccio, Rebecca Shea, and Carol Herrnstadt Shulman.