Nuclear Nonproliferation: Additional Actions Needed to Improve Security of Radiological Sources at U.S. Medical Facilities
Published: 2012-09-10T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In the hands of terrorists, radiological material, such as cesium-137, could be used to construct a "dirty bomb." Such material--encapsulated in steel or titanium and called a sealed source--is commonly found in equipment used by U.S. medical facilities to treat, among other things, cancer patients. NRC is responsible for regulating the commercial use of sealed sources and has relinquished its regulatory authority to 37 states, known as Agreement States. In 2008, NNSA established a program to provide security upgrades to U.S. hospitals and medical facilities that use radiological sources. GAO was asked to determine (1) the extent to which NRC's requirements ensure the security of radiological sources at U.S. medical facilities and (2) the status of NNSA's efforts to improve the security of sources at these facilities. GAO reviewed relevant laws, regulations, and guidance; interviewed federal agency and state officials; and visited 26 hospitals and medical facilities in 7 states and Washington, D.C.
section_title: What GAO Found
paragraphs: The Nuclear Regulatory Commission's (NRC) requirements do not consistently ensure the security of high-risk radiological sources at the 26 selected hospitals and medical facilities GAO visited. One reason for this is that the requirements are broadly written and do not prescribe specific measures that hospitals and medical facilities must take to secure medical equipment containing sealed sources, such as the use of cameras or alarms. Rather, the requirements provide a general framework for what constitutes adequate security practices, which is implemented in various ways at different hospitals. Some of the medical equipment in the facilities visited was more vulnerable to potential tampering or theft than that of other facilities because some hospitals developed better security controls than others. Some examples of poor security GAO observed included: an irradiator, used for medical research and containing almost 2,000 curies of cesium-137, was stored on a wheeled pallet down the hall from, and accessible to, a loading dock at one facility; at a second facility, the combination to a locked door, which housed an irradiator containing 1,500 curies of cesium- 137, was clearly written on the door frame; and at a third facility, an official told GAO that the number of people with unescorted access to the facility's radiological sources was estimated to be at least 500. In addition, some NRC and Agreement State inspectors said the training NRC requires is not sufficient.
As of March 2012, the National Nuclear Security Administration (NNSA) had spent $105 million to complete security upgrades at 321 of the 1,503 U.S. hospitals and medical facilities it identified as having high-risk radiological sources. Of the 26 hospitals and medical facilities that GAO visited, 13 had volunteered for the NNSA security upgrades and had received security upgrades, such as remote monitoring systems, surveillance cameras, enhanced security doors, iris scanners, motion detectors, and tamper alarms; three others were in the process of receiving upgrades. However, NNSA does not anticipate completing all such security upgrades until 2025, leaving a number of facilities potentially vulnerable. In addition, the program's impact is limited because, among other things, it is voluntary, and facilities can decline to participate. To date, 14 facilities, including 4 in large urban areas, have declined to participate in the program. Combined, those 14 facilities have medical equipment containing over 41,000 curies of high-risk radiological material. According to police department officials in a major city, one hospital with a blood irradiator of approximately 1,700 curies has declined the NNSA upgrades due in part to cost concerns, even though the police department considers it to be a high-risk facility.
section_title: What GAO Recommends
paragraphs: GAO recommends, among other things, that NRC strengthen its security requirements by providing medical facilities with specific measures they must take to develop and sustain a more effective security program. NRC neither agreed nor disagreed with this recommendation and stated that its existing security requirements are adequate. GAO continues to believe that implementing its recommendation would contribute to increased security at U.S. hospitals and medical facilities.

section_title: Letter
paragraphs: Radioactive material is used worldwide for legitimate purposes, including  medical procedures for treating cancer, purifying blood, or conducting  research. Material used for these purposes is typically sealed in a metal  capsule such as stainless steel, titanium, or platinum, to prevent its  dispersal and is commonly called a sealed source. Some of these  sources are highly radioactive, and can be found in medical equipment in  U.S. hospitals and medical facilities, which are often open to the public  and located in large population centers. The small size and portability of  sealed radiological sources make them potentially vulnerable to theft or  misuse when not adequately secured.
In the hands of terrorists, these sealed sources could be used to produce  a simple and crude but potentially dangerous weapon, known as a dirty  bomb, by packaging explosives with the radioactive material for dispersal  when the bomb goes off. A dirty bomb detonation would likely result in  few deaths, mainly from the explosion, but could create significant social  and economic impacts from public panic, decontamination costs, and  denial of access to the area in which the detonation took place for  extended periods. A 2004 study by the National Defense University noted  that the economic impact on a major populated area from a successful  dirty bomb attack is likely to equal, and perhaps exceed, that of the  September 11, 2001, attacks on New York City and Washington, D.C.  The potential impacts of a dirty bomb attack could also produce  significant health consequences. In 2002, the Federation of American  Scientists concluded that an americium radiological source combined with  1 pound of explosives would require medical supervision and monitoring  for the population of an area 10 times larger than the area hit by the initial  blast.
Incidents involving radiological sources can provide a measure of  understanding of what could happen in the case of a dirty bomb attack.  For example, in 1987, an accident involving an abandoned, or orphaned,  teletherapy machine, which is used to treat cancer by focusing a beam of  radiation from a highly active radiological source at affected tissue, killed  four people and injured many more in the region of Goiania in central  Brazil. The device encapsulated about 1,400 curies of cesium-137, which is generally in the form of a powder similar to talc and highly dispersible. The accident and its aftermath caused about $36 million in damages to  the region, according to an official from Brazil’s Nuclear Energy  Commission. In addition, the accident created environmental and medical  problems. Specifically, 85 houses were significantly contaminated, and 41  of these had to be evacuated. The decontamination process required the  demolition of homes and other buildings and generated 3,500 cubic  meters of radioactive waste. Furthermore, over 8,000 persons requested  monitoring for contamination in order to obtain certificates stating they  were not contaminated.
A curie is a unit of measurement of radioactivity. In modern nuclear physics, it is precisely  defined as the amount of substance in which 37 billion atoms per second undergo  radioactive disintegration. In the international system of units, the becquerel is the  preferred unit of radioactivity. One curie equals 3.7 x 10 becquerels. controlled or unrestricted area and that is not in storage. However, NRC  did not specify in its regulations how licensees were required to  implement the specific requirements. After September 11, 2001, NRC  reviewed the existing security requirements and determined that  increased security of radiological material was necessary. Therefore,  NRC issued a security order in 2005 directing those licensees possessing  certain types of radiological materials, including those commonly used in  hospitals and medical facilities, to implement increased security  measures, such as conducting employee background checks. In 2007,  NRC issued an additional security order requiring that individuals  requesting unescorted access to radiological material also undergo  fingerprinting with verification through the Federal Bureau of  Investigation. In addition, NRC provided licensees with implementation  guidance for the two security orders.
GAO, Nuclear Nonproliferation: Further Actions Needed by U.S. Agencies to Secure  Vulnerable Nuclear and Radiological Materials, GAO-12-512T (Washington D.C.: Mar. 14,  2012).
Federal Register.requirements in the earlier security orders but do not provide a  prescriptive framework that would direct hospitals and medical facilities  on how to secure their high-risk radiological sources. For example, when  the regulations become effective, they will provide hospitals and medical  facilities with more specific information on how they must monitor their  high-risk radiological sources against tampering and theft, including a  requirement that they choose their security measures from a menu of  options, such as a monitored intrusion detection system that is linked to  an on-site or off-site central monitoring facility or providing direct visual  surveillance by approved individuals located within the security zone.  However, the pending regulations allow licensees to choose any single  option, regardless of the risk posed by the radiological source or the  location of the licensee’s facility. In addition, the security measures  provided in the pending regulations are very similar to the measures  outlined in the prior implementation guidance. For the purposes of this  report, we are referring to the NRC security orders and implementation  guidance, which contain security requirements, as “NRC security  controls” or “requirements.” For additional information on the current NRC  security controls under the NRC security orders and the approved but not  yet published final regulations, see appendix II.
Pub. L. No. 83-703 § 274 (1954.) The following are the 37 states that have entered into  an agreement with NRC, whereby NRC has relinquished authority, and those states have  assumed regulatory authority over certain byproduct, source, and small quantities of  special nuclear materials: Alabama, Arizona, Arkansas, California, Colorado, Florida,  Georgia, Illinois, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts,  Minnesota, Mississippi, Nebraska, Nevada, New Jersey, New Hampshire, New Mexico,  New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode  Island, South Carolina, Tennessee, Texas, Utah, Virginia, Washington, and Wisconsin. with NRC regulations. Figure 1 shows which states are overseen by NRC  and which are Agreement States.
The National Nuclear Security Administration (NNSA), a separately  organized agency within the Department of Energy (DOE), established a  voluntary program in 2008 as part of its Domestic Material Protection  program to provide security upgrades, beyond what NRC requires, to  U.S. commercial facilities that contain high-risk radiological materials. The  upgrading of hospitals and medical facilities is one component of the  Domestic Material Protection program, which also secures high-risk  radiological sources in other commercial facilities and sites. NNSA has  identified approximately 1,500 U.S. hospitals and medical facilities with  high-risk radiological sources that contain approximately 28 million curies  of radioactive material and that are candidates for security upgrades.  NNSA also provides training for hospital personnel and local police  departments through its Alarm Response Training program at the Y-12  National Security Complex in Oak Ridge, Tennessee. This NNSA-funded  training is designed to teach facility personnel and local law enforcement  officials how to protect themselves and their communities when  responding to alarms indicating the possible theft or sabotage of nuclear  or radioactive materials.
Additionally, other federal agencies, such as the Departments of Defense  (DOD) and Veterans Affairs (VA), which are NRC licensees, are required  to implement their programs to meet all NRC requirements to secure  radiological sources at U.S. hospital and medical facilities.
This report responds to your request for a review of radiological source  security. For this report, we determined (1) the extent to which NRC’s  requirements ensure the security of high-risk radiological sources at U.S.  hospitals and medical facilities and (2) the progress NNSA has made and  the challenges it faces providing security upgrades at U.S. hospitals and  medical facilities that contain high-risk radiological sources.
To conduct this work, we reviewed relevant laws, regulations, and  guidance for overseeing radiological sources. We interviewed agency  officials at NNSA, NRC, DOD, VA, and the Departments of Homeland  Security (DHS), and Justice (DOJ). We also interviewed experts in the  field of nuclear security, state government officials in selected states, and  safety and security personnel at hospitals to obtain their views on how  radiological sources are secured at U.S. hospitals and medical facilities.  To examine how NRC’s requirements affect the security of high-risk  radiological sources at U.S. hospitals and medical facilities, we collected  information and interviewed agency officials responsible for overseeing  and securing sources at NRC, NNSA, VA, DOD, DHS, and DOJ. We also  gathered information from Agreement States and NRC regions by  collecting information and interviewing officials at 20 selected Agreement  States and the three NRC regional offices with responsibility for  overseeing high-risk radiological sources. To learn how NRC  requirements are implemented at the facilities, we visited 26 hospitals and  medical facilities in California, Maryland, New York, Pennsylvania,  Tennessee, Texas, Virginia, and Washington, D.C. We selected these  hospitals and medical facilities on the basis of geographic dispersion, the  amount of curies contained in their radiological sources, and types of  radiological devices. The facility information is not generalizable to all  hospitals or medical facilities but provides illustrative examples. We also  visited local law enforcement agencies in California, New York, and  Washington, D.C. To evaluate the extent to which NNSA has enhanced  the security of high-risk radiological sources at U.S. hospitals and medical  facilities and the challenges they face, we analyzed information from and  interviewed NNSA officials about their Domestic Material Protection  program, which partners with hospitals and medical facilities to provide  voluntary security upgrades to facilities with high-risk radiological sources.  We also visited facilities that received NNSA upgrades and security  assessments in California, New York, Pennsylvania, Tennessee, Texas,  Virginia, and Washington, D.C. These facilities were selected to provide  us with a cross section of hospitals and medical facilities that had  completed security upgrades, were in the process of completing  upgrades, or had volunteered for the program and were negotiating with  NNSA about the scope of the upgrades. To determine the costs of these  security upgrades, we obtained cost data from NNSA and interviewed the  agency officials who oversee the program. To assess the reliability of  these data, we discussed their reliability with knowledgeable NNSA  officials and questioned them about the system’s internal controls to verify  the accuracy and completeness of the data. We found the data  sufficiently reliable for our reporting purposes. Appendix I presents a  more detailed description of our scope and methodology.
We conducted this performance audit from April 2011 to September 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: Radiological sources are used throughout the world for peaceful  purposes. Until the 1950s, only naturally occurring radioactive materials,  such as radium-226, were available to be used in radiological sources.  Since then, sources containing radiological material produced artificially in  nuclear reactors and accelerators have become widely available,  including cesium-137, cobalt-60, iridium-192, and strontium-90, which are  used to treat cancer through radiotherapy and cesium-137, which is also  used to treat blood. See figure 2, which shows an example of an  americium-241 sealed radiological source. Sealed sources vary in size  from the size of a pencil eraser to rods up to several inches in length.
Radiological material can be found in various forms, such as metals or  powders, and is measured by its level of activity. The greater the activity  level—measured in curies—the more radiation emitted, which increases  the potential risk to public health and safety if improperly used or  controlled. The intensity of radiological materials decays over time at  various rates. The term “half-life” is used to indicate the period during  which the radioactivity decreases by half as a result of decay. In general,  the shorter the half-life and the larger the mass, the more radiation will be  emitted within a particular period.
According to the International Atomic Energy Agency (IAEA),of protection provided by users of the radiological material should be  commensurate with the safety and security risks that it presents if  improperly used. For example, radiological materials used for certain  diagnostic purposes, such as diagnostic imaging, have low levels of  activity and do not present a significant safety or security risk. However,  high-risk sealed radiological sources that contain cobalt-60, cesium-137  or iridium-192, could pose a greater threat to the public and the  environment and could also pose a potentially more significant security  risk, particularly if acquired by terrorists to produce a dirty bomb.
Two types of licenses are associated with the use of radioactive materials—general  licenses and specific licenses. General licenses are associated with products that contain  some radioactive material, such as fixed gauges or exit signs, and the owners of these  products do not have to apply to NRC or an Agreement State for a license. A company  seeking radiological material for uses that do not qualify for a general license must apply  to NRC or, if it conducts business in an Agreement State, to the appropriate state office for  a specific license. Specific licenses include those of “limited scope,” in which radioactive  materials will be used by a defined number of authorized users, and those of “broad  scope,” for facilities that have experience successfully operating under a specific license  of limited scope.
Officer (RSO), to oversee compliance with applicable NRC and  Agreement State regulations, including security controls.
NRC has stated that nuclear and radiological materials are critical and  beneficial components of global medical, industrial, and academic efforts.  However, the possibility that these materials could be used by terrorists is  a national security concern. As a result, NRC tracks the number of  hospital and medical facility licensees with radionuclides of concern  through its National Source Tracking System. This database provides a  “cradle-to-grave” account of the origins of each radiological source  (manufacture, remanufacturing, or import) and records who used it and  eventually disposed of, or exported it. NNSA coordinates with NRC to  receive these updated data and has further enhanced the data for its  purposes, including identifying which radioactive materials are associated  with which licenses and what sources are located in which facilities.
section_title: NRC Requirements and Implementation by Licensees Do Not Ensure the Security of High-Risk Radiological Sources
paragraphs: At the 26 selected hospitals and medical facilities we visited, NRC’s  requirements did not consistently ensure the security of high-risk  radiological sources. One reason for this is that the requirements, which  are contained in NRC security controls (i.e., the two security orders and  implementation guidance) are broadly written and do not prescribe  specific measures that licensees must take to secure their equipment  containing high-risk radiological sources. Some of the NRC-licensed  hospitals and medical facilities we visited are more at risk than others to  sabotage and theft because some hospitals developed better security for  protecting their radiological sources than others. Licensees have  implemented these broad requirements in various ways, leaving some  hospitals’ radiological sources more vulnerable than others. In addition,  some inspectors said that the NRC-required training is not sufficient, and  personnel at hospital and medical facilities are not required to have  security training, although they implement NRC requirements at their  sites. NRC reviews of Agreement States also found that some Agreement  States do not have sufficient staffing and resources to enforce NRC  security controls.
subsections: section_title: NRC’s Security Requirements Governing Radioactive Material Are Non prescriptive
paragraphs: NRC’s requirements direct licensees possessing high-risk radiological  material contained in medical equipment to implement increased security  measures. However, these requirements are broadly written and do not  prescribe the specific steps hospitals and medical facilities must take to  secure the material. Rather, the security controls and their requirements  provide a general framework for what constitutes adequate security  practices. The officials said that the key elements of the framework  include: (1) limiting access to only approved individuals through the use of  background checks that include fingerprinting; (2) enhancing physical  barriers and intrusion detection systems; (3) coordinating with local law  enforcement to respond to an actual or attempted theft, sabotage, or  diversion of radiological material; (4) promptly notifying authorities of  incidents; and (5) monitoring shipments of radiological material during  transit. According to NRC officials, the intent of the security controls is to  develop a combination of people, procedures, and equipment that will  delay and detect an intruder and initiate a response to the intrusion—not  to provide absolute security from theft or unauthorized access. The  security controls provide minimum requirements that must be met to  ensure adequate security, and licensees may go beyond the minimum  requirements.
NRC officials told us that they have adopted a risk-based approach to  security, in which the level of security should be commensurate with the  type and amount of sources they are attempting to protect. In addition,  NRC officials said that they take facility costs into consideration when  issuing new security requirements. The risk-based approach reflects the  agency’s concerns regarding the potential adverse financial effect that  additional security measures could have on private medical facilities  throughout the United States. As a result, the security controls issued by  NRC are intentionally broad to allow licensees flexibility when  implementing security upgrades. However, according to NRC officials,  NRC requirements relating to the adequate protection of public health and  safety do not consider costs. The officials state that this approach aligns  with Executive Order 12866, which directs Executive Branch agencies to  tailor their regulations to impose the least burden on society, including  individuals, businesses of differing sizes, and other entities (including  small communities and governmental entities), consistent with obtaining  the regulatory objectives, taking into account, among other things, and to  the extent practicable, the costs of cumulative regulations. However, the  Executive Order requirements in pertinent part do not apply to the NRC,  but NRC follows many of the provisions voluntarily. In late April 2012,  NRC released a document that stated, among other things, that its  security program is a multilayered, non prescriptive framework that allows  licensees to develop security programs specifically tailored to their  facilities. NRC officials told us that due to diverse economic conditions,  facility type, layout, and operations of hospital and medical facilities, a  “one size fits all” approach to radiological source security is neither  practical nor desirable. The officials said that the ability to tailor security to  a facility’s needs and resources is particularly important for commercial  facilities with limited resources. For example, personnel from one smaller  medical facility we visited told us that implementing specific security  requirements—such as cameras and other surveillance equipment— could jeopardize their continued operations because of the costs  associated with the installation and maintenance of this equipment.
NRC’s implementation guidance, which supplements the security orders,  provides examples of how hospitals and medical facilities can secure their  high-risk radiological material and meet security requirements. In their  implementation guidance, NRC provides that facilities may meet the  security requirements by, for example, limiting the distribution of keys, key  cards, or combinations to doors and gates to approved individuals;  activating locked doors and gates by using remote surveillance; using a  card reader and electronic locking devices at control points; and having a  person approved for unescorted access conduct constant surveillance of  the devices containing the radiological material.
However, ultimate responsibility for implementing NRC’s security controls  is left to the discretion of the hospital and medical facility personnel that  possess the materials. The controls do not prescribe the specific  measures that licensees must take to secure their sources, such as the  use of cameras, alarms, and other physical security measures. The  licensee determines, for example, if security cameras are necessary or  what types of locks or alarms, if any, are needed to secure doors or  windows. For some locations we visited that are staffed 24 hours a day,   7 days a week, such as blood banks, requirements for access control can  be met when the room where the medical device containing radiological  material is located is continuously staffed by an individual or individuals  who are determined to be trustworthy and reliable. As long as the room is  staffed at all times, the facility is not required to have any additional  physical security, such as cameras or motion detection equipment.
NRC’s security controls require hospital and medical facility personnel to  conduct background checks to determine the trustworthiness and  reliability of individuals requesting unescorted access to radiological  material. NRC officials told us that background checks are important for  protecting against an “insider threat,” in which someone with access to  the radiological material might try to remove, tamper with, or sabotage the  source. NRC’s implementation guidance states that the commission’s  requirements are not intended to stop determined adversaries intent on  malevolent action from gaining access to the radioactive material. Rather,  these requirements are designed to provide reasonable assurance that  individuals with unescorted access to the radioactive material are  trustworthy and reliable and that facilities have a reliable means to rapidly  identify events that are potentially malevolent and have a process for  prompt police response. Furthermore, hospital and medical facility  officials are responsible for appointing a trustworthiness and reliability  official (T&R official), who is to determine which employees will be  granted unescorted access to the device containing radioactive material.  The T&R officials at the 26 hospitals and medical facilities we visited were  typically RSOs, security officials, or officials from the human resources  department. When granting unescorted access for individuals employed  less than 3 years, NRC also requires hospitals and medical facilities to, at  a minimum, verify employment history, education, and personal  references. For individuals employed for longer than 3 years, facilities are  to determine trustworthiness and reliability, at a minimum, by reviewing  the employee’s employment history with the facility.
Officials at 5 of the 26 hospitals and medical facilities we visited told us  they face challenges in determining which individuals are suitable for a  trustworthiness and reliability certification. For example, two of these five  officials said that the current background examination process places too  much emphasis on the judgment of hospital personnel. Performing  background checks on foreign nationals is also particularly challenging.  Officials at 6 of the 26 hospitals and medical facilities we visited agreed,  citing, for example, the difficulty in acquiring relevant background  information from different countries, the inability to corroborate written  documentation, and language barriers. Administrators at 2 of these 6  hospitals also told us that a more centralized background examination  process with uniform criteria and standards should replace the current  system, which varies from facility to facility.
section_title: Some Medical Facilities Licensed by NRC Are More Vulnerable Than Others to Potential Sabotage and Theft Because of Security Weaknesses
paragraphs: The 26 hospitals and medical facilities we visited in seven states and  Washington, D.C., have implemented NRC’s security controls in a variety  of ways that could leave some facilities’ radiological sources more  vulnerable than others to possible tampering, sabotage, or outright theft  because, on their own initiative, some facilities have decided to  implement more stringent security measures than others.
Law enforcement personnel from states with significant amounts of high- risk radioactive material told us that NRC’s security controls have an  inherent weakness: they do not specify what the facility is protecting  against and are not linked to a design basis threat. According to IAEA, a  design basis threat includes the attributes and characteristics of a  potential insider and/or external adversaries, who might attempt  unauthorized removal or sabotage, against which a physical protection  system is designed and evaluated. NRC officials noted that, according to  IAEA’s Nuclear Security Series Implementation Guide No. 11, “Security of  Radioactive Sources,” the design and evaluation of a security system  should take into account the current national threat assessment and may  include the development and application of a design basis threat,  although it is not required.
Typically, a design basis threat characterizes the elements of a potential  attack, including the number of attackers, their training, and the weapons  and tactics they are capable of employing. Instead, NRC relies solely on  the amount of curies under the control of a hospital or medical facility  when determining if the facility is subject to increased security controls.  According to NRC, it would not be feasible to require a design basis  threat analysis for U.S. hospitals and medical facilities because of the  varied nature of the facilities and the additional resources required to  conduct an analysis for individual facilities. NNSA also does not use a  design basis threat for its security assessments of hospitals and medical  facilities but does employ a threat scenario (known as potential adversary  capability) as the basis for its recommendations for security  enhancements. NNSA defines Potential Adversary Capabilities as the  method for documenting a realistic threat level that the security upgrades  must enhance protection against. At VA, which is overseen by NRC under  a Master Materials License (MML),radiological security told us that VA initially developed a generic threat  scenario for use at its facilities with high-risk radiological materials  because NRC did not provide a design basis threat as part of its security  controls. Later, VA coordinated closely with NNSA to complete security  assessments and install security upgrades at the VA facilities with high  risk sources. The assessments were completed from 2009 through 2011,  with installation of the agreed upon security upgrades currently ongoing.  VA facilities have also participated in the NNSA Alarm Response training  program.
All of the 26 medical facilities we visited have implemented NRC’s  security controls and undergone inspections by either NRC or Agreement  State inspectors. At some facilities, the implementation of the controls  resulted in significant security upgrades, such as the addition of  surveillance cameras, upgrades to locks on doors, and alarms. NRC  stated that, although hospitals are open to the public, the specific location  housing a radiological source generally is not. These sources are  shielded inside medical devices that can weigh thousands of pounds,  which make it difficult to remove or tamper with the radiological material,  according to NRC.
Notwithstanding NRC’s views, we observed potential security  weaknesses in several facilities we visited, such as the following:
At a hospital in one state, two cesium-137 research irradiators (i.e.,  used for medical or biological research), that contain approximately  2,000 curies and 6,000 curies, respectively, are housed in the  basement of a building that is open to the public. The hallway leading  to the irradiator room has a camera, but it is pointed away from the  room. The door to the room is opened by a swipe card lock, and there  are no cameras or other security measures inside the room. We  observed that one of the irradiators was sitting on a wheeled pallet.  When we asked the RSO if he had considered removing the wheels,  he said no. Furthermore, we observed that the irradiator room is  located in close proximity to an external loading dock and that the  cameras along the corridor to the loading dock are displayed on a  single monitor, making it difficult for someone monitoring the corridor  to interpret what activity is occurring. This facility had passed its most  recent NRC security inspection, according to a hospital official,  because access to the room where the irradiators were located was  restricted through use of a swipe card. However, this facility could be  vulnerable because of the limited security we observed and the  mobility of one of the irradiators.
At a hospital in a major U.S. city, we observed that the interior door to  the hospital blood bank, which had a cesium-137 blood irradiator of  approximately 1,500 curies, had the combination to the lock written  on the door frame. The door is in a busy hallway with heavy traffic,  and the security administrator for the hospital said that he often walks  around erasing door combinations that are written next to the locks.  According to NRC officials, a single lock is not necessarily a security  weakness; however, failure to control the combination and restrict  access to only trustworthy and reliable individuals is a clear violation  of NRC requirements. Figure 3 shows the combination written on the  door frame to the blood bank.
At a blood center in a third state we visited, we observed a cesium- 137 blood irradiator of approximately 1,400 curies in a room that was  secured by a conventional key lock. The irradiator was located in the  middle of the room and not secured to the floor. The room had an  exterior wall with a bank of unalarmed and unsecured windows that  looked out onto a publically accessible loading dock. The blood center  officials said that, while they met NRC’s security controls, they  acknowledged that the center is highly vulnerable to theft or sabotage  of their radiological sources. According to NRC officials, an irradiator  sitting in the middle of the floor that is not bolted down is not  necessarily vulnerable. Figure 4 shows the irradiator that is not bolted  to the floor and the bank of unsecured windows looking out onto the  loading dock.
The RSO at a large university hospital told us that he did not know the  exact number of people with unescorted access to the hospital’s  radiological sources, although he said that there were at least 500.  The hospital’s current data system does not allow for entering records  for more than 500 individuals. In the past, he said, the hospital had as  many as 800 people with unescorted access to sources. In contrast,  at a major medical research facility on a military installation we visited,  access was limited to 4 safety and security personnel.
section_title: Some NRC and Agreement State Inspectors and Hospital and Medical Facilities Lack Training and Resources to Enforce NRC Requirements
paragraphs: NRC and Agreement State inspectors and hospital and medical facility  personnel we interviewed said that the NRC training has not prepared  them to adequately enforce NRC requirements. Furthermore, personnel  at the facilities said that they may not have the resources they need to  implement the security controls.
Some inspectors from NRC and Agreement States said that they have  not received adequate training from NRC on securing high-risk material at  hospitals and medical facilities. NRC requires that NRC and Agreement  State inspectors take training for implementing the security controls. NRC  has developed and provides a 5-day security training course for NRC and  Agreement State inspectors on how to implement the security controls.  The course takes place at DOE national laboratories, with recent training  occurring at Sandia National Laboratory in New Mexico. It includes 17  modules providing information on how to protect against malicious uses  of radioactive materials, such as the introduction to physical protection,  target identification, intrusion detection, security lighting, access control  systems, barriers, locking systems, and response forces. The course also  covers NRC security controls associated with the increased security  measures. However, even with this training, 6 of the 48 inspectors we  spoke with who cover both NRC regions and Agreement States told us  that they do not feel comfortable conducting security inspections at  hospitals and medical facilities. According to the inspectors, NRC’s  training course provides an introduction to security practices for those  with limited security experience and trains inspectors generally in how to  conduct security inspections. The inspectors typically have educational  backgrounds in radiation safety or health physics rather than security.  The inspectors said that not having security experience has made it  difficult for them to transition to conducting security inspections. Examples  are as follows:
An Agreement State inspector told us that he attended NRC’s training  program, but he did not believe that it sufficiently prepared him to be a  security expert and make the kinds of judgments required to  determine whether licensees have adequate security.
Inspectors from another Agreement State told us that the course did  not cover certain topics that they thought were essential to  radiological security, such as the use of radiation detectors. They also  said that they were placed in the awkward situation of having to  enforce NRC’s security orders, which they did not believe they were  fully qualified to interpret.
Another Agreement State inspector from a third state we visited told  us that he was not qualified to do security inspections. However, he  said that he was doing the best he could to interpret the NRC security  controls and help the licensees implement the requirements.
An NRC inspector also said that security inspections were particularly  difficult for him because he is trained as a physicist. He said that the  security controls were confusing and that he did not understand the  nuances of security.
NRC’s security controls require hospitals and medical facilities to develop  a program for assessing and responding to unauthorized access,  including detecting an unauthorized intrusion, assessing the situation, and  calling for a response from the local law enforcement agency of an actual  or attempted theft of the high-risk radiological materials or the device  itself. However, none of the personnel who are responsible for  implementing the security controls for high-risk radiological sources at the  26 hospital and medical facilities we visited has been trained in how to  implement NRC’s security controls. In addition, 15 officials at the 26  hospitals and medical facilities told us that they have backgrounds in  radiological safety and facilities management and have limited security  experience, making them responsible for security with limited previous  experience to draw from. We found the following examples:
At one hospital, the RSO said that when the security controls were  instituted in 2005, his new responsibilities included ensuring the  security of a cobalt-60 gamma knife of approximately 2,600 curies,  which is used to treat cancer patients, and a cesium-137 blood  irradiator of about 2,400 curies. He told us that he was not  comfortable with his security role because he was trained as a health  physicist.
One facility manager who oversees the security for an approximately  1,700 curie cesium-137 blood irradiator at a blood bank told us that he  has a background in construction, not security. He said that it would  have been helpful if NRC’s controls were more prescriptive, including  better guidance, so that he would be in a better position to determine  what security would be most effective.
NRC requires medical facility officials to demonstrate radiation safety  expertise through a combination of education and work experience to be  eligible to become an RSO. However, the security controls do not require  that RSOs or other designated security officials have security experience  or that they take NRC security training. For example, NRC regulations  state that individuals may meet the eligibility requirements for becoming  an RSO by completing a master’s degree or doctoral degree in health  physics or a related field, combined with 2 years of full-time experience  under the supervision of a board-certified medical physicist. In addition,  NRC’s new regulations, when finalized, will require that officials at  hospitals and medical facilities provide training on their security program  and procedures to personnel involved in securing high-risk radiological  material. However, the regulations do not require that the RSO, who is  typically responsible for providing the training, has any formal security  education or work experience, although the RSO is responsible for the  security of radiological sources. Without training and adequate guidance,  medical facility officials, including RSOs, who may be responsible for  implementing NRC’s security controls, may not have adequate knowledge  of securing equipment containing high-risk radiological sources.
section_title: Some Agreement States Do Not Have Sufficient Staffing and Resources to Enforce Security Controls
paragraphs: NRC’s recent reviews of Agreement States’ inspection programs showed  a lack of adequate staff, resources, and security training in two states.  In its review of one of the state’s inspection programs, NRC reported that  the program experienced significant turnover and that inspectors did not  have an adequate understanding of the security controls. According to an  official in this state, high staff turnover and the resulting lack of security  experience affected the quality of the state’s oversight. In addition, staff  turnover issues have kept inspectors from receiving needed on-the-job  training or mentoring from experienced inspectors. As a result, inspectors  have difficulty assessing whether licensees comply with NRC security  controls. According to NRC’s review of the state program, the state  inspectors took steps to incorporate interviews with appropriate personnel  and performance observations into their inspection activities. However,  inspectors often did not adequately follow up on potential items of non  compliance that were observed during the performance reviews. NRC’s  review noted that the state inspectors did not have sufficient familiarity  with NRC’s security controls and therefore had difficulty assessing  licensee compliance with the requirements. In one case, the inspector did  not identify or understand the security significance of an item of  noncompliance. In addition, during a final meeting with the facility  personnel responsible for managing the license, the inspector could not  clearly articulate the applicable requirements and was unable to explain  to the licensee what actions could be taken to correct the identified  deficiencies.
NRC reported that Agreement State inspectors completed some level of  preparation, such as reviewing NRC’s security controls, prior to their  inspections but, in some cases, their preparation was inadequate. In  addition, NRC officials stated that, in accompanying Agreement State  inspectors, they identified problems with the completeness of their  reviews, technical quality, consistency, and attention to health and  safety/security. NRC noted that the deficiencies were indicative of a  programmatic and chronic problem rather than an isolated occurrence or  a periodic decline in performance.
In its review of another Agreement State’s program, NRC stated that new  inspectors would have benefitted from additional training on NRC’s  security controls. An Agreement State inspector told NRC’s review team  that he did not understand the meaning of some of the documents he was  reviewing. Another Agreement State inspector stated that he was  authorized to inspect a radiological device independently—without being  accompanied by a more experienced inspector—before he was ready to  do so. In addition, some Agreement State inspectors told NRC’s review  team that they sometimes performed inspections without the added  benefit of having attended a training class for the type of inspection being  performed, primarily because they were unable to get into the classes.  One state program manager, who acts as the primary trainer for a state  inspection program, acknowledged to the NRC review team that because  of her workload she often has to limit the number of training classes  offered.
section_title: NNSA Completed Security Upgrades in More Than 300 Medical Facilities, but Some Hospitals Do Not Participate in the Voluntary Program
paragraphs: As of April 2012, NNSA had completed security upgrades at 321, or one- fifth, of the 1,503 U.S. hospital and medical facilities it had identified as  having high-risk radiological material but does not expect to complete all  such upgrades until 2025. In addition, the program’s impact is constrained  because: (1) it is voluntary, (2) hospitals and medical facilities will have to  maintain the upgrades beyond NNSA’s 3- to 5-year warranty period, and  (3) the program does not require facilities to sustain the upgrades.
subsections: section_title: NNSA Has Made Progress in Securing Radioactive Sources, but Does Not Expect to Complete All 1,500 Medical Buildings Until 2025
paragraphs: NNSA’s Domestic Material Protection program is designed to raise the  security at U.S. facilities with high-risk radiological material, including  hospitals and medical facilities, to a level that is above NRC and the  Agreement State’s regulatory requirements. NNSA’s voluntary program  provides these U.S. hospitals and medical facilities with security  assessments, but the agency does not share these assessments with  NRC and Agreement State inspectors. According to NNSA officials, the  agency does not share the assessments because of its concern that  hospitals and medical facilities, which are voluntarily cooperating with  NNSA, would not provide complete and candid information to NNSA if it  shared the assessments with NRC and Agreement State’s regulatory  inspection agencies. After completing the assessments, NNSA installs  security upgrades, such as remote monitoring systems, biometric access  controls, and security cameras, to secure the devices and facilities that  contain high-risk radiological sources. NNSA pays the cost for all security  upgrades, but hospitals and medical facilities are responsible for  maintaining the security systems after a 3- to-5-year warranty period  expires. According to NNSA officials, during the warranty period,  sustainability costs for the upgrades at each hospital average $40,000 per  facility per year, including equipment warranty and maintenance costs, as  well as the costs associated with labor and site visits to ensure that the  hospitals are properly operating the NNSA upgrades. The NNSA officials  estimate that when the hospitals are ready to assume full responsibility  for the security upgrades at their facilities, the sustainability costs  assumed by the hospitals are approximately $10,000 per facility per year.
Of the 1,502 U.S. medical facilities NNSA has identified that contain high- risk radiological sources, the agency has provided security upgrades to  321, or about 21 percent of them. The 1,502 facilities cumulatively contain  about 28 million curies of radioactive material, according to NNSA’s  estimate. According to NNSA officials, as of March 2012, the Domestic  Material Protection program had spent approximately $105 million to  provide security upgrades to radiological sources at the 321 facilities.  NNSA plans to complete security upgrades at all 1,502 medical facilities it  has identified as high risk by 2025, at a projected cost of $608 million.  NNSA officials also told us that they estimate the average cost to upgrade  a medical facility has been $317,800.goal is universal participation in their program by all licensees holding  high-risk radiological sources.
NNSA officials told us that their  NNSA provided a further breakdown of the approximately $105 million  that was spent as of March 1, 2012. As table 1 shows, the majority of  program expenditures were to complete security assessments and  equipment upgrades—such as cameras, motion detection devices, and  alarms—at U.S. hospitals and medical facilities. NNSA spent  approximately $99 million, or 95 percent of its total program costs, on  equipment, labor, and travel costs associated with the security  assessments and upgrades—primarily carried out by personnel from  Sandia National Laboratory, Pacific Northwest National Laboratory, and  private-sector security vendors. The program spent an additional  $975,800, or 1 percent of its total costs, on designing and testing  equipment used for security upgrades. The remaining $4.3 million, or 4.1  percent of NNSA’s total costs, was spent on laboratory overhead charges  and contract fees.
Of the 26 hospitals and medical facilities that we visited in seven states  and the District of Columbia, 13 had received NNSA upgrades, and 3  were in the process of receiving upgrades. Officials from 11 of the 16  hospitals and medical facilities told us that the NNSA program enhanced  the security of their facilities. We observed a number of security upgrades  at these facilities, including remote monitoring systems, surveillance  cameras, enhanced security doors, iris scanners, motion detectors, and  tamper alarms. In addition, NNSA officials told us that as part of the  program they fund the installation of in-device delay kits. These kits are  installed in the interior of medical equipment to make it more difficult to  remove or tamper with radiological material contained within the  equipment. NNSA officials told us that they currently contract with three  companies to install the kits in irradiators and have partnered with another  company to upgrade the security of new gamma knives. Figures 5, 6, 7,  and 8 provide examples of the different NNSA upgrades.
The voluntary nature of the NNSA program allows hospitals and medical  facilities to decline the upgrades, even though NNSA assumes all up-front  capital costs. Most hospitals and medical facilities we visited were  amenable to participating in the program, but NNSA officials told us that,  as of July 2012, 14 facilities have declined to participate in the voluntary  security upgrade program. These 14 facilities contain over 41,000 curies  of high-risk radiological material. According to NNSA officials, 9 of these  facilities declined to participate because facility management decided not  to accept any NNSA assistance; 3 were unwilling to accept the full suite  of NNSA security upgrades; and 2 were either facing bankruptcy or were  planning to have their radiological sources removed. Four of the 14  facilities are located in large urban areas that NNSA officials consider  high risk.
We met with officials from one hospital and one medical facility that  declined the NNSA upgrades. Both facilities were located in densely  populated urban areas. Specifically, we found the following:
According to police department officials in a major U.S. city, one  hospital with a blood irradiator of approximately 1,700 curies has  declined the NNSA upgrades, even though the police department  considers it to be a high-risk facility. The hospital officials told us that  they decided not to implement the NNSA upgrades because of  concerns about maintenance costs associated with the security  equipment after the 3- to 5-year NNSA-funded warranty period  expired. The RSO said that the security that the hospital has in place  is adequate. Furthermore, the RSO told us that the hospital is under  serious budget pressure that makes it difficult to justify spending more  money to sustain equipment for protecting their radiological sources.
Staff at a blood bank with a cesium-137 blood irradiator of  approximately 1,400 curies told us that NNSA was prepared to  upgrade the facility’s security but that the blood bank decided not to  participate. The blood bank officials said that senior management  wanted to wait until the blood bank moved to a new location, which it  planned to do within the next 3 years. However, we observed that the  blood irradiator was vulnerable to theft or tampering and discussed  these vulnerabilities with the blood bank officials, who agreed that  their device was vulnerable. In February 2012, we contacted NNSA  officials about this matter. As a result, the facility decided to volunteer  for the NNSA program, and NNSA and national laboratory officials  met with facility personnel and developed a plan to increase the  security of the irradiator by October 2012.
NNSA requires that hospitals and medical facilities sign a sustainability  statement, outlining responsibility for the security of high-risk radiological  material and stating that they will assume full responsibility for the  operation, testing, and maintenance of the security system after the  NNSA-funded warranty period expires. However, the agency does not  require that hospitals and medical facilities maintain the installed security  upgrades beyond the 3- to 5-year warranty period. Nine hospital and law  enforcement officials in three states we visited told us that not having  such a requirement to sustain NNSA’s upgrades limits the program’s  impact. NNSA officials told us that before they agree to implement the  security upgrades, they attempt to determine if a site is committed to  sustaining them. NNSA requires that hospital and medical facility officials  sign the sustainability statement after completion of the design, but prior  to the installation of the security upgrades. However, the NNSA officials  told us that the sustainability statement is not legally binding.
section_title: NNSA Generally Targets Security Upgrades to States with Significant Amounts of High-Risk Radiological Material
paragraphs: According to our review of NNSA documents and interviews with NNSA  officials, NNSA is, for the most part, funding security upgrades in states  that have the most high-risk radiological material at hospitals and medical  facilities. NNSA has developed a prioritization methodology that ranks  different facilities and is designed to assign resources according to the  relative risk of the radiological material and the expected risk reduction  resulting from the planned security activity. NNSA’s prioritization criteria  include four factors: (1) attractiveness level of the radiological material,  (2) site security conditions, (3) threat environment, and (4) location or  proximity to a target. In addition, NNSA officials told us that when ranking  facilities for upgrades, they consider whether the facility has requested or  volunteered for a security assessment under the program, if there are  multiple high-risk sources in the same facility, and if NNSA can gain  access to a number of sites through a partnership with other federal  agencies and organizations such as the Department of Agriculture, the  National Institutes of Health, and the American Red Cross.
Our analysis of NNSA data shows that NNSA is focusing the majority of  the program’s resources on states with high curie amounts and large  numbers of hospitals and medical buildings with high-risk radiological  sources. As of March 1, 2012, NNSA had spent $53 million—or 51  percent of total expenditures for the Domestic Material Protection  program—in Massachusetts, New York, Texas, Pennsylvania, and  California. These five states contain 37 percent of all hospitals and  medical facilities with high-risk radiological sources, and 39 percent of all  curies in hospitals in the United States.
However, as table 2 shows, some states with large numbers of hospitals  and medical facilities—Florida, Indiana, New Jersey, Ohio, and  Tennessee—have not received as many upgrades from NNSA. These  states received $13 million, or 12 percent of all NNSA expenditures since  the program began in 2008. Furthermore, other states with large numbers  of medical facilities, such as Alabama, Michigan, and Wisconsin, have  received no assessments or upgrades. In addition, some states with  relatively few hospitals and medical facilities and a small amount of curies  have each received more than $1 million from NNSA to upgrade their  facilities. These states were Hawaii and Rhode Island. In the case of  Hawaii, NNSA officials told us that the state has over 50,000 curies of  non-medical cesium-137, which made doing medical upgrades at the  same time cost effective. In addition, NNSA said that Hawaii served as a  model for how a network of facilities could be integrated into a centralized  security network. As NNSA moves forward with the program, these  officials said that they hope to replicate this model in some large cities  and additional small states.
NNSA officials told us that both the cost efficiencies and the voluntary  nature of the Domestic Material Protection program require that they  target sites based on their selection criteria and look for opportunities to  provide upgrades when hospitals and medical facilities volunteer for  assessments and upgrades. These officials stated that budgetary  uncertainty makes it necessary to identify states where they can  maximize their resources by upgrading a number of facilities in close  proximity to each other. In addition, NNSA conducts outreach efforts in  partnership with NRC and Agreement States to educate licensees about  its program and find hospitals and medical facilities that want to  participate. NNSA officials told us their outreach and promotional efforts  are constrained because they do not want to enlist more facilities in the  program than can be funded in a reasonable period of time. Additionally,  NRC has supported NNSA’s program by making licensees aware of the  program in a January 2010 NRC Regulatory Issue Summary. In the  issue summary, NRC officials encouraged licensees to work  cooperatively with manufacturers; regulators; and other federal, state, and  local authorities to look for opportunities to further enhance the security of  their sources and devices and incorporate best practices, where  appropriate. The NRC officials also stated that NNSA staff and  contractors have valuable perspectives and experience on best practices  from visiting multiple licensees and operations. According to an NNSA  official, increased collaboration with NRC and Agreement States to  promote the program would be beneficial.
However, some Agreement States are more proactive than others in  helping NNSA find such hospitals and medical facilities. For example,  NNSA has not completed upgrades in some states with a large number of  radiological sources, like Michigan and Wisconsin. The opposite is true in  some states with fewer sources, such as Hawaii and Rhode Island, where  NNSA found enough facilities to participate to make the upgrades cost  effective.
section_title: Conclusions
paragraphs: A dirty bomb attack in the United States would have serious economic  and psychological consequences. It is therefore in the interest of the  federal government to ensure that all high-risk radiological materials in  U.S. hospitals and medical facilities are secured as quickly as possible  from potential theft or sabotage. However, NNSA does not expect to  complete security upgrades at all hospitals and medical facilities in the  United States until 2025; one-fifth of the upgrades are completed to date.  In addition, the voluntary nature of NNSA’s security upgrade program  allows hospitals and medical facilities that contain high-risk radiological  materials to refuse security upgrades, even though they are initially paid  for by NNSA. As a result, 14 hospitals and medical facilities, with a  combined 41,000 curies of high-risk radiological material, have declined  to participate in the program, and several of these facilities are located in  or in close proximity to populated urban areas. NNSA has taken steps to  promote the program both by speaking at conferences and through other  outreach efforts. In addition, NRC and Agreement States have provided  support through promotion activities, such as NRC issuing a Regulatory  Issue Summary in 2010 that described the NNSA program. These are  positive steps, but there are still many hospitals that are not participating  in this important program. While we understand that some hospitals and  medical facilities may not participate in the program due to cost concerns,  the longer the security upgrades remain unimplemented, the greater the  risk that potentially dangerous radiological materials from these facilities  could be used as a terrorist weapon.
NRC has taken a risk-based approach to improve the security of  radiological sources at U.S. hospitals and medical facilities, but this  approach is not based on facility specific security risks and results in a  wide variety of security measures implemented by the medical facilities  we visited. The risk-based requirements do not go far enough as several  of the medical facilities we visited did not have adequate security  measures in place. NRC’s security controls are designed to improve  security but do not prescribe the specific measures that licensees should  take to secure their sources, such as specific direction on the use of  cameras, alarms, and other physical security measures. As a result,  these security controls, and the manner in which they are implemented,  have left some hospitals and medical facilities we visited vulnerable to  possible theft or sabotage of potentially dangerous radiological sources.  Furthermore, NRC’s pending regulations will require that licensees  choose security measures to implement from a menu of options based on  NRC’s earlier implementation guidance. Similar to the current security  requirements, the pending regulations do not specify which measures  best address the risks posed by hospital radiological sources, allowing  medical facilities to potentially choose the least disruptive option for their  operations or the most economical option regardless of the risk.
The limitations in NRC’s security controls are exacerbated because NRC  and Agreement State inspectors may not receive adequate training from  the agency on the security of high-risk radiological material at hospitals  and medical facilities. According to the views of several inspectors we  interviewed—the 5 days of training provided by NRC is not sufficient for  inspectors who typically have a health and safety background and limited  security experience. According to NRC, the training is one component for  qualification to perform independent security inspections. Other  components include: 1) qualification as a NRC health and safety  inspector, 2) observation of security inspections conducted by other  experienced security inspectors, and 3) conducting an inspection under  the direct oversight of a qualified security inspector. Nevertheless, the  inspectors may not be in the best position to make the most informed  decisions and judgments about the security of licensees’ radiological  materials. For example, we were told that an irradiator stored on a  wheeled pallet located down the hall from a loading dock had not raised  inspectors’ concerns during the facility’s most recent NRC security  inspection. Moreover, some hospital officials, including RSOs, rely on  inspectors for advice on how to implement NRC’s security controls.  However, these inspectors have minimal security training, and hospital  officials receive limited security guidance from NRC in how to implement  the security controls. Additional vulnerabilities are created because NRC  security controls do not require that medical facility officials and RSOs  have security experience. Without adequate security guidance, medical  facility officials, including RSOs, who may be responsible for  implementing NRC’s security controls may not have adequate knowledge  of securing equipment containing high-risk radiological sources. Finally,  ensuring that hospitals only grant unescorted access to trustworthy  individuals is critical to strengthening security, especially for securing  against an insider threat. However, the current background examination  process relies upon the judgment of hospital personnel, who may not  have adequate experience to make that determination. For this reason,  some hospital administrators told us that NRC should provide them with  additional support for conducting background checks and making  trustworthiness and reliability determinations as to which employees  would have unescorted access to equipment containing high-risk  radiological sources.
section_title: Recommendations for Executive Action
paragraphs: GAO is making four recommendations.
Because the security of radiological sources in hospitals and medical  facilities has national security implications, and many potentially  vulnerable medical facilities with high-risk sources have not received  security upgrades, we recommend that the Administrator of NNSA, in  consultation with the Chairman of NRC and Agreement State officials,  take the following action:  Increase outreach efforts to promote awareness of and participation in  NNSA’s security upgrade program. Special attention should be given  to medical facilities in urban areas or in close proximity to urban areas  that contain medical equipment with high-risk radiological sources.
In addition, to help address the security vulnerabilities at U.S. hospitals  and medical facilities that contain high-risk radiological materials, we  recommend that the Chairman of the Nuclear Regulatory Commission  take the following three actions:
Strengthen NRC security requirements by providing hospitals and  medical facilities with specific measures they must take to develop  and sustain a more effective security program, including specific  direction on the use of cameras, alarms, and other relevant physical  security measures.
Ensure that NRC and Agreement State inspectors receive more  comprehensive training to improve their security awareness and  ability to conduct related security inspections.
Supplement existing guidance for facility officials, including RSOs,  who may be responsible for implementing NRC’s security controls, in  how to adequately secure equipment containing high-risk radiological  sources and conduct trustworthiness and reliability determinations.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Chairman of NRC, the  Administrator of NNSA, the Secretary of Defense, and the Secretary of  Veterans Affairs. NRC provided written comments on the draft report,  which are presented in appendix III. In addition, NRC provided technical  comments, which we incorporated as appropriate. NNSA and VA did not  provide written comments but provided technical comments which we  incorporated as appropriate. DOD did not provide comments.
In its comments, NRC agreed with one of our four recommendations and  neither agreed nor disagreed with the three other recommendations.  Specifically, NRC agreed that the Administrator of NNSA, in consultation  with NRC and Agreement state officials, increase outreach efforts to  promote awareness of NNSA’s security upgrade program, with special  attention given to medical facilities in urban areas or in close proximity to  urban areas that contain medical equipment with high-risk radiological  sources.
NRC neither agreed nor disagreed with our other recommendations that it  (1) strengthen its security requirements by providing hospital and medical  facilities with specific measures they must take to develop and sustain a  more effective security program; (2) ensure that NRC and Agreement  State inspectors receive more comprehensive training to improve their  security awareness and ability to conduct related security inspections;  and (3) train facility officials who may be responsible for implementing  NRC security controls in how to adequately secure equipment and  conduct trustworthiness and reliability determinations. In its comments,  NRC provided additional information regarding each of these three  recommendations as follows:  Strengthening NRC security requirements. NRC stated that per its policy  it uses a multilayered risk informed performance-based approach for the  security of radioactive materials in the United States. It also stated in its  comments that the requirements were developed in consultation with the  Agreement States, in consideration of available intelligence reporting and  security assessments performed by experts inside and outside the NRC,  and are consistent with IAEA security guidelines and Executive Order  12866. We do not take issue with NRC’s statement that its performance- based approach is consistent with IAEA security guidelines and Executive  Order 12866. However, we note that a more prescriptive approach for the  security of radioactive materials, such as that we are recommending, is  also consistent with IAEA security guidelines. In fact, the guidelines point  out that a performance-based approach functions most effectively where  there are professional advisors with expertise to design and implement  the necessary security measures, a situation we found not to exist in  many of the medical facilities we visited. With respect to Executive Order  12866, we would also note that NRC states that the requirements of the  order do not apply to it. However, even if the order did apply to NRC, the  order itself provides only that “to the extent feasible” agencies should  adopt a performance-based approach. The order further directs agencies  to which the order applies to tailor their regulations to impose the least  burden possible “consistent with obtaining regulatory objectives.” We  found that NRC’s current performance-based approach does not  consistently ensure that NRC is meeting its objective of securing high-risk  radiological sources at the 26 selected hospitals and medical facilities we  visited.
NRC also stated that in its view, our recommendation is based on four  security issues identified in the report, two of which they identified as  violations of the existing requirements. NRC states that the failure of a  licensee to properly implement security controls established under a  performance based regulatory requirement is a compliance issue, and  does not mean that the intended control itself is inadequate. We  recognize in our draft report that NRC has adopted a risk-based approach  to radiological security and state that NRC’s security requirements are  non-prescriptive, which allows licensees to develop security programs  specifically tailored to their facilities. However, as we also noted in our  draft report, this risk-based approach is not based on security risks  specific to hospitals and medical facilities and results in a wide variety of  security measures implemented by the medical facilities we visited during  the course of our audit work. Consequently, we found that some of the  medical equipment in the facilities we visited was more vulnerable to  potential tampering or theft than that of other facilities, even though all the  facilities we visited had implemented NRC’s security controls and  undergone inspections by either NRC or Agreement State inspectors.  Furthermore, we are not basing our recommendation, as NRC states,  solely on our observations at 26 medical facilities. Rather, we are also  relying on the views of law enforcement personnel from states with  significant amounts of high-risk radiological material, who told us that  NRC’s security controls have an inherent weakness: the security controls  do not specify what the facility is protecting against and are not linked to a  design basis threat. In addition, NNSA has developed a specific program  to upgrade the physical security at hospitals and medical facilities in the  United States, which already meet NRC’s security controls. In our view, it  stands to reason that if NNSA has identified security vulnerabilities at 321  hospitals and medical facilities in the United Sates, and taken actions to  address them, then NRC’s existing security controls need to be  strengthened. This is not merely an issue of how licensees comply with  existing security regulations but involves both the security requirements  and their implementation. For these reasons, we continue to believe our  recommendation that NRC strengthen its security requirements is  appropriate.
Additional training for inspectors. NRC stated that its training course  provides instruction on a performance based methodology to evaluate  and assess the adequacy of a physical protection system to protect  against theft or sabotage of materials identified in NRC’s security  controls. NRC also stated that its one 5-day training course, in  combination with on the job training and other requirements, prepares  NRC and Agreement State inspectors to complete their required duties.  NRC stated that it will evaluate whether any additional training  enhancements are needed to its inspector qualification program based on  our recommendation, and it plans to review and revise the training  associated with the inspector qualification program in conjunction with  pending security regulation. We are encouraged that NRC will evaluate  whether any additional enhancements are needed to its inspector  qualification program in response to our recommendation. We believe  that NRC’s review of its training is necessary and should be completed as  quickly as possible, with an eye toward adopting a more comprehensive  inspector training program, as envisioned in our recommendation.
Training for hospital personnel. NRC recognizes our concern that there is  a need to improve the licensee’s knowledge of acceptable security  practices. According to NRC, as a regulator, it must maintain  independent, objective oversight of licensees and may not operate in a  consultative role. Therefore, NRC stated that it does not provide training  to licensees but provides regulatory guidance documents to aid facility  officials as they establish programs and specific controls to meet security  requirements, including implementing guidance and over 200 questions  and answers for the existing security requirements on its public website.  However, as we stated in the draft report, even with this guidance, facility  officials at 15 of the 26 hospitals and medical facilities we visited told us  that they have limited security experience and no training from NRC on  how to implement the security controls. In addition, the current  background examination process (trustworthiness and reliability) relies on  the judgment of hospital personnel, who may not have adequate  experience to make that determination. Therefore, we continue to believe  that medical facility officials would benefit from additional support from  NRC when implementing the security controls at their facilities. Because  NRC believes it cannot provide training to its licensees given its  independent role as a regulator, we are modifying the recommendation to  encourage NRC to supplement existing guidance and ensure that it is  widely disseminated, rather than provide specific training to facility  officials.
We are sending copies of this report to the Secretaries of the  Departments of Defense, Energy, and Veterans Affairs; as well as the  Administrator of the National Nuclear Security Administration; the  Chairman of the Nuclear Regulatory Commission; the appropriate  congressional committees; and other interested parties. In addition, the  report is available at no charge on the GAO website at http://gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202) 512-3841 or gaffiganm@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found  on the last page of this report. GAO staff who made key contributions to  this report are listed in appendix IV.
section_title: Appendix I: Scope and Methodology
paragraphs: We focused our review primarily on the Nuclear Regulatory Commission  (NRC) and the Department of Energy’s National Nuclear Security  Administration (NNSA) because they are the principal federal agencies  with responsibility for securing radiological material at hospitals and  medical facilities in the United States. We also performed work at the  Departments of Defense (DOD), Homeland Security (DHS), Justice  (DOJ), and Veterans Affairs (VA) because they are also involved in  securing radiological material. In addition, we interviewed experts in the  field of nuclear security, representatives from state government, and  safety and security personnel at hospitals and medical facilities to discuss  their views on how radiological material is secured at U.S. hospitals and  medical facilities. In August 2011, we attended the Organization of  Agreement States (OAS) annual meeting in Richmond, Virginia, where  we spoke to Agreement State representatives and attended sessions on  how states oversee the security of radiological material.
We visited hospitals and medical facilities in California, Maryland, New  York, Pennsylvania, Tennessee, Texas, Virginia, and Washington, D.C.  We selected these states and Washington D.C., on the basis of  geographic dispersion, curies of radiological sources, number of buildings  with high-risk radiological sources in the state, and number of sites with  NNSA security upgrades completed or in progress. Overall, these seven  states and Washington, D.C., contain over 12 million curies, or 43 percent  of all curies in U.S. hospitals and medical facilities. In addition, the seven  states and Washington, D.C., have 625 hospitals and medical buildings  with high-risk radiological sources, or 42 percent of all medical sites with  high-risk radiological material in the United States. As of March 1, 2012,  NNSA spent almost $56 million in the seven states and Washington,  D.C., on assessing sites and completing upgrades, or 53 percent of the  program’s total expenditure. During our review, we observed physical  security upgrades at 26 hospitals and medical facilities. These sites  included university and private hospitals, medical research facilities, blood  banks, and cancer treatment facilities. The 26 sites we visited are a non  generalizable sample, selected on the basis of the number of radiological  devices in the state and the total number of cumulative curies contained  in these devices in each state. In addition, we considered if the site had  undergone security upgrades funded by NNSA, and whether the site is  located in a large urban area. At each location, we interviewed facility  staff responsible for implementing procedures to secure radiological  sources. We also met with security personnel at each site, when  available, and spoke to officials with local law enforcement agencies  responsible for responding to security breaches. We also met with local  law enforcement personnel in Los Angeles County, New York City, and  Washington, D.C., to discuss coordination of security across large urban  areas.
We received electronic data from NNSA’s G-2 database, which  aggregates data from NRC’s National Source Tracking System (NSTS).  To determine the reliability of these data, we conducted electronic testing  and interviewed staff at NNSA and NRC about the reliability of these data.  We tested these data to ensure both their completeness and accuracy,  and determined that these data were sufficiently reliable to use in  selecting locations to visit and summarizing by state the total number of  buildings, number of buildings with completed security upgrades, and  total number of curies.
To examine how NRC’s regulations direct the security of high-risk  radiological material at U.S. hospitals and medical facilities, we reviewed  information and interviewed officials responsible for overseeing and  securing sources at NRC, NNSA, VA, DOD, DHS, and DOJ. We also  reviewed information from Agreement States and NRC regions and  interviewed officials at 20 of the 37 Agreement States and the three NRC  regional offices with responsibility for overseeing high-risk radiological  material. We spoke with officials about how Agreement States implement  the NRC security controls from the following 20 of the 37 Agreement  States: Alabama, Arizona, Arkansas, California, Colorado, Florida,  Kentucky, Maryland, Massachusetts, Mississippi, New Mexico, New York,  North Carolina, Pennsylvania, Rhode Island, Tennessee, Texas, Virginia,  Washington, and Wisconsin. We also spoke with officials in NRC Regions  I, III, and IV. We selected the Agreement State and NRC Regional Office  officials based on their experience with inspecting for the security of high- risk radiological sources across the United States.
To learn how NRC security requirement are implemented at the facilities,  we visited hospitals, medical facilities, and local law enforcement  agencies in the seven states and Washington, D.C., and interviewed  officials about NRC’s security requirements. To assess NRC’s new rule,  approved by the NRC on March 16, 2012, we reviewed the proposed  regulation and spoke with NRC officials about its implementation. To  determine the extent to which NRC and Agreement State inspectors  receive security training, we discussed training procedures with NRC  headquarters staff, reviewed training materials, and interviewed  inspectors in NRC regional offices and Agreement States about the  effectiveness of the training. To determine the sufficiency of staffing and  resources in the 37 Agreement States, we reviewed 40 Integrated  Materials Performance Evaluation Program (IMPEP) reports conducted  by NRC in 40 state programs or NRC regions from 2006 to 2011. We  analyzed the IMPEP reports to assess how Agreement States are  implementing NRC’s security controls.
To evaluate the extent to which NNSA has enhanced the security of high- risk radiological sources at U.S. hospitals and medical facilities and the  challenges they face, we analyzed information and interviewed NNSA  officials about the Domestic Material Protection program, which provides  voluntary upgrades to facilities with high-risk radiological material. We  analyzed NNSA data outlining the number of facilities that have received  upgrades or are in the process of receiving upgrades and visited facilities  that have received NNSA upgrades and security assessments in  California, New York, Pennsylvania, Tennessee, Texas, Virginia, and  Washington, D.C. To assess the voluntary nature of the program and  sustainability of the upgrades, we spoke with hospital and medical facility  officials about the program. To assess NNSA’s prioritization criteria and  determine how much money the agency has spent on security  enhancements, we gathered cost data from NNSA and contacted the  agency officials who oversee the program. We also analyzed NNSA  expenditure data to determine in which states NNSA has spent money on  upgrades and assessments since the program began. We conducted  electronic testing and discussed the reliability of these data with NNSA  officials, and we determined that they were sufficiently reliable to  summarize the total cost of the upgrades by state.
We conducted this performance audit from April 2011 to September 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: NRC Security Controls and Selected Pending Part 37 Regulations Changes (10 C.F.R. Part 37)
paragraphs: Appendix II: NRC Security Controls and  Selected Pending Part 37 Regulations Changes  (10 C.F.R. Part 37)
Relevant Increased Controls and Fingerprint Order  Access controls (IC 1)  Licensees shall control access to radioactive material at all  times and limit access only to trustworthy and reliable  individuals, approved by the licensee, who require access to  perform their duties.
The licensee shall allow only trustworthy and reliable  individuals, approved in writing by the licensee, to have  unescorted access to radioactive material quantities of  concern and devices. The licensee shall approve for  unescorted access only those individuals with job duties that  require access to such radioactive material and devices.  For individuals employed by the licensee for 3 years or  less, trustworthiness and reliability shall be determined, at  a minimum, by verifying employment history, education,  and personal references. The licensee shall also, to the  extent possible, obtain independent information to  corroborate that provided by the employee (i.e., seeking  references not supplied by the individual).  For individuals employed by the licensee for longer than 3  years, trustworthiness and reliability shall be determined,  at a minimum, by a review of the employees’ employment  history with the licensee.  In the case of a service provider’s employee, the licensee  shall obtain from the service provider written verification  attesting to or certifying the employee’s trustworthiness  and reliability from an NRC-required background check  before granting unescorted access. undergo or have undergone an FBI criminal history check.  Individuals who have been determined to be trustworthy and  reliable must undergo training in the licensee’s security program  and procedures.  The background check must cover the past 7 years (or since  18th birthday if shorter) for all employees, whether the individual  is a long-time employee or a new hire. Individuals must be  reinvestigated every 10 years.  Part 37 provides relief from record checks and background  investigations for certain categories of service provider  employees (emergency response personnel, commercial vehicle  drivers, and package handlers at transportation facilities).
Monitor and Response (IC 2)  Licensees shall have a documented program to monitor and  immediately detect, assess, and respond to unauthorized  access to radiological sources.
A written security plan, rather than a documented program is required.
The licensee shall respond immediately to any actual or  attempted theft, sabotage, or diversion of such radioactive  material or of the devices, including requesting assistance  from local law enforcement.  The licensee shall have a prearranged plan with their  Local Law Enforcement Agency for assistance in response  to an actual or attempted theft, sabotage, or diversion of  such radioactive material or of the devices consistent with  scope and timing with a potential vulnerability.  The licensee shall have a dependable means to transmit  information between, and among, the various components  used to detect and identify an unauthorized intrusion, to  inform the assessor, and to summon the appropriate  responder.  After initiating appropriate response to any actual or  attempted theft, sabotage, or diversion of radioactive  material or of the devices, the licensee shall, as promptly  as possible, notify NRC Operations Center. (i) A monitored intrusion detection system that is linked to an on- site or off-site central monitoring facility; or  (ii) Electronic devices for intrusion detection alarms that will alert  nearby facility personnel; or  (iii) A monitored video surveillance system; or  (iv) Direct visual surveillance by approved individuals located  within the security zone; or  (v) Direct visual surveillance by a licensee designated individual  located outside the security zone.  Licensees must assess any suspicious activity related to  possible theft, sabotage, or diversion of radioactive material and  notify NRC and local law enforcement as appropriate.  Licensees must implement a maintenance and testing program  to ensure that monitoring and detection equipment is functioning  properly.  Licensees are required to periodically (at least annually) review  the security program to ensure its continuing effectiveness.  Licensees must have a means to detect unauthorized removal of  the radioactive material from the security zone.
Individuals with unescorted access must be fingerprinted  and undergo a Federal Bureau of Investigations (FBI)  criminal history check.  The official responsible for determining whether individuals  are trustworthy and reliable must also undergo a  trustworthiness and reliability determination.
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: In addition to the contact name above, Gene Aloise (Director); Glen Levis  (Assistant Director); Jeffrey Barron; Alysia Davis; Will Horton; Karen  Keegan; Cheryl Peterson; Rebecca Shea; and Carol Hernstadt Shulman  made key contributions to this report.