oversight

Nuclear Nonproliferation: U.S. and International Assistance Efforts to Control Sealed Radioactive Sources Need Strengthening

Published by the Government Accountability Office on 2003-05-16.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             United States General Accounting Office

GAO          Report to the Ranking Minority Member,
             Subcommittee on Financial Management,
             the Budget, and International Security,
             Committee on Governmental Affairs, U.S.
             Senate
May 2003
             NUCLEAR
             NONPROLIFERATION
             U.S. and International
             Assistance Efforts to
             Control Sealed
             Radioactive Sources
             Need Strengthening




GAO-03-638
             a
                                               May 2003


                                               NUCLEAR NONPROLIFERATION

                                               U.S. and International Assistance Efforts
Highlights of GAO-03-638, a report to the      to Control Sealed Radioactive Sources
Ranking Minority Member, Subcommittee
on Financial Management, the Budget,           Need Strengthening
and International Security, Committee on
Governmental Affairs, U.S. Senate




Sealed radioactive sources,                    The precise number of sealed sources in use is unknown because many
radioactive material encapsulated              countries do not systematically account for them. However, nearly
in stainless steel or other metal, are         10 million sealed sources exist in the United States and the 49 countries
used worldwide in medicine,                    responding to a GAO survey. There is also limited information about the
industry, and research. These                  number of sealed sources that have been lost, stolen, or abandoned, but it is
sealed sources pose a threat to
national security because terrorists
                                               estimated to be in the thousands worldwide. Many of the most vulnerable
could use them to make “dirty                  sealed sources that could pose a security risk are located in the countries of
bombs.” GAO was asked to                       the former Soviet Union.
determine (1) the number of sealed
sources worldwide and how many                 All of the 49 countries that responded to GAO’s survey reported that they
have been reported lost, stolen, or            have established legislative or regulatory controls over sealed sources.
abandoned; (2) the controls, both              However, nuclear safety and security experts from DOE, the Departments of
legislative and regulatory, used by            State and Defense, the Nuclear Regulatory Commission (NRC), the
countries that possess sealed                  International Atomic Energy Agency, and the European Commission told
sources; and (3) the assistance                GAO that countries’ controls over sealed sources vary greatly and are
provided by the Department of                  weakest among less developed countries.
Energy (DOE) and other U.S.
federal agencies to strengthen
other countries’ control over sealed           In fiscal year 2002, DOE established a program focusing on improving the
sources and the extent to which                security of sealed sources in the former Soviet Union and has started to fund
these efforts are believed to be               security upgrades in Russia and other former Soviet countries. The
effectively implemented.                       Departments of Defense and State and NRC also have programs to help
                                               countries strengthen controls over sealed sources. DOE plans to expand its
                                               program to other countries and regions in 2003 and is developing a plan to
                                               guide its efforts. However, the department has not fully coordinated its
GAO recommends that the                        efforts with NRC and the Department of State to ensure that a
Secretary of Energy (1) develop a
comprehensive plan for DOE to
                                               governmentwide strategy is established. In addition, as of January 2003, the
guide its future efforts, (2) take the         majority of DOE’s program expenditures totaling $8.9 million were spent by
lead in developing a                           DOE’s national laboratories in the United States.
governmentwide plan to strengthen
controls over other countries’                 Abandoned Electrical Generators Containing Large Amounts of Radioactive Strontium-90 in
sealed sources; and (3) strengthen             a Former Soviet Union Country
efforts to increase program
expenditures in the countries
requiring assistance.

DOE agreed with our
recommendations to strengthen the
program but believes it has fully
coordinated with other federal
agencies. DOE’s contention is
contrary to other agencies’ views.

www.gao.gov/cgi-bin/getrpt?GAO-03-638.

To view the full report, including the scope
and methodology, click on the link above.
For more information, contact Gene Aloise at
(202) 512-3841 or aloisee@gao.gov.
Contents



Letter                                                                                                   1
                              Results in Brief                                                           2
                              Background                                                                 5
                              The Number of Sealed Sources in Use and Lost, Stolen, or
                                Abandoned Worldwide Is Unknown                                           7
                              Countries Have Established Legislative and Regulatory Controls
                                over Sealed Sources, but Adequacy of Controls Varies                    18
                              DOE Has a Program to Help Other Countries Secure Sealed Sources,
                                but Strengthened Coordination and Planning Are Needed                   23
                              Conclusions                                                               37
                              Recommendations for Executive Action                                      38
                              Agency Comments and Our Evaluation                                        39


Appendixes
                Appendix I:   Scope and Methodology                                                     42
               Appendix II:   Results of Survey of IAEA Member Countries                                44
              Appendix III:   List of Countries Surveyed by GAO and Responses                           61
               Appendix IV:   Information on Trafficking Incidents Involving Sealed
                              Sources                                                                   65
               Appendix V:    Information About Accidents Involving Sealed Sources                      74
              Appendix VI:    Information on Producers and Distributors of Radioactive
                              Material                                                                  83
             Appendix VII:    The Nuclear Regulatory Commission’s Policy on Exports of
                              Sealed Sources                                                            85
             Appendix VIII:   Results of the International Conference on the Security of
                              Radioactive Sources                                                       88
              Appendix IX:    Information on IAEA’s Revised Categorization of Radioactive
                              Sources                                                                   91
               Appendix X:    Countries Participating in IAEA’s Model Project Program                   93
              Appendix XI:    France’s System for Controlling Sealed Sources                            96
             Appendix XII:    Comments from the Department of Energy                                    98
             Appendix XIII:   Comments from the Department of State                                     99
             Appendix XIV:    Comments from the Nuclear Regulatory Commission                          102
              Appendix XV:    GAO Contacts and Staff Acknowledgments                                   104




                              Page i                                    GAO-03-638 Nuclear Nonproliferation
          Contents




Tables    Table 1: Regional Distribution of Sealed Sources in Countries
                    Responding to GAO’s Survey on the Security of
                    Radioactive Sealed Sources                                          8
          Table 2: Reported Lost or Stolen and Recovered Sealed Sources                12
          Table 3: Estimated Number of Radioisotope Thermoelectric
                    Generators in the Former Soviet Union                              15
          Table 4: Assistance to Improve Controls over Radioactive Sources
                    through January 31, 2003                                           31
          Table 5: Radiological Threat Reduction Program Expenditures by
                    DOE’s National Laboratories as of January 31, 2003                 35
          Table 6: Countries Surveyed and Surveys Received                             61
          Table 7: Significant Seizures of Illicitly Trafficked Sealed Sources
                    Since 1993                                                         69
          Table 8: Selected Accidents Involving Sealed Sources Since 1983              75
          Table 9: Estimated Costs Related to the Accident in Mexico                   76
          Table 10: Major Producers and Distributors of Radioactive Material
                    Used to Manufacture Sealed Sources                                 83
          Table 11: Countries Participating in IAEA’s Model Project
                    Program                                                            93


Figures   Figure 1: Radioisotope Thermoelectric Generators Manufactured
                    in the Former Soviet Union                                         14
          Figure 2: Abandoned Radioisotope Thermoelectric Generator in
                    Russia                                                             16
          Figure 3: Seed Irradiators Used in the Former Soviet Union                   17
          Figure 4: Moscow Radon Building Scheduled for DOE-Funded
                    Security Upgrades                                                  25
          Figure 5: DOE-Funded Physical Security Upgrades in the Former
                    Soviet Union                                                       26
          Figure 6: Reported International Trafficking Incidents Involving
                    Radioactive Sources, 1993-2002                                     66
          Figure 7: Illicit Trafficking Incidents by Type of Radioactive
                    Source, 1993-2002                                                  67
          Figure 8: Contaminated Radioactive Debris from Demolished
                    Residences in Goiania                                              78
          Figure 9: Location Where Sealed Sources Were Found, Lilo,
                    Georgia                                                            80




          Page ii                                      GAO-03-638 Nuclear Nonproliferation
Contents




Abbreviations

DOD     Department of Defense
DOE     Department of Energy
GAO     General Accounting Office
IAEA    International Atomic Energy Agency
MINATOM Russian Ministry of Atomic Energy
NRC     Nuclear Regulatory Commission
USAID   U.S. Agency for International Development

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 copyrighted materials separately from GAO’s product.




Page iii                                             GAO-03-638 Nuclear Nonproliferation
A
United States General Accounting Office
Washington, D.C. 20548



                                    May 16, 2003                                                                    Leter




                                    The Honorable Daniel K. Akaka
                                    Ranking Minority Member
                                    Subcommittee on Financial Management,
                                     the Budget, and International Security
                                    Committee on Governmental Affairs
                                    United States Senate

                                    Dear Senator Akaka:

                                    Since September 11, 2001, U.S. and international nuclear safety and
                                    security experts have raised concerns that terrorists could obtain
                                    radioactive material used in medicine, research, agriculture, and industry
                                    to construct a radiological dispersion device, or “dirty bomb.” This
                                    radioactive material is encapsulated, or sealed, in metal, such as stainless
                                    steel, titanium, or platinum, to prevent its dispersal and is commonly called
                                    a sealed radioactive source. These sealed sources are used throughout the
                                    United States and other countries in equipment designed to, among other
                                    things, diagnose and treat illnesses, preserve food, detect flaws and other
                                    failures in pipeline welds, and determine the moisture content of soil.
                                    Depending on their use, sealed sources contain different types of
                                    radioactive material, such as strontium-90, cobalt-60, cesium-137,
                                    plutonium-238, and plutonium-239. If these sealed sources fell into the
                                    hands of terrorists, they could use them to produce a simple and crude, but
                                    potentially dangerous, weapon by packaging explosives, such as dynamite,
                                    with the radioactive material, which would be dispersed when the bomb
                                    went off. Depending on the type, amount, and form (powder or solid), the
                                    dispersed radioactive material could cause radiation sickness for people
                                    nearby and produce serious economic costs and psychological and social
                                    disruption associated with the evacuation and subsequent cleanup of the
                                    contaminated area.




                                    Page 1                                       GAO-03-638 Nuclear Nonproliferation
                   Given the concerns about the security of sealed sources worldwide, you
                   asked us to determine, to the extent possible (1) the number of sealed
                   sources worldwide and how many are reported lost, stolen, or abandoned;
                   (2) the controls, both legislative and regulatory, used by countries that
                   possess sealed sources; and (3) the assistance provided by the Department
                   of Energy (DOE) and other U.S. federal agencies to strengthen other
                   countries’ control over sealed sources and the extent to which these efforts
                   are believed to be effectively implemented. To address these objectives,
                   we distributed a survey to 127 International Atomic Energy Agency (IAEA)1
                   member states to determine, among other things, how countries control
                   sealed sources. Appendix I presents our scope and methodology,
                   appendix II presents the results of the survey, and appendix III contains a
                   list of the countries we sent the survey to, including those that responded
                   to it. We also met with or had discussions with officials from several
                   countries to learn more about how they regulate and control sealed sources
                   and met with officials from international organizations, such as IAEA and
                   the European Commission,2 to obtain their views on the problem of
                   uncontrolled sealed sources. A forthcoming report will address controls
                   over sealed sources in the United States. We conducted our review from
                   May 2002 through May 2003 in accordance with generally accepted
                   government auditing standards.



Results in Brief   The precise number of sealed sources that is in use today or that has been
                   lost, stolen, or abandoned is unknown because many countries do not
                   systematically account for them. Some estimates are available, however.
                   For example, about 2 million licensed sealed sources are currently being
                   used in the United States, according to the Nuclear Regulatory Commission
                   (NRC), and the 49 countries that responded to our survey reported that
                   7.8 million sealed sources are in use. Limited information exists about the
                   number of sealed sources that has been lost, stolen, or abandoned—
                   commonly referred to as “orphan sources”—but it is estimated to be in the
                   thousands worldwide. In the United States, about 250 sealed sources or


                   1
                    Affiliated with the United Nations, IAEA’s aims are to promote the peaceful use of nuclear
                   energy and to verify that nuclear material under its supervision or control is not used to
                   further any military purpose.
                   2
                    As the European Union’s executive body, the European Commission has three main tasks:
                   to serve as the sole initiator of policy, to act as guardian of the European Union treaties by
                   investigating treaty breaches, and to supervise the implementation of European Union law
                   in the member states.




                   Page 2                                                  GAO-03-638 Nuclear Nonproliferation
devices containing sealed sources are reported lost or stolen annually, but
the majority of these sources are recovered. The countries that responded
to our survey said that a total of 612 sealed sources had been reported lost
or stolen since 1995, 254 of which had not been recovered. U.S. and
international nuclear safety and security experts told us that the largest
number of lost, stolen, or abandoned sealed sources is located in the
former Soviet Union. Of particular concern are as many as 12 electrical
generators that were abandoned in the Republic of Georgia. These
generators are powered by high activity levels (ranging from 40,000 to
150,000 curies) of strontium-90—a destructive radioactive material.
Recently, the United States and other countries—and IAEA—located and
secured most of these generators believed to exist in Georgia. However,
more than 1,000 additional generators that are not adequately protected
and pose a significant security risk are spread throughout the former Soviet
Union.

All of the countries that responded to our survey reported that they have
established legislative or regulatory controls over sealed sources.
However, nuclear safety and security experts from DOE, the Department of
State, the Department of Defense (DOD), NRC, IAEA, and the European
Commission told us that controls on radioactive sources vary greatly
between countries and focus primarily on protecting public health and
safety rather than on securing sealed sources from theft or destructive use.
These experts also told us that controls over sealed sources are weakest
among less developed countries. For example, representatives from
several countries of the former Soviet Union told us that their national
systems of control need improvement, particularly regarding inventorying,
consolidating and securing, and transporting sealed sources. Because of
concerns about many countries’ inability to control radioactive materials—
IAEA has estimated that as many as 110 countries worldwide do not have
adequate controls over sealed sources—IAEA established a program to
help 88 countries enhance their regulatory infrastructures. Although the
program has helped countries improve their regulatory controls, many
participating countries continue to have numerous regulatory deficiencies.
In the absence of regulatory controls, radioactive sources have been
inadequately protected or secured; little or no attention has been paid to
the export or import controls of sources; and basic record keeping has
been lacking. Finally, officials from the Department of State, the European
Commission, and IAEA told us that France has implemented a system for
controlling sealed sources that could serve as a model for other countries.
France’s system requires distributors of sealed sources to assume financial
responsibility for recovering and disposing of them.



Page 3                                       GAO-03-638 Nuclear Nonproliferation
DOE and other U.S. agencies have funded programs to strengthen controls
over sealed sources in other countries. DOE, which has the largest
program, received about $37 million since fiscal year 2002 to initiate a
program to assist other countries in controlling their sealed sources.
According to DOE officials, the program is expected to receive an
additional $22 million in supplemental appropriations in fiscal year 2003,
including $5 million for securing nuclear material in Iraq. DOE established
a program focusing on improving the security of sites containing sealed
sources in the former Soviet Union because that is where DOE believed the
greatest threat exists. DOE has begun funding site assessments and
security upgrades at several locations in Russia, Uzbekistan, the Republic
of Georgia, Moldova, and Tajikistan. In Russia, for example, DOE has
focused on securing sources at several large nuclear waste repositories
scattered around the country. Furthermore, the Secretary of Energy
recently announced that the program will expand to other regions of the
world. Other U.S. federal agencies have begun efforts to help countries
strengthen controls over sealed sources as well. Since fiscal year 2001,
DOD has obligated about $1.7 million to inventory, secure, and dispose of
sealed sources in Kazakhstan. In fiscal year 2002, the State Department
received appropriations totaling about $1.2 million primarily to support
IAEA projects on the safety and security of sealed sources. Finally, the
NRC received about $250,000 from the U.S. Agency for International
Development (USAID) to help Armenia develop a registry of sealed sources
and improve Armenia’s legislative and regulatory framework for controlling
sources.

DOE’s initial efforts to secure sealed sources have lacked adequate
planning and coordination, and the majority of the program funds were
spent in the United States rather than in the countries of the former Soviet
Union. DOE is in the process of developing a plan to guide its efforts.
However, DOE officials told us that more detailed planning and analysis
will be needed to, among other things, (1) determine which countries
outside the former Soviet Union present the greatest security risk and most
urgently require assistance, (2) identify future funding requirements, and
(3) develop performance measures to gauge program success. In addition,
Department of State and NRC officials told us that DOE has not fully
coordinated its efforts with their agencies. In their view, DOE needs their
input to ensure that a comprehensive governmentwide strategy is taken to,
among other things, leverage program resources, maximize available
expertise, avoid possible duplication of effort, and help ensure future
program success. DOE has not systematically undertaken the kind of
comprehensive planning that would foster better coordination with the



Page 4                                       GAO-03-638 Nuclear Nonproliferation
             other agencies and could also lead to better coordination with other
             countries’ nuclear organizations. For example, officials from Russia’s
             nuclear regulatory organization, Gosatomnadzor, told us that DOE did not
             adequately consult them when it initially selected sites in Russia for
             security improvements. Regarding DOE’s effort to secure sealed sources in
             the former Soviet Union, as of January 31, 2003, DOE had spent about
             $8.9 million, including $3 million transferred to IAEA. Of the remaining
             $5.9 million in expenditures, 93 percent was spent in the United States by
             DOE’s national laboratories. DOE officials told us that the program is still
             in its early stages and that the objective of the program is to place a
             significant percentage of funds in the recipient countries to improve
             security.

             This report makes recommendations designed to improve the management
             of DOE’s efforts to help improve controls over sealed sources. Specifically,
             it recommends that DOE (1) develop a comprehensive plan that identifies
             those countries that most urgently require assistance, establish realistic
             time frames and resources necessary to accomplish program goals, and
             establish meaningful performance measures; (2) take the lead in
             developing a governmentwide plan designed to, among other things,
             improve interagency coordination; and (3) strengthen its efforts to increase
             program expenditures in the countries requiring assistance.



Background   Sealed sources are used throughout the world for a variety of peaceful
             purposes. Until the 1950s, only naturally occurring radioactive materials,
             such as radium-226, were available to be used in sealed sources. Since
             then, sealed sources containing radioactive material produced artificially in
             nuclear reactors and accelerators have become widely available, including
             cobalt-60, strontium-90, cesium-137, and iridium-192. Radioactive material
             can be found in various forms. For example, cobalt-60 is a metal, while the
             cesium-137 in many sealed sources is in a powdery form closely resembling
             talc. Radioactive materials are measured by their level of activity. The
             greater the activity level—measured in units called curies3—the more
             radiation emitted, which increases the potential risk to public health and
             safety if improperly used or controlled. The intensity of radioactive


             3
              The 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 1010 becquerels.




             Page 5                                              GAO-03-638 Nuclear Nonproliferation
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.

Usually, radioactive material with high radioactivity is placed in a sealed
container to prevent leakage of the material itself. Because of the varied
characteristics of the radioactive material—physical structure (metal,
ceramic, or powder), activity level, half-life, and type of radiation emitted, 4
some materials pose a greater risk to people, property, and the
environment than others. According to IAEA, the level of protection
provided to users of the radioactive material should be commensurate with
the safety and security risks that it presents if improperly used. For
example, radioactive materials used for certain diagnostic purposes have
low levels of activity and do not present a significant safety or security risk.
However, powerful sealed sources, such as those used in radiotherapy
(cancer treatment) that use cobalt-60, cesium-137, or iridium-192, could
pose a greater threat to the public and the environment and would also
pose a potentially more significant security risk, particularly if acquired to
produce a dirty bomb.

The small size, portability, and potential value of sealed sources make them
vulnerable to misuse, improper disposal, and theft. According to IAEA,
illicit trafficking in or smuggling of nuclear material, including sealed
sources, has increased worldwide in recent years: IAEA reported 272 cases
of illicit trafficking in these sources from 1993 to the end of 2002. (See
app. IV for more information about illicit trafficking incidents.) While no
dirty bombs have been detonated, in the mid-1990s Chechen separatists
placed a canister containing cesium-137 in a Moscow park. Although the
device was not detonated and no radioactive material was dispersed, the
incident demonstrated that terrorists have the capability and willingness to
use sealed sources as weapons of terror.

U.S. and international experts have noted that some accidents involving
sealed sources can provide a measure of understanding of what the


4
 Radioactive material emits alpha and beta particles, gamma rays, neutrons, or a
combination thereof. For example, americium-241 emits alpha particles and gamma rays;
cobalt-60 emits beta particles and gamma rays; and strontium-90 emits only beta particles.
Alpha particles are not a hazard outside of the body; beta particles can be more penetrating
and cause radiation damage. Both, however, are generally most hazardous when ingested or
inhaled. Gamma rays are an external hazard because they can easily pass through clothing
and skin. Neutron particles are less common but can also cause damage.




Page 6                                                GAO-03-638 Nuclear Nonproliferation
                              possible impacts of a dirty bomb might be. In 1987, an accident involving a
                              cesium-137 sealed source in Brazil killed four people, injured many more,
                              and caused about $36 million in damages to the local economy. This
                              accident had such an enormous psychological impact on the local
                              population that the atomic symbol was added to the region’s flag as a
                              lasting reminder of the accident’s consequences. Appendix V contains
                              more information about worldwide accidents involving sealed sources.



The Number of Sealed          The precise number of sealed sources that is in use worldwide is unknown
                              because many countries do not systematically account for them. The lack
Sources in Use and            of a full accounting of sealed sources makes it equally difficult to determine
Lost, Stolen, or              the number that has been lost, stolen, or abandoned—referred to as
                              “orphan sources.” Orphan sources, which are estimated to number in the
Abandoned Worldwide           thousands worldwide, are considered by U.S. and international officials to
Is Unknown                    pose significant health, safety, and security risks because they are outside
                              of regulatory control. According to U.S. and international safety and
                              security experts, one of the most urgent problems is locating and securing
                              orphan sources in the former Soviet Union because they pose a significant
                              security risk.



The Number of Sealed          The number of sealed sources in use worldwide is unknown, but some
Sources in Use Worldwide Is   estimates are available. According to IAEA, millions of sealed radioactive
                              sources have been distributed worldwide over the past 50 years.
Unknown Because
                              Approximately 2 million licensed sealed sources are in use in the United
Countries Do Not              States, according to the NRC. In addition, according to the European
Systematically Account for    Commission, approximately 500,000 sealed sources have been supplied to
Them                          operators in the 15 member states of the European Union, of which about
                              110,000 are currently in use. The European Commission also estimated in
                              1999 that approximately 840,000 sealed sources exist in Russia, although
                              Russian officials believe the total number is significantly higher.

                              The 49 countries that responded to our survey reported a total of about
                              7.8 million sealed sources that are in use within their countries. These
                              sealed sources are used in various applications, such as industrial
                              radiography and therapeutic medicine. Table 1 summarizes the responses
                              received from the countries surveyed regarding the number of sealed
                              sources in use and their major applications.




                              Page 7                                        GAO-03-638 Nuclear Nonproliferation
Table 1: Regional Distribution of Sealed Sources in Countries Responding to GAO’s
Survey on the Security of Radioactive Sealed Sources

                               Number of sealed
Region                           sources in use        Major applications
Africa                                           834   Smoke detectors, academic/research,
                                                       and fixed gauges
Asia                                         18,420    Fixed gauges, analytical instruments,
                                                       and academic/research
Europe                                   4,866,024     Smoke detectors, fixed gauges, and
                                                       academic/research
Former Soviet Union                          20,344    Smoke detectors, irradiation, and
                                                       academic/research
Middle East                                   6,545    Medical-diagnostic,
                                                       academic/research, and portable
                                                       gauges
North Americaa and                       2,887,025     Smoke detectors, fixed gauges, and
Central America                                        academic/research
South America                                 2,836    Smoke detectors, fixed gauges, and
                                                       medical-diagnostic
South Pacific                                 1,854    Industrial radiography, smoke
                                                       detectors, and irradiation
Total                                    7,803,882
Source: GAO.
a
The United States was not surveyed for this report.


Several factors contribute to the lack of comprehensive information about
the number of sealed sources worldwide. According to IAEA, many
countries do not maintain accurate or complete inventories of sealed
sources in use or registries of users of sources. In response to our survey,
28 of the 49 countries said they had an inventory of sealed sources. In
addition, 17 countries said they were in the process of developing an
inventory. However, several countries that reported they had inventories
indicated that the number of sources was estimated rather than actual. A
few countries, including a European nation, indicated that they did not
have the resources necessary to develop a national registry of sources and
users.

An additional factor contributing to countries’ limited or incomplete
inventories is that sealed sources have been imported and exported by
distributors and governments without consistent monitoring or tracking by
the suppliers, the recipients of the sources, or the appropriate regulatory




Page 8                                                    GAO-03-638 Nuclear Nonproliferation
authority. Appendix VI provides information on the major producers of
sealed sources worldwide.

The Chairman of NRC noted in March 2003 that international commerce in
these sources is extensive and that existing controls on imports and
exports are minimal. For example, most U.S.-origin sealed sources are
exported under a general license.5 This means that in most instances,
sealed sources are exported without NRC knowing the type, amount, or
activity level of the sources, or their destination. (See app. VII for more
information about NRC’s export regulations.)

Sealed sources have also been distributed worldwide by a variety of means
other than commercial trade without adequate monitoring and oversight.
As a result, the sealed sources have not always been properly accounted
for and accurately inventoried. For example, sealed sources have been
(1) distributed by corporations working in developing countries without
formal clearance from or approval by the recipient country’s regulatory
authority, (2) donated by medical practitioners and nonprofit
organizations, and (3) provided through international technical
cooperation programs. IAEA has reported that international
corporations—such as oil companies—have brought sealed sources used
in oil exploration into developing countries. In some cases, there was no
competent authority in the country to register or license the sealed
sources, and existing national rules were regarded as too complicated or
difficult for the corporations to follow. One African country reported in
response to our survey that its inventory of sealed sources was incomplete
because foreign construction companies had not notified the country’s
regulatory authority when it imported sealed sources.

According to IAEA, medical practitioners have brought sealed sources into
developing countries for the purpose of establishing health clinics and
hospitals and a number of sources were not properly accounted for. IAEA
reported that hospitals in many developed countries donated large
amounts of surplus radium-226 to hospitals in developing countries in the
1960s. One African country responding to our survey noted that according
to old records, radium had been imported into the country but could not be

5
 Under NRC regulations sealed sources may not be exported to certain countries and may
only be exported to certain other countries in limited quantities. Sealed sources may not be
exported to Cuba, Iran, Iraq, Libya, North Korea, and Sudan. 10 C.F.R. § 110.28. Sealed
sources may be exported only in limited quantities to Afghanistan, Andorra, Angola, Burma,
Djibouti, India, Israel, Oman, Pakistan, and Syria. 10 C.F.R.§ 110.29.




Page 9                                                GAO-03-638 Nuclear Nonproliferation
located. Nonprofit organizations have also provided medical equipment
using sealed sources to foreign countries. For example, the American
International Health Alliance, operating under a series of cooperative
agreements with USAID and DOE, has donated medical supplies,
pharmaceuticals, and equipment, including those containing sealed
sources, to countries in the former Soviet Union and Central and Eastern
Europe since 1992.6 According to an official from the American
International Health Alliance, DOD also donated medical equipment
containing sealed sources from field facilities to several countries in the
former Soviet Union under the auspices of Operation Provide Hope. Since
1992, over 500 airlift deliveries by DOD to Armenia, Azerbaijan, Belarus,
Georgia, Kazakhstan, Ukraine, and Uzbekistan occurred, but the exact
number of sealed source devices donated is unknown.

IAEA has supplied sealed sources to many countries through its technical
cooperation program.7 In 1991, IAEA estimated that it had provided many
developing countries with 565 sources since 1957. IAEA officials told us
that IAEA had provided developing member states with over 1,000 devices
containing sealed sources since 1996. Most of these sealed sources are not
considered a security risk by IAEA because of their low radioactivity.
However, officials did note that about 125 of the 1,000 devices contained
sources that could pose security risks if acquired by terrorists. These
include (1) teletherapy machines with cobalt-60 sources of activity
between 5,000 and 7,000 curies, (2) brachytherapy machines with cesium-
137 sources of activity between 0.5 and 1 curie and iridium-192 sources of
10 curies, (3) irradiators with cobalt-60 sources with activity in the range of
12,000 to 200,000 curies, and (4) calibrators with activity around 4,000
curies. IAEA officials said that they were uncertain, however, the extent to
which the sealed sources have been included in countries’ inventories.

While it is the responsibility of each country—and not IAEA—to maintain
accurate inventories of the sources, IAEA has encouraged many of its
member states to establish and/or strengthen their radiation and waste

6
 The American International Health Alliance and its partners identify the health needs of
local populations, develop strategies for meeting those needs, and implement programs and
services to help local populations attain their goals. The equipment supplements voluntary
and in-kind commitments of individual health care professionals, partner hospitals, and
universities.
7
 IAEA’s technical cooperation program is designed to provide its member states with
technical assistance by providing equipment, expert services, and training that support the
upgrading and establishment of nuclear techniques and facilities.




Page 10                                               GAO-03-638 Nuclear Nonproliferation
                             safety infrastructures via the model project program. In addition, IAEA
                             policy does not allow for the approval of any technical cooperation
                             projects involving the use of significant sealed sources unless the member
                             state in question has, among other things, an effective regulatory
                             framework that includes a system of notification, authorization, and
                             control of sealed sources together with an inventory of sources. IAEA’s
                             model project program is discussed on pages 22 and 23 of this report.

                             DOE has provided countries with sealed sources under the Atoms for
                             Peace Program. According to a March 2002 DOE Inspector General report,
                             Accounting for Sealed Sources of Nuclear Material Provided to Foreign
                             Countries, DOE could not fully account for sealed sources loaned to
                             foreign countries and no longer maintained an accounting and tracking
                             system for sealed sources. The report noted that DOE and its predecessor
                             agencies provided 33 countries, including Iran, Pakistan, India, Malaysia,
                             and Vietnam, with 536 sealed sources, which contained plutonium, from
                             the 1950s through the 1970s. Initially, these materials were loaned to
                             foreign facilities, and the U.S. government maintained ownership.
                             However, in the 1960s, the U.S. government began transferring ownership
                             through direct sale or donation, but it still retained title to much of the
                             sealed sources provided to foreign entities. The report concluded that
                             (1) the oversight of sealed sources was inadequate and that inaccurate
                             inventory records limit DOE’s ability to protect nuclear materials from loss,
                             theft, or other diversion, and (2) DOE should work with IAEA to establish
                             adequate regulatory oversight of sealed sources in foreign countries. In its
                             response to the report, DOE stated that it is not the current policy of the
                             U.S. government to track sealed sources once they are in the control of
                             foreign entities and that to track loaned sealed sources would require a
                             change in policy and international agreements.



Limited Information Exists   Because many countries cannot account for their sealed sources, there is
about the Number of Lost,    limited information on the number of sealed sources that are lost, stolen, or
                             abandoned—referred to as “orphan sources.” According to the Director
Stolen, or Abandoned
                             General of IAEA, orphan sources are a widespread phenomenon, and 34 of
Sealed Sources               the 49 countries responding to our survey indicated that orphan sources
                             pose problems in their country. In the European Union, up to 70 sealed
                             sources are lost among its member states annually. According to NRC,
                             about 250 sealed sources or devices are lost or stolen in the United States
                             annually, but the majority of the sources have been recovered. NRC said
                             that the European Union does not report sources as being lost unless they
                             are at a certain activity level that exceeds the NRC threshold for tracking



                             Page 11                                      GAO-03-638 Nuclear Nonproliferation
purposes. As a result, NRC typically reports a greater number of lost sealed
sources than the European Union does.

The problem of orphan sources is most significant in the countries of the
former Soviet Union, where the collapse of the centralized Soviet
government structure over a decade ago led to a loss of records and
regulatory oversight over sealed sources. According to Russia’s nuclear
regulatory agency, Gosatomnadzor, 51 sealed sources were reported lost in
2002 and 245 were lost in 2000. No information was made available to us
for 2001. In the Republic of Georgia, over 280 orphan sources have been
recovered since the mid-1990s. Survey respondents reported that 612
sources had been lost or stolen since 1995. Of the 612 reported orphan
sources, 254 had not yet been recovered. Table 2 summarizes the number
of lost, stolen, and recovered sources reported.



Table 2: Reported Lost or Stolen and Recovered Sealed Sources

                                                Reported lost or stolen    Recovered sealed
Region                                                 sealed sources              sources
Africa                                                               8                      0
Asia                                                                93                     11
Europe                                                             298                    213
Former Soviet Union                                                 35                     14
Middle East                                                         41                     24
                   a
North America and Central
America                                                             72                     65
South America                                                       21                     10
South Pacific                                                       44                     21
Total                                                              612                    358
Source: GAO.
a
    The United States was not included in this survey.


Thirty-five of the 49 countries we surveyed indicated that they had an
organized process to search for orphan sources, and several of these
countries listed one or more organizations that are responsible for
removing the sources once they have been found. However, the remaining
14 countries, spread across different regions, reported that they did not
have a similar process to search for orphaned sources. Four of the 14
countries were located in Africa.




Page 12                                                    GAO-03-638 Nuclear Nonproliferation
                              Six countries indicated that there were disincentives to finding orphaned
                              sources. In particular, they noted that an individual who reports finding a
                              source might be held responsible for paying for its disposal. Russian
                              officials told us that facilities possessing sealed sources that are no longer
                              used are responsible for disposal costs. The disposal fees are very high
                              and, as a result, the users are reluctant to notify authorities about them and
                              frequently opt to dispose of them illegally.



Certain Lost, Stolen, or      According to U.S. and international safety and security experts, among the
Abandoned Sealed Sources      most urgent problems are the security risks posed by the approximately
                              1,000 radioisotope thermoelectric generators located in the former Soviet
Pose a Significant Security
                              Union. These generators were designed to provide electric power and are
Risk                          ideally suited for remote locations to power navigational facilities, such as
                              lighthouses, radio beacons, and meteorological stations.8 Each has activity
                              levels ranging from 40,000 to 150,000 curies of strontium-90—similar to the
                              amount of strontium-90 released from the Chernobyl accident in 1986.
                              These generators pose a security risk because they may not be adequately
                              protected or secured. An international effort was initiated about 2 years
                              ago to recover and secure these generators in remote locations in the
                              Republic of Georgia. Although the exact number of generators in Georgia
                              is unknown, IAEA and Georgian officials told us that at least six generators
                              have been recovered.




                              8
                               The United States had also deployed a small number of radioistope thermoelectric
                              generators in Alaska.




                              Page 13                                             GAO-03-638 Nuclear Nonproliferation
Figure 1: Radioisotope Thermoelectric Generators Manufactured in the Former
Soviet Union




We met with the Russian organization that developed the radioisotope
thermoelectric generators—the Russian National Technical Physics and
Automation Research Institute. Institute officials told us that the
generators pose a serious security and safety threat and should all be taken
out of service. They noted that the units have a design service life of 10 to
15 years and that no repair or maintenance has been done on any of these
units since 1991. However, Russian Ministry of Atomic Energy (MINATOM)
officials said that the generators are technically sound and should not be
completely removed from service without adequate replacement power.
MINATOM officials said they are considering extending the life of the
generators in order to keep them in service significantly longer than
originally planned. Table 3 shows the estimated number of radioisotope
thermoelectric generators located in the countries of the former Soviet
Union.




Page 14                                        GAO-03-638 Nuclear Nonproliferation
Table 3: Estimated Number of Radioisotope Thermoelectric Generators in the
Former Soviet Union


                                                                                   Radioisotope thermoelectric
Country                                                                                             generators
Armenia                                                                                                     1
Azerbaijan                                                                                                  1
Belarus                                                                                                     3
Georgia                                                                                                    12a
Kazakhstan                                                                                                  3
Russia                                                                                                   998b
Tajikistan                                                                                                  1
Ukraine                                                                                                    12
Total                                                                                                   1,031
Sources: NRC, MINATOM, and Russian National Technical Physics Automation Research Institute.
a
The estimated number of generators in Georgia ranges from 6 to 12.
b
Includes 829 that are operational and 169 that are in storage.


There have been numerous attempts to steal the sealed sources from these
generators. For example, in recent years there have been six attempts to
disassemble the generators in Kazakhstan and a number of similar events
in Georgia and Russia. Some of the strontium-90 sealed sources from the
generators have been found in residential areas. In a few instances, people
who have stolen the sealed sources have used them for heating and
cooking, and officials have speculated that the metal shielding might have
been used to make bullets. In 2001, three woodsmen in Georgia who found
the strontium-90 sealed source from an abandoned and dismantled
generator used it as a heat source and suffered severe radiation burns.
IAEA and DOE officials told us that other devices containing sealed
sources, such as seed irradiators that were used in the former Soviet Union,
pose significant security risks. Seed irradiators were mounted on trucks
and used to irradiate seeds in order to kill fungus and inhibit germination.
According to IAEA and DOE, each irradiator has activity levels of over
1,000 curies of cesium-137 in powdery form (cesium chloride).




Page 15                                                                   GAO-03-638 Nuclear Nonproliferation
Figure 2: Abandoned Radioisotope Thermoelectric Generator in Russia




Page 16                                       GAO-03-638 Nuclear Nonproliferation
Figure 3: Seed Irradiators Used in the Former Soviet Union




IAEA’s Director of the Division of Radiation and Waste Safety told us that
no one knows the total number of orphan sources or their location in the
former Soviet Union. IAEA is continuously obtaining new information
about previously unknown devices using sealed sources. This makes it
extremely difficult for the agency to develop strategies to locate and
recover these sources in a systematic way. The Director also told us that
the problem of orphan sources is not unique to the former Soviet Union and
that similar problems exist in other parts of the world.




Page 17                                         GAO-03-638 Nuclear Nonproliferation
Countries Have             All of the countries responding to our survey said they have established
                           legislative or regulatory controls over sealed sources. However, U.S. and
Established Legislative    international nuclear safety and security experts told us that controls
and Regulatory             placed on radioactive sources vary greatly between countries and focus
                           primarily on protecting public health and safety and not on securing sealed
Controls over Sealed       sources from theft or destructive use. According to IAEA, as many as 110
Sources, but Adequacy      countries worldwide do not have adequate controls over sealed sources
of Controls Varies         and the agency has established a program to help 88 countries upgrade
                           their regulatory infrastructures.



Countries Responding to    All of the countries that responded to our survey reported that they have
Our Survey Reported That   established legislative or regulatory controls over sealed sources. The
                           countries that responded to our survey identified various controls over
They Have Established      sealed sources, including (1) licensing and inspection; (2) tracking the
Controls over Sealed       import and export of sources; (3) maintaining national registries of
Sources                    sources’ users; (4) maintaining national inventories of sources;
                           (5) searching for and recovering lost, stolen, or abandoned sources;
                           (6) securing sources; and (7) regulating their safe transport. According to
                           IAEA, controls over sealed sources are based on countries’ development of
                           a framework of laws and regulations. Twenty-five of the 49 countries
                           reported that they had established a strong legislative framework to control
                           sealed sources and most of these same countries indicated that they had a
                           strong regulatory framework as well. Several countries characterized their
                           legislative or regulatory framework as weak. The countries that reported
                           having a strong legislative or regulatory framework were spread across
                           many regions, including the former Soviet Union, Europe, Africa, and the
                           South Pacific. Countries reporting that they had weak or nonexistent
                           regulatory frameworks were located primarily in the former Soviet Union,
                           the Middle East, Europe, Africa, and South America.




                           Page 18                                      GAO-03-638 Nuclear Nonproliferation
Countries reported using various guidelines to develop their laws or
regulations that serve as the basis for controls over sealed sources. Forty-
four of the 49 countries said they used either one or both IAEA guidelines—
(1) the International Basic Safety Standards for Protection against Ionizing
Radiation and for the Safety of Radiation Sources and (2) the Code of
Conduct on the Safety and Security of Radioactive Sources.9 Twelve of the
countries responding to our survey indicated that they base their regulatory
controls, in part, on European Union regulations. European Commission
officials told us that efforts are under way to strengthen controls over
sealed sources, including harmonizing measures among member states for
the recovery of orphan sources. These efforts began prior to September 11,
2001, in response to accidents where orphan sources were melted with
scrap metal, resulting in significant economic damages. In 2002, the
commission adopted a proposed directive to improve controls over sealed
sources that emit large amounts of radiation. The proposal urges that
necessary measures be taken to protect public health from orphan source
exposure. More recently, a commission committee proposed that users of
radioactive sources in the European Union be charged a refundable deposit
before acquiring sealed sources.

All of the countries responding to our survey identified one or more
organizations responsible for regulating sealed sources. Forty-five of the
49 countries reported that regulatory organizations inspect facilities where
sealed sources are stored or in use. Regarding enforcement, three
countries failed to list any actions that inspectors could take to ensure
compliance with laws and regulations. Many of the countries identified
more than one enforcement mechanism available, including levying fines,
suspending or terminating licenses, and closing a facility. Enforcement
mechanisms, however, are not always used. Representatives from one
European country—that did not respond to our survey but discussed these
matters with us—told us that imposed fines tend to be so low that many
users of sealed sources may find it cheaper to pay the fines rather than
comply with the regulations.

9
 The International Basic Safety Standards are intended to ensure (1) the protection of
individuals and the population against radiation exposure, (2) the safety of radiation
sources in order to prevent accidents, and (3) the security of sources to prevent the
relinquishing of control over their use. IAEA’s Code of Conduct is a nonbinding document
that applies to all radioactive sources that may pose a significant risk to health and the
environment. It does not cover fissile materials used to construct weapons of mass
destruction and sources within military or defense programs. The code is currently being
revised to reflect member states’ increased concerns about the security risks posed by
sealed sources.




Page 19                                               GAO-03-638 Nuclear Nonproliferation
                              All of the countries responding to our survey reported that users of sealed
                              sources are required to secure radioactive materials in their possession. In
                              addition, 39 of the respondents reported that they had facilities to store
                              disused sources. However, only 18 countries indicated that they have a
                              facility to permanently dispose of the sealed sources. Those countries that
                              did not have any storage facilities were primarily located in Africa.
                              Representatives from four former Soviet Union countries told us that the
                              absence of secure storage poses a serious security problem, and an official
                              from the Republic of Georgia told us that a well-protected centralized
                              storage facility was urgently needed.

                              All but four of the countries responding to our survey said they had
                              regulations covering the safe transport of sealed sources. The countries
                              that did not have such regulations were located in Africa, South America,
                              and the Middle East. Although Russia did not respond to our survey,
                              Russian officials told us that they were concerned about moving sealed
                              sources safely and securely. They said that sources that were no longer
                              being used are moved great distances by trucks and are vulnerable to theft
                              because the operators of the vehicles must stop to rest or lose
                              communications owing to the remoteness of the locations where they are
                              traveling.



Countries’ Controls over      Nuclear safety and security experts from the Departments of Energy, State,
Sealed Sources Vary and Are   and Defense; NRC; IAEA; and the European Commission told us that
                              controls placed on sealed sources vary greatly between countries and have
Weakest among Developing      focused primarily on protecting public health and safety and not on
Countries                     securing the sources from potential terrorists threats. According to IAEA,
                              as many as 110 countries worldwide lack the regulatory infrastructure to
                              adequately protect or control sealed sources. Many of these countries are
                              considered less developed and are confronted with social, political, and
                              economic problems that divert attention from imposing controls on the
                              many thousands of radioactive sources used in hospitals, research
                              facilities, industries, or universities. In many cases, these countries’
                              regulatory organizations have a limited number of trained personnel. In the
                              absence of regulatory controls, radioactive sources have been inadequately
                              protected or secured; little or no attention has been paid to export or
                              import controls of sources; and there has been a lack of basic record
                              keeping. IAEA’s Director of the Division of Radiation and Waste Safety told
                              us that many countries also lack the commitment or political will to
                              exercise controls over sealed sources.




                              Page 20                                      GAO-03-638 Nuclear Nonproliferation
In March 2003 over 700 delegates from more than 120 countries met in
Vienna, Austria, to participate in an international conference on the
security of radioactive sources. The conference, sponsored by the
governments of the United States and the Russian Federation, emphasized
that all users of sealed sources share a responsibility for managing them in
a safe and secure manner and that the manufacturers of sources and
regulators have important roles to play. The conference also noted that
high-risk radioactive sources that are not under secure and regulated
control, including orphan sources, raise serious security and safety
concerns. U.S. and international experts are in the process of developing a
systematic approach to identifying the highest-risk sources. In 2000 IAEA
established a categorization of sealed sources to, among other things,
determine the level of oversight that should be applied to the safety and
security of a particular type of source. In response to growing concerns
about sealed sources being used as a terror weapon, IAEA has revised the
categorization. The categorization, which is still in draft, provides a
relative numerical ranking of sealed sources and practices for which they
are used. Appendix VIII provides more information about the conference,
and appendix IX contains additional details about IAEA’s revised
categorization of sources.




Page 21                                      GAO-03-638 Nuclear Nonproliferation
IAEA Has Implemented a   In 1994 IAEA established a model project program to enhance countries’
Program to Help Many     regulatory infrastructure. This program is available to any IAEA member
                         state upon request. (See app. X for a list of countries participating in the
Countries Improve        program.) The program has expanded and includes 88 countries. As of
Regulatory Controls      December 2002, IAEA had spent $27.7 million to help these countries.
                         Each country’s progress is measured through five milestones, including the
                         establishment of a regulatory framework.10 This milestone is considered
                         the most time-consuming and requires that the country draft and
                         implement radiation protection laws and regulations; designate and
                         empower a national regulatory authority; and establish a system for the
                         notification, authorization, and control of radioactive sources, including
                         the preparation of an inventory of sources and installations. According to
                         IAEA, about 77 percent of the countries participating in the program as of
                         September 2001 had promulgated the necessary laws and established
                         regulatory authorities. In addition, about 42 percent of the countries had
                         adopted the necessary regulations; about 50 percent had systems for the
                         notification, authorization, and control of radioactive sources in place and
                         operational; and about 80 percent had systems in place to inventory
                         sources. Considering that the program had been under way since the mid-
                         1990s, the level of achievement was much lower than expected, and the
                         time necessary to overcome some of the difficulties faced by the countries
                         was underestimated. The reasons that many of the countries had not fully
                         implemented this milestone included (1) time-consuming legislative and
                         regulatory procedures; (2) institutional instability; (3) budgetary
                         constraints, resulting in, among other things, a high turnover of qualified
                         staff; (4) unfocused regulatory structures, resulting in overlapping
                         responsibilities; (5) limited regulatory independence and empowerment;
                         and (6) insufficient financial and technical resources, trained staff, and
                         support services. Several countries responding to our survey indicated that
                         additional assistance is needed to improve controls over sealed sources,
                         including radiation detection equipment and training for regulatory staff.

                         U.S. and international officials told us that there are about 50 additional
                         countries needing assistance that are not member states of IAEA and are
                         not eligible for assistance under the model project program. According to
                         IAEA, many of these countries have sealed sources that are being used


                         10
                          The five milestones are (1) the establishment of a regulatory framework, (2) the
                         establishment of occupational exposure control, (3) the establishment of medical exposure
                         control, (4) the establishment of public exposure control, and (5) the establishment of
                         emergency preparedness and response capabilities.




                         Page 22                                             GAO-03-638 Nuclear Nonproliferation
                          without adequate controls. These officials are concerned that without
                          appropriate regulatory oversight, sources in these countries pose a
                          particularly serious threat because they are not adequately protected.

                          Officials from the Department of State, IAEA, and the European
                          Commission told us that France has implemented a system for controlling
                          sealed sources that could serve as a model for other countries, including
                          many developing nations. France’s system requires distributors of sealed
                          sources to assume financial responsibility for recovering and disposing of
                          these sources at the end of their 10-year life. According to French officials,
                          this system has significantly reduced the number of orphan sources.
                          France’s system for controlling sources is discussed in more detail in
                          appendix XI.



DOE Has a Program to      DOE has the primary U.S. government responsibility for helping other
                          countries strengthen controls over sealed sources. Since fiscal year 2002,
Help Other Countries      DOE has received $36.9 million to, among other things, secure sources at
Secure Sealed Sources,    several large nuclear waste repositories in Russia and other countries of
                          the former Soviet Union. Other U.S. federal agencies, including the
but Strengthened          Departments of Defense and State, and NRC have efforts under way to help
Coordination and          countries strengthen controls over sealed sources as well. DOE’s initial
Planning Are Needed       efforts to secure sealed sources have lacked adequate planning and
                          coordination, and the majority of program expenditures have been in the
                          United States. According to DOE officials, efforts are under way to
                          improve the management of the program, including the development of a
                          plan and better coordination with other agencies.



DOE Is Leading the U.S.   DOE is leading U.S. government efforts to help other countries strengthen
Effort to Help Other      controls over sealed sources. DOE’s effort is part of the overall U.S.
                          national strategy to reduce the risk that terrorist groups could use these
Countries Secure Sealed
                          materials in a dirty bomb attack against the United States. A congressional
Sources                   report instructs DOE to use a portion of its fiscal year 2002 supplemental
                          appropriation to address the threat posed by dirty bombs.11 In response to
                          the congressional requirement, the National Nuclear Security
                          Administration’s Office of International Material Protection and
                          Cooperation established the Radiological Threat Reduction program in


                          11
                               H.R. Conf. Rep. No. 107-350, at 431 (2001).




                          Page 23                                            GAO-03-638 Nuclear Nonproliferation
January 2002, budgeting $20.6 million for the program in fiscal year 2002,
and received an additional $16.3 million appropriation in fiscal year 2003.
The program is expected to receive an additional $22 million in
supplemental appropriations in fiscal year 2003, including $5 million to
secure nuclear material in Iraq.

Initially, DOE evaluated the threat to national security from radioactive
materials and determined that sealed sources pose a greater threat than
other radioactive materials, such as radioactive waste and nuclear fuel,
because of their availability; radioactivity; and other physical
characteristics, such as half-life. DOE did further studies of the dirty bomb
threat, including (1) narrowing the list of sealed sources that are a high
priority because of their characteristics and availability, (2) analyzing
possible scenarios in which a radiological dispersion device could be used,
and (3) determining what the economic consequences of a dirty bomb
attack in the United States would be. The former assistant deputy
administrator of the Office of International Material Protection and
Cooperation told us that it would be impossible to secure all sealed sources
but that by determining which sources pose the greatest risk, DOE could
prioritize its efforts.

DOE has focused on securing sealed sources in the countries of the former
Soviet Union because DOE officials have determined that is where the
greatest number of vulnerable sealed sources is located. In April 2002 the
Radiological Threat Reduction program initiated its first security upgrade
project at the Moscow Radon, a regional facility involved with collecting,
transporting, processing, and disposing of sealed sources and low- and
intermediate-level radioactive waste. There are 35 Radon facilities in the
former Soviet Union, but the Moscow Radon is by far the largest and
collects almost 80 percent of the institutional, industrial, and medical
radioactive wastes in Russia from almost 2,000 enterprises in the city of
Moscow, the Moscow region, and nine neighboring regions. During our
visit to the Moscow Radon in October 2002, Radon officials showed us the
building for which most of the DOE-funded upgrades are planned. (See
fig. 4.) Planned upgrades at the site include surveillance cameras, motion
detectors, vehicles, building upgrades, and a security facility where guards
can monitor the building where most high-activity sources are stored.
Although there have been no known attempts at theft of materials at the
site, Radon officials told us that upgrades are needed because existing
security is inadequate.




Page 24                                      GAO-03-638 Nuclear Nonproliferation
Figure 4: Moscow Radon Building Scheduled for DOE-Funded Security Upgrades




The program has also secured sealed sources in Uzbekistan and the
Republic of Georgia. In Uzbekistan, DOE has funded security upgrades at
research and irradiation facilities and the construction of a national
repository for sealed sources, and plans to fund increased physical security
upgrades at a dozen regional cancer treatment facilities. In the Republic of
Georgia, DOE funded security upgrades at a facility where radioisotope
thermoelectric generators and other high-activity sealed sources are
stored. Upgrades in both countries included bricking up windows;
reinforcing doors; improving or replacing roofs; upgrading storage vaults;
installing motion detectors and alarm systems; and other low-cost,
“low-tech” measures. Figure 5 shows an example of the security upgrades
funded by DOE.




Page 25                                      GAO-03-638 Nuclear Nonproliferation
Figure 5: DOE-Funded Physical Security Upgrades in the Former Soviet Union




(Top) before: Weak doors and windows; door locked with a simple padlock; and gaps/holes in roof.
(Bottom) after: Reinforced steel doors with double locks that cannot be cut; bricked-up windows; alarm
system; patched, reinforced roof.


In June 2002 DOE launched two additional efforts—a bilateral initiative
with MINATOM to secure sealed sources at Russian facilities identified by


Page 26                                                     GAO-03-638 Nuclear Nonproliferation
MINATOM, and a Tripartite Initiative with MINATOM and IAEA. The
objective of the Tripartite Initiative is to improve the security of sealed
sources in former Soviet states by developing inventories of sealed
sources, locating the sealed sources, recovering the sealed sources, storing
recovered sealed sources in a secure manner, and disposing of the sources.

Ultimately, DOE hopes that Russia will play a key role in recovering sealed
sources in other former Soviet states because many of these sealed sources
were manufactured in and distributed from Russia. In July 2002 MINATOM
provided DOE with a number of priority projects for funding in Russia.
These projects included recovering and securing radioisotope
thermoelectric generators, and recovering orphan sources at 45 sites in
Russia. According to DOE, the sites will be prioritized according to the
type and activity level of the radioactive material present.

DOE has completed site assessments at four Radon sites in Russia.
Upgrades at these facilities are expected to be completed by the end of
fiscal year 2004. A key criterion for deciding if the site requires upgrades is
an inventory of the sealed sources stored there—if the inventory includes
sealed sources that DOE has determined to be high risk, security upgrades
will be implemented.

Under the Tripartite Initiative, 19 additional Radon sites in other former
Soviet states will be assessed. These Radon sites are located in Armenia,
Azerbaijan, Belarus,12 Estonia, Georgia, Kazakhstan, Latvia, Lithuania,
Moldova, Tajikistan, Turkmenistan, Ukraine, and Uzbekistan. DOE also
plans to perform site assessments and security upgrades at medical,
industrial, and research facilities throughout the former Soviet Union,
similar to those done in Uzbekistan and Georgia. DOE, IAEA, and
MINATOM officials visited Moldova in the fall of 2002 to conduct a physical
security evaluation, implement the upgrades at the Moldova Radon, and
identify other sites where further work is needed to improve security. DOE
and IAEA officials conducted a similar trip to Tajikistan in December 2002.
Work in both countries is expected to be complete in the summer of 2003,
and DOE plans to initiate projects in Ukraine, Kazakhstan, the Baltics, and
possibly Armenia, Azerbaijan, and Kyrgyzstan in fiscal year 2003.



12
 Current U.S. policy is to restrict assistance in Belarus to humanitarian assistance and
exchange programs with state-run educational institutions; Russia and IAEA will likely
carry out any work to secure sealed sources in Belarus under the Tripartite Initiative.




Page 27                                                GAO-03-638 Nuclear Nonproliferation
                              In March 2003 the Secretary of Energy announced a new initiative to
                              broaden the Tripartite Initiative to other countries needing assistance to
                              secure high-risk vulnerable sources. The emphasis of the expanded
                              initiative will be on developing countries outside of the former Soviet
                              Union. As part of this expanded effort, DOE expects to initiate work in
                              Serbia and Indonesia this year.

                              Finally, DOE also has a program designed to strengthen other countries’
                              controls over sealed sources managed by the Office of International
                              Nuclear Safety within the National Nuclear Security Administration. The
                              office is working with IAEA, other international organizations, NRC, and
                              the State Department to develop a management program for sealed
                              sources. The purpose of this program is to protect the health and safety of
                              the public and people who work with sealed sources by developing
                              literature and training programs. The program also contributed assistance
                              for the international effort to recover orphan sources in the Republic of
                              Georgia, including providing technical assistance, detection and personnel
                              protection equipment, training, and software. In Armenia, this program is
                              providing training, equipment, and other technical assistance to enhance
                              the safety and security of sealed sources. As of September 30, 2002, DOE
                              had spent about $330,000 for these activities.



DOD, State, and NRC Also      DOD, through its Cooperative Threat Reduction program,13 is helping
Have Programs to              Kazakhstan to inventory, secure, and dispose of about 2,000 sealed sources,
                              primarily cesium-137 and cobalt-60, from an out-of-service industrial
Strengthen Other Countries’   facility, and identify other facilities with sealed sources. The manager of
Controls over Sealed          the program told us that although sealed sources are not traditionally
Sources                       considered to be weapons of mass destruction, DOD undertook this project
                              because the Kazakhstan government asked for assistance and the quantity
                              and types of sealed sources posed a security threat. The program began in
                              fiscal year 2001, prior to the establishment of DOE’s program to secure
                              sealed sources, and DOD does not expect to engage in any further projects
                              to secure sources in the former Soviet Union countries. The $1.7 million
                              project is expected to be completed by the end of fiscal year 2003.




                              13
                               The Cooperative Threat Reduction program is designed to help the countries of the former
                              Soviet Union destroy and prevent the proliferation of nuclear, chemical, and biological
                              weapons of mass destruction.




                              Page 28                                             GAO-03-638 Nuclear Nonproliferation
The State Department is also funding various projects to strengthen
controls. For example, State provided IAEA with $1 million in fiscal year
2002 to support the agency’s projects related to the safety and security of
radioactive sources. Additionally, State allocated $120,000 in fiscal year
2002 from the Nonproliferation and Disarmament Fund14 for a pilot project
to develop and improve radiation safety programs in developing countries,
including controls over sealed sources. The project was initially developed
by the Health Physics Society15 and proposed by State’s Office of the Senior
Coordinator for Nuclear Safety. Health Physics Society members volunteer
their time, and State Department funding is used for travel, per diem, the
cost of shipping donated equipment to the host countries, and evaluation of
the project—about $3,000 spent to date. Four countries—Costa Rica,
Ecuador, Jamaica, and Panama—were chosen for the pilot; however, work
has been initiated in only two countries. The project was recently
reactivated after a suspension of several months because of State
Department concerns about program management, security, and liability
issues.

The State Department has also contracted with Sandia National Laboratory
for a $100,000 study to assess the current laws and procedures governing
intercountry transfers of sealed sources. Specifically, the study is looking
at six countries that are either major exporters or importers of sealed
sources and will provide information on, among other things, the number
of sources that is imported and exported, and whether exporters are
required to verify whether the countries they are exporting to have controls
in place to ensure the safety and security of sealed sources.

In addition, NRC has a program to strengthen controls that focuses on
Armenia. NRC has spent $62,000 in Freedom Support Act funds transferred
from USAID to assist Armenia. Initially, NRC will help Armenia develop a
registry of sealed sources, including identifying the information required;
develop the database; and help Armenia gather, assess, develop, and verify
existing data on sources. Currently, Armenian regulations on sealed
sources and other radioactive materials are spread across different
ministries and departments, and many have not been changed since the fall


14
 The mission of the Nonproliferation and Disarmament fund is to undertake high-priority,
rapid response projects to halt the proliferation of and destroy or neutralize weapons of
mass destruction, and limit the spread of advanced conventional weapons.
15
 The Health Physics Society is a scientific and professional organization whose members
specialize in occupational and environmental radiation safety.




Page 29                                              GAO-03-638 Nuclear Nonproliferation
of the Soviet Union. NRC plans to assist Armenia with reviewing existing
regulations and developing consolidated regulations on, among other
things, licensing and inspections of radioactive sources, which will apply
governmentwide and meet international standards. In addition, NRC
provided Russia and Ukraine with guidance and training on the licensing
and regulation of sealed sources in the mid-1990s. NRC has also started
working with Canada and Mexico to share information about controls over
sealed sources in each country and improve cross-border controls and has
provided cost-free experts to help IAEA update its Categorization of
Radioactive Sources and Code of Conduct.

Finally, DOE and State are providing funds to support IAEA efforts to
strengthen controls over sealed sources. DOE and State have pledged a
total of $8.2 million—67 percent of the total $12.2 million pledged—to
IAEA’s Nuclear Security Fund.16 This fund was established after the
terrorist attacks of September 11, 2001, in conjunction with IAEA’s action
plan to improve nuclear security worldwide. The State Department has
directed $1 million of its contribution specifically toward activities to
improve the controls over sealed sources, and DOE’s $3 million
contribution is entirely directed to these efforts. Planned activities to
improve the security of sealed sources in member states include, among
other things, enhancing ongoing activities to improve controls of sealed
sources; developing standards, guidelines, and recommendations on the
security of radioactive sources; establishing security standards for the
transport of radioactive material; and locating and securing orphan
sources.

Table 4 summarizes the amounts that the Departments of Energy, State,
and Defense, and NRC have received, obligated, and spent to help other
countries strengthen their controls over sealed sources as of January 31,
2003.




16
  Other countries that have pledged voluntary contributions to the Nuclear Security Fund
include Australia, Bulgaria, Czech Republic, France, Greece, Iran, Ireland, Israel, Japan, the
Netherlands, New Zealand, Norway, Romania, Slovenia, South Korea, Sweden, and the
United Kingdom. The Nuclear Threat Initiative, a nongovernmental organization, has also
pledged to contribute to the fund.




Page 30                                                GAO-03-638 Nuclear Nonproliferation
Table 4: Assistance to Improve Controls over Radioactive Sources through January 31, 2003

Program/Activity                           Description                                               Received           Obligated             Spent
DOE Radiological Threat                    Assisting Russia and other former Soviet                $36,900,000        $11,426,600        $8,934,000
Reduction program                          Republics to secure sealed sources. Includes
                                           $3 million for IAEA activities.
DOE International Emergency                Training program for control and management                430,000              430,000          330,000
Management program                         of radioactive materials. Also provides
                                           assistance to help locate, handle, and safely
                                           remove high-risk sources.
DOD Cooperative Threat                     Securing, inventorying, and disposing of                  1,703,884           1,699,214          975,140
Reduction programa                         sources in Kazakhstan.
State Department Radiation                 Assisting to build radiation safety                        120,020              120,020            3,094
Safety without Borders Pilot               infrastructures in developing countries
project                                    participating in the IAEA model project.
State Department study                     Studying protocols on international transfers of           100,000              100,000           49,300
conducted by Sandia National               sealed sources in several countries.
Laboratory
State Department Nuclear                   Funding to IAEA.                                          1,000,000           1,000,000        1,000,000
Safety
Nuclear Regulatory                         Designing and developing a registry of sources,            250,000             250,000            62,000
Commission                                 and assistance to assess and develop
                                           regulations related to radioactive materials in
                                           Armenia.
Total                                                                                              $40,503,904        $15,025,834       $11,353,534
Sources: DOE, DOD, Department of State, and NRC.
                                                         a
                                                          DOD figures are through April 1, 2003.




DOE Efforts Have Not Been                                DOE is in the process of developing a plan to guide its efforts to help other
Well Planned and                                         countries secure sealed sources. According to DOE officials, initial
                                                         attempts to develop a plan were stopped in May 2002 because the former
Coordinated with Those of
                                                         administrator of the Office of International Material Protection and
Other U.S. Agencies                                      Cooperation felt that the program needed to show tangible results quickly.
                                                         In the absence of a plan, DOE officials told us that the program has
                                                         modeled its work in Russia on previous DOE projects to secure fissile
                                                         materials in Russia through its Material Protection, Control, and
                                                         Accounting program. The director of the program told us that while the
                                                         initial approach to securing sealed sources in Russia—focusing on
                                                         improving physical security at Radon sites—was a good idea, it hindered
                                                         DOE from setting priorities among other sites in Russia. He further noted
                                                         that the program is now focusing on improving the security of the most
                                                         vulnerable high-risk sources first.



                                                         Page 31                                                 GAO-03-638 Nuclear Nonproliferation
DOE officials told us that they recognize that the development of a plan is
essential. DOE’s draft plan has established short- and long-term program
elements, including consolidating and securing dangerous materials in
vulnerable locations; leveraging critical partnerships, such as continuing to
work with IAEA on key efforts such as the model projects program and the
code of conduct; and continuing to help countries detect smuggled
radioactive materials through its Second Line of Defense program.17 In
addition to the plan, DOE officials said they are also developing a more
detailed action plan; radioactivity thresholds for vulnerable high-risk
radioactive materials; and guidelines for describing the actions that should
be taken by DOE when sources are found to exceed those radioactivity
thresholds. As part of its overall effort, DOE officials told us that more
detailed planning and analysis will be needed to, among other things,
(1) determine which countries present the greatest security risk and most
urgently require assistance, (2) identify future funding requirements, and
(3) develop performance measures to gauge program success.

Despite these recent initiatives to improve program planning, officials from
Gosatomnadzor, the Russian agency responsible for regulating sealed
sources in use at almost 8,000 facilities in Russia, told us that beyond an
initial meeting, DOE had not consulted with them in the selection or
prioritization of sites for physical security upgrades. In particular,
Gosatomnadzor officials were surprised that DOE was focusing so much
attention on improving security at the Radon facilities in Russia where they
believed the probability that sealed sources will be stolen is low. They said
that it would be preferable to begin securing sealed sources from other
vulnerable sites near Moscow, for example, out-of-service irradiation and
research facilities. A systematic approach is required to assess needs,
identify priorities, and develop a comprehensive approach to securing
sealed sources. In their view, DOE’s initial approach had the potential to be
superficial.

DOE officials told us that they are now working more closely with
Gosatomnadzor. In a March 31, 2003, letter from DOE’s Acting Deputy
Assistant Secretary for International Material Protection and Cooperation
to Gosatomnadzor’s First Deputy Chairman, the DOE official noted the
need for regulatory oversight of the Russian radiological industry and



17
 See Nuclear Nonproliferation: U.S. Efforts to Help Other Countries Combat Nuclear
Smuggling Need Strengthened Coordination and Planning (GAO-02-426, May 16, 2002).




Page 32                                           GAO-03-638 Nuclear Nonproliferation
suggested that a proposal be formulated jointly with NRC to work
cooperatively in this area.

DOE is also seeking to improve planning and coordination of the Tripartite
Initiative. According to an IAEA official, DOE coordinated its efforts with
IAEA and Russia on the Moldova visit that contributed to a successful start
of the Tripartite Initiative. The participants jointly developed and
implemented a common approach for securing some vulnerable sealed
sources, and arrangements were made to construct a facility to store these
sources. However, the IAEA official told us that the Tajikistan assessment
was not well coordinated. He noted that DOE was not flexible in
scheduling the preliminary assessment visit and that Russia did not
participate in the visit. Because of the timing of the visit, IAEA’s
representative to the Tripartite Initiative was unable to participate in the
visit, however, an official from IAEA’s Department of Technical
Cooperation did accompany the DOE team.

DOE officials told us that they were unable to make changes to their
existing itinerary because they would have incurred significant delays if
travel dates were changed due to country clearance restrictions for U.S.
government travel in Tajikistan. Furthermore, they noted that because of
the different roles that DOE, MINATOM, and IAEA play under the Tripartite
Initiative, it is not necessary that representatives of each organization be
present on each visit. As currently envisioned, the Russian and IAEA
participants will act as an advance team, gathering information about
which sealed sources exist in a given country and their current level of
vulnerability. Subsequently, the U.S. team will visit the country and
negotiate contracts to improve security at the vulnerable sites.

IAEA’s official also told us that, overall, the Tripartite Initiative has not been
well planned. Initial efforts have been ad-hoc, and a more systematic
approach is needed as the program continues. He said that improved
planning is essential particularly because the Tripartite Initiative will be
used as a model to guide future efforts as the program expands worldwide.
DOE officials agreed that improved coordination is needed. DOE,
MINATOM, and IAEA are working to finalize a “Terms of Reference”
document that defines the objectives, scope, roles, operational framework,
and procedures to be followed for implementing projects under the
Initiative. Furthermore, preliminary schedules for missions to several
countries have been jointly developed through August 2003.




Page 33                                         GAO-03-638 Nuclear Nonproliferation
Department of State and NRC officials told us that DOE has not fully
coordinated its efforts with their agencies, although they noted that efforts
were recently under way to improve coordination. These officials told us
that DOE needs their input to ensure that a comprehensive
governmentwide strategy is taken to, among other things, leverage
program resources, maximize available expertise, avoid possible
duplication of effort, and help ensure long-term success. DOE has not
systematically undertaken the kind of comprehensive planning that would
foster better coordination with the other agencies and could also lead to
better coordination with other countries’ nuclear organizations. For
example, DOE did not adequately consult NRC or State when developing
the Radiological Threat Reduction program or developing the Tripartite
Initiative with MINATOM and IAEA. Officials from NRC and the State
Department expressed interest in sharing information and working with
DOE to plan and execute the Radiological Threat Reduction program, but
told us that there had been limited information sharing between agencies.

Both NRC and the State Department have extensive experience in nuclear
regulatory and safety-related issues in the former Soviet Union. NRC has
received approximately $50 million from fiscal year 1991 through fiscal
year 2002 to support regulatory strengthening efforts in the countries of
central and eastern Europe and the former Soviet Union. These efforts
have included training other countries’ regulators in all aspects of licensing
and inspection procedures, advising on how to establish a legal basis for
nuclear regulations, and developing a control and accounting system for
nuclear materials. The State Department’s Office of the Senior Coordinator
for Nuclear Safety, which was established about 10 years ago, provides
overall policy guidance for efforts to improve the safety of Soviet-designed
nuclear power reactors. Since then, the office’s mandate has expanded to
include the safety of other foreign civilian nuclear facilities, including
research reactors and waste facilities. In addition, State Department
officials said that more recently, State has been leading U.S. negotiations to
revise IAEA’s Code of Conduct and leading consultations within the U.S.
government with large exporters of sealed sources to strengthen export
controls on international transfers of them.

Several officials also told us that DOE was focusing too narrowly on rapid
physical security upgrades and not taking into account long-term needs to
develop better regulatory infrastructures in host countries. These officials
also said that a coordinated, targeted effort to identify and secure the most
vulnerable and high-risk sealed sources could eliminate the greatest risks,
and that developing regulatory frameworks in host countries would



Page 34                                       GAO-03-638 Nuclear Nonproliferation
                                         significantly improve the safety and security of sealed sources. DOE noted
                                         that part of the program’s strategy is to support IAEA initiatives to leverage
                                         resources of member states to improve the security of sealed sources in
                                         their countries. They are hoping to build on the work IAEA has done in this
                                         area, particularly on the development of regulatory infrastructure.



The Majority of DOE’s                    DOE budgeted $20.6 million for the Radiological Threat Reduction program
Program Expenditures Have                in fiscal year 2002 and received an additional $16.3 million in fiscal year
                                         2003. DOE had spent about $8.9 million of the total $36.9 million received
Been in the United States                as of January 31, 2003, including $3 million transferred to IAEA’s Nuclear
                                         Security Fund. Of the remaining $5.9 million in expenditures, 93 percent
                                         was spent in the United States by DOE’s national laboratories for labor,
                                         travel, equipment, and overhead. Only $407,900 had been spent by the
                                         national laboratories in the countries receiving assistance. Table 5 shows
                                         expenditures by the laboratories by component of cost as of January 31,
                                         2003.



Table 5: Radiological Threat Reduction Program Expenditures by DOE’s National Laboratories as of January 31, 2003

Dollars in thousands
                                                                                         Program activities in the
                                       Program activities in the United States             former Soviet Union
                                                                                                           Services
                                                                                                                and
Laboratory                              Labora     Travelb   Equipment    Overhead             Travelc   equipment           Total
Argonne National Laboratory              $707       $82.7          $3.1           $0.4               0         $3.0        $796.2
Los Alamos National Laboratory         1,263.9      114.4        103.2              0            29.5                0     1,511.0
Lawrence Livermore National
Laboratory                                65.3        8.4           0.6          -0.1d               0               0        74.2
Nonproliferation and National
Security Institute                       142.9        3.5             0             0                0               0      146.4
Nevada Operations Office                  65.4        6.0             0            9.1           15.7          10.0         106.2
Oak Ridge National Laboratory            208.5          0           1.3             0                0               0      209.8
Pacific Northwest National
Laboratory                             2,316.2      132.3          45.8           12.5               0        327.9        2,834.7
Remote Sensing Laboratory                175.2       38.5           1.9            7.6           11.8          10.0         245.0
Sandia National Laboratory                10.5          0             0             0                0               0        10.5
Total                                 $4,954.9     $385.8       $155.9           $29.5          $57.0        $350.9      $5,934.0
Source: DOE.




                                         Page 35                                               GAO-03-638 Nuclear Nonproliferation
a
  Includes salaries, wages, fringe benefits, and pensions that are directly chargeable to the
Radiological Threat Reduction program. DOE’s headquarters employees’ salaries are not
charged directly to the program but are funded through DOE’s Office of International
Material Protection and Cooperation.
b
  Includes both travel and per diem costs—foreign and domestic—for laboratory officials
and subcontractors.
c
 Includes travel costs for officials from other countries.
d
  The negative amount reflects funds from a prior fiscal year that were returned to the
Radiological Threat Reduction program by the laboratory.

DOE officials cited several reasons why only a small percentage of the
funds allocated to the program since fiscal year 2002 had been spent as of
January 31, 2003, including the following:

• The new program required significant start-up effort to assess the threat
  posed by sealed sources, determine the potential impacts from the
  detonation of a dirty bomb, and categorize and prioritize the types of
  sources that pose the greatest security risk.

• Difficulties and other unforeseen delays are frequently associated with
  doing work in the former Soviet Union. For example, the Russian
  Ministry of Construction, which maintains the Radon sites in Russia,
  raised concerns, after work had already started, that it had to authorize
  any work performed at those sites. Consequently, work was stopped at
  the Radon sites for several months. Initially, this Ministry had not been
  consulted by DOE and MINATOM in discussions about performing work
  at the Radon sites.

• It took DOE a significant amount of time to establish appropriate
  contacts in the countries of the former Soviet Union where DOE plans
  to provide assistance. While DOE has a long history of working with
  Russia to secure fissile materials through its Material Protection,
  Control, and Accounting program, DOE was required to identify and
  work with a different set of organizations responsible for regulating
  sealed sources.

DOE officials told us that expenditures in countries of the former Soviet
Union and other regions of the world are expected to increase as the
program evolves. According to DOE, as the program matures security
upgrades will be followed by comprehensive and costly consolidation and
disposition activities, all of which will take place in foreign countries. DOE
has requested an additional $36 million for the program in fiscal year 2004.




Page 36                                                GAO-03-638 Nuclear Nonproliferation
              The director of the program said that the amount requested was an
              estimate based on anticipated future funding requirements. He expects
              that the funds will be allocated for, among other things, continued work in
              Russia, including securing large numbers of radioisotope thermoelectric
              generators, additional contributions to IAEA’s Nuclear Security Fund, and
              expanded efforts to secure sources in countries outside of the former
              Soviet Union. The director also noted that plans to secure sources in other
              parts of the world are still being developed and that DOE wants to ensure
              that it has a sound basis for determining which countries to select for
              assistance.



Conclusions   The attacks that occurred in September 2001 widened the array of potential
              scenarios and challenges that U.S. decision makers must confront
              concerning terrorist threats. Sealed sources containing radioactive
              material, which have many beneficial industrial, medical, and research
              applications, must now be considered possible terrorist weapons. These
              sealed sources are in virtually every country of the world and are often
              inadequately secured or accounted for. The central question is, What can
              the United States and the world community do to confront this problem,
              given the likely vast and unknown number of sources that exist and
              continue to be manufactured and distributed globally?

              DOE appears to be well suited to help countries secure sealed sources
              because of its long history in securing weapons grade material in the
              former Soviet Union. Further, DOE’s efforts to develop a plan to guide its
              efforts is a step in the right direction. However, additional planning and
              detailed analyses will be needed to, among other things, systematically
              identify and prioritize countries that require assistance, establish realistic
              time frames and resources necessary to accomplish these tasks, and
              develop meaningful performance measurements. The elements of such a
              plan assumed greater importance in light of the Secretary of Energy’s
              recent announcement that DOE’s program will expand beyond the
              countries of the former Soviet Union. For this reason alone, it is imperative
              that a comprehensive plan be established and implemented before
              significant amounts of appropriated funds are spent to improve
              international controls over sealed sources. Regarding program
              expenditures, we agree with DOE’s objective to maximize program
              resources in the recipient countries. To date, the national laboratories have
              spent the majority of the program funds in United States and we believe
              that this trend needs to be reversed as the program evolves. We would
              expect that in the future, a markedly smaller percentage of program funds



              Page 37                                       GAO-03-638 Nuclear Nonproliferation
                      will be directed toward the national laboratories and the greatest
                      percentage will go to the countries that need the assistance to strengthen
                      controls over sealed sources.

                      We share the views of Department of State and NRC officials who
                      expressed their concerns that DOE was not adequately coordinating its
                      efforts with the other agencies. The Department of State and NRC have a
                      long history of working on international nuclear safety issues, and their
                      expertise and insights would be valuable, we believe, in crafting an overall
                      governmentwide plan for strengthening controls over sealed sources. In
                      particular, NRC has experience in working closely with many countries of
                      the former Soviet Union to develop and strengthen national regulatory
                      infrastructures. Clearly, any long-term plan requires that countries have a
                      competent regulatory authority that can place appropriate levels of
                      controls on sealed sources.



Recommendations for   We recommend that the Secretary of Energy (working with the
                      Administrator of the National Nuclear Security Administration):
Executive Action
                      • Develop a comprehensive program plan for helping other countries
                        secure sealed sources that includes (1) a unified set of program goals
                        and priorities, including a well-defined plan for meeting these goals in
                        the countries to be included; (2) program cost estimates; (3) time frames
                        for effectively spending program funds; (4) performance measures;
                        (5) ways to sustain upgrades to the facilities and equipment financed,
                        including cost estimates; and (6) an exit strategy for each country,
                        including a plan for transferring responsibilities to the host country for
                        building and equipment maintenance. The plan should be flexible and
                        updated periodically to ensure that long-term efforts are sustainable.

                      • Take the lead in developing a comprehensive governmentwide plan to
                        strengthen controls over other countries’ sealed sources. The plan
                        should be developed in conjunction with the Secretaries of State,
                        Defense, and Homeland Security, and the Chairman of NRC. In addition,
                        this plan should be coordinated with the International Atomic Energy
                        Agency to avoid overlap or duplication of effort.

                      • Strengthen efforts to increase program expenditures in the countries
                        requiring the assistance.




                      Page 38                                      GAO-03-638 Nuclear Nonproliferation
Agency Comments and   We provided the Departments of Energy, State, and Defense, and the
                      Nuclear Regulatory Commission with draft copies of this report for their
Our Evaluation        review and comment. We also provided IAEA with pertinent sections of
                      the report for review. DOD had no comments on the draft report. DOE’s,
                      State’s, and NRC’s written comments are presented as appendixes XII, XIII,
                      and XIV, respectively. The three agencies and IAEA also provided technical
                      comments, which we incorporated into the report as appropriate.

                      DOE’s National Nuclear Security Administration agreed with our
                      recommendations that the program needs strengthening and noted that the
                      Secretary and the Administrator are actively involved with the international
                      community to address the security of other countries’ sealed sources.
                      However, DOE disagreed with our finding that it had not coordinated its
                      efforts with NRC and the Department of State to ensure that a
                      governmentwide strategy is established. Further, DOE believes that it is
                      important to place the report’s findings in context since the program is in
                      its startup phase. Regarding DOE’s point about coordination, we had been
                      told several times during the course of our review by NRC and State
                      Department officials that DOE had not systematically included these
                      agencies in the development of a comprehensive strategy to strengthen
                      other countries’ controls over sealed sources. In fact, we raised this issue
                      with DOE program officials during our review and these officials
                      acknowledged that DOE needed to do a better job in coordinating its
                      program with other U.S. agencies. Although NRC and State Department
                      officials told us that coordination has improved recently, they endorsed the
                      need for the development of a governmentwide strategy to ensure that they
                      fully participate in future U.S. efforts. Regarding DOE’s concern about
                      putting the report’s findings in context, we noted in the draft report that the
                      program required a significant start-up effort to, among other things, assess
                      the threat posed by sealed sources, determine the potential impacts from
                      the detonation of a dirty bomb, and prioritize the types of sources that pose
                      the greatest threat.

                      State agreed with the facts presented in our report and noted that a
                      comprehensive approach to controlling sources will require a concerted
                      diplomatic effort that should be combined with the technical expertise
                      possessed by DOE in recovering and securing sealed sources in other
                      countries. State said that it possesses a unique perspective that is crucial
                      to the success of the program and hoped that we would clarify our
                      recommendation to delineate between DOE’s technical programmatic
                      responsibilities and State’s overall diplomatic role in guiding international



                      Page 39                                        GAO-03-638 Nuclear Nonproliferation
strategies for securing radiation sources. Regarding State’s point, we
acknowledge State’s responsibility to develop and implement international
strategies on behalf of the U.S. government. However, we believe, as noted
in the report, that DOE is well suited to help other countries secure sealed
sources because of its long history in securing weapons grade material in
the former Soviet Union and that it should take the lead in developing a
comprehensive plan to strengthen controls of other countries’ sealed
sources.

NRC made several points. First, NRC believed that our report should have
focused more attention on high-risk radioactive sources rather than on
radioactive sources of all types. NRC stated that the vast majority of
radioactive sources in use in the United States and abroad are not useful to
a terrorist and that it has been working with DOE and IAEA to finalize
IAEA’s revised Code of Conduct on Safety and Security of Radioactive
Sources and the revised Categorization of Sources. In addition, NRC noted
that only a few of the radioactive sources that are lost or stolen in the
United States are high-risk and that a majority of the sources reported lost
or stolen involve small or short-lived sources which are not useful as a
radiological dispersion device. Second, NRC identified various efforts that
it has undertaken to improve the security of high-risk sources in the United
States. Third, NRC pointed out that we should consider including the
Department of Homeland Security in our recommendation that calls for the
development of a governmentwide plan to help other countries secure
sealed sources.

Regarding NRC’s comments, one of the objectives of our report was to
specifically determine the number of sealed sources worldwide, and we
believe that it is important to develop information, to the extent possible,
regarding the number of all sealed radioactive sources that are in use. In
fact, IAEA has placed great emphasis, particularly among developing
countries, on the importance of developing and maintaining inventories of
sources for safety and security purposes. As we noted in our report,
current IAEA policy does not allow for the approval of any Technical Co-
operation project involving the use of significant radiation sources, unless
the member state in question, among other things, complies with the
requirements to maintain an effective regulatory framework that includes
an inventory of sources.

While we agree with NRC that the highest-risk sources present the greatest
concern as desirable material for a “dirty bomb,” other sealed radioactive
sources could also be used as a terrorist weapon. No one can say with



Page 40                                      GAO-03-638 Nuclear Nonproliferation
certainty what the psychological, social, or economic costs of a dirty
bomb—regardless of the radioactive material used to construct it—would
be. In addition, it is important to note that work by NRC, IAEA, and others
to characterize sources is still ongoing.

Regarding NRC’s comments about its activities to increase the security of
the highest-risk sources, we will address these matters in our forthcoming
report on U.S. efforts to strengthen controls over sealed sources in the
United States. Finally, during the course of our review, no agency we met
with was aware of or told us of a role being played by the Department of
Homeland Security in securing sealed sources in other countries. However,
we agree with NRC that it makes sense to coordinate the development of a
governmentwide plan for this activity with the Department of Homeland
Security and we have revised our recommendation to include the
department.


As agreed with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days after the
date of this letter. We will send copies of this report to the Secretary of
Energy; the Administrator, National Nuclear Security Administration; the
Secretary of State; the Secretary of Defense; the Secretary of the
Department of Homeland Security; the Chairman, Nuclear Regulatory
Commission; the Director, Office of Management and Budget; and
interested congressional committees. We will make copies available to
others upon request. In addition, the report will be available at no charge
on the GAO Web site at http://www.gao.gov.

If you have any questions concerning this report, I can be reached at
202-512-3841 or robinsonr@gao.gov. Major contributors to this report are
included in appendix XV.

Sincerely yours,




Robert A. Robinson
Managing Director, Natural Resources
  and Environment




Page 41                                        GAO-03-638 Nuclear Nonproliferation
Appendix I

Scope and Methodology                                                                        AA
                                                                                              ppp
                                                                                                ep
                                                                                                 ned
                                                                                                   n
                                                                                                   x
                                                                                                   id
                                                                                                    e
                                                                                                    x
                                                                                                    Iis




             To answer our objectives related to (1) number of sealed sources
             worldwide and how many sources are lost, stolen, or abandoned and (2)
             the legislative and regulatory controls that countries that possess sealed
             sources use, we distributed a questionnaire to 127 member countries of the
             International Atomic Energy Agency (IAEA), including 3 countries whose
             IAEA membership had been approved but had not yet taken effect at the
             time of our survey. We did not, however, survey all IAEA member states.
             Specifically, we did not distribute questionnaires to Afghanistan, Cuba,
             Iran, Iraq, Ivory Coast, Libya, Sudan, Syria, and the Holy See. The State
             Department recommended that we not correspond with the first eight
             countries listed. We determined from discussions with IAEA that the Holy
             See did not have any sealed sources. We did not include the United States
             because it is being treated separately in another GAO report.

             IAEA provided us with a list of the appropriate contacts for most of the
             countries we planned to survey. These officials were primarily from
             member countries’ regulatory authorities. We pretested the survey with the
             U.S. Nuclear Regulatory Commission (NRC) and with representatives from
             Brazil, Poland, the United Kingdom, Uganda, and Uzbekistan. After
             revising the survey to reflect the comments of these officials, we
             distributed it in December 2002 via E-mail and fax, and through countries’
             embassies in Washington, D.C., and Vienna, Austria, where IAEA is located.
             As a follow-up for nonrespondents, we also distributed questionnaires
             directly to many countries’ representatives who were attending an
             international conference in Vienna, Austria, on the security of radioactive
             sources. We also sent out periodic reminders to the countries from January
             through March 2003 requesting their assistance to complete the survey in a
             timely fashion. We received responses from 49 IAEA member states (39
             percent), including countries from Asia, North and South America, the
             former Soviet Union, Europe, the Middle East, and Africa. According to
             IAEA officials, the response rate was consistent with the rate it achieves
             when it sends out similar types of questionnaires to member states. In
             addition we were told by IAEA officials and others that there is an inherent
             difficulty associated with trying to obtain these types of data from
             countries owing to the sensitive nature of some of the questions and
             countries’ concerns about ensuring the confidentiality of their responses.
             Our survey results were used without attempting to project the information
             to the universe of IAEA members. We did not assume that nonrespondent
             countries would have had similar answers to our survey. Regarding the
             matter of confidentiality, we notified the countries that the results from the
             survey would be reported in aggregate and that individual responses would
             not be disclosed.



             Page 42                                       GAO-03-638 Nuclear Nonproliferation
Appendix I
Scope and Methodology




We supplemented the results obtained from the survey with interviews with
officials from several countries, including Brazil, France, Kazakhstan, the
Republic of Georgia, Russia, the United Kingdom, and Uzbekistan to learn
more about how they regulate and control sealed sources. We also met
with officials from IAEA and the European Commission to obtain their
views on the security problems and challenges associated with sealed
sources. In addition, we also interviewed and obtained pertinent
documents from officials of several U.S. government agencies, including
the Departments of Defense, Energy, and State, and NRC.

We attended two DOE-sponsored conferences related to the security of
sealed sources. The first conference, held in London, United Kingdom,
during September-October 2002, focused on international approaches to
nuclear and radiological security. The second conference, which was held
in Vienna, Austria, in March 2003, focused on the security of radioactive
sources and was attended by representatives from more than 120
countries.

To determine what assistance has been provided by the United States to
other countries to strengthen their controls over sealed sources, we
obtained budget, obligation, and expenditure data from the four agencies
providing assistance—the Departments of Energy, State, and Defense, and
NRC. To assess how well the programs were being implemented, we
interviewed program officials from each agency and reviewed pertinent
documents, including agency plans as available. We also obtained
information about these programs through interviews with representatives
of IAEA and officials from some of the countries receiving U.S. assistance.

Finally, we visited Russia to obtain a first-hand look at a waste facility that
contains sealed sources. Specifically, we traveled to the Moscow Radon
site at Sergiyev Posad, located about 90 kilometers from Moscow. While in
Russia we also interviewed officials from the Ministry of Atomic Energy,
the Ministry of Health, the Kurchatov Institute, Gosatomnadzor (Russia’s
nuclear regulatory organization), the Russian Academy of Sciences, and the
Russian National Technical Physics and Automation Research Institute.

We performed our review from May 2002 through May 2003 in accordance
with generally accepted government auditing standards.




Page 43                                        GAO-03-638 Nuclear Nonproliferation
Appendix II

Results of Survey of IAEA Member Countries                                                Appendx
                                                                                                Ii




              This appendix presents a copy of the survey sent to 127 IAEA member
              countries and the results of that survey.




              Page 44                                   GAO-03-638 Nuclear Nonproliferation
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Results of Survey of IAEA Member Countries




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Page 60                                      GAO-03-638 Nuclear Nonproliferation
Appendix III

List of Countries Surveyed by GAO and
Responses                                                                                      Appendx
                                                                                                     iI




               Table 6 lists all of the countries that we sent surveys to and identifies
               whether or not they completed the survey when this report was being
               written.



               Table 6: Countries Surveyed and Surveys Received

                                                   Completed the       Did not complete the
               Country                             survey              survey
               Albania                             X
               Algeria                                                 X
               Angola                                                  X
               Argentina                                               X
               Armenia                             X
               Australia                           X
               Austria                                                 X
               Azerbaijan                          X
               Bangladesh                                              X
               Belarus                                                 X
               Belgium                                                 X
               Benin                                                   X
               Bolivia                                                 X
               Bosnia and Herzegovina                                  X
               Botswana                                                X
               Brazil                                                  X
               Bulgaria                            X
               Burkina Faso                                            X
               Cambodia                                                X
               Cameroon                            X
               Canada                              X
               Central African Republic                                X
               Chile                                                   X
               China                                                   X
               Colombia                            X
               Costa Rica                          X
               Croatia                                                 X
               Cyprus                              X
               Czech Republic                      X
               Democratic Republic of the Congo                        X




               Page 61                                       GAO-03-638 Nuclear Nonproliferation
Appendix III
List of Countries Surveyed by GAO and
Responses




(Continued From Previous Page)
                                        Completed the      Did not complete the
Country                                 survey             survey
Denmark                                 X
Dominican Republic                                         X
Ecuador                                 X
Egypt                                                      X
El Salvador                                                X
         a
Eritrea                                                    X
Estonia                                 X
Ethiopia                                                   X
Finland                                 X
France                                                     X
Gabon                                                      X
Georgia                                                    X
Germany                                                    X
Ghana                                   X
Greece                                  X
Guatemala                               X
Haiti                                                      X
             b
Honduras                                                   X
Hungary                                 X
Iceland                                 X
India                                                      X
Indonesia                                                  X
Ireland                                                    X
Israel                                                     X
Italy                                   X
Jamaica                                                    X
Japan                                   X
Jordan                                                     X
Kazakhstan                                                 X
Kenya                                                      X
Korea (Republic of)                                        X
Kuwait                                  X
Kyrgyzstana                                                X
Latvia                                  X
Lebanon                                 X
Liberia                                                    X




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Appendix III
List of Countries Surveyed by GAO and
Responses




(Continued From Previous Page)
                                        Completed the      Did not complete the
Country                                 survey             survey
Liechtenstein                                              X
Lithuania                                                  X
Luxembourg                              X
Macedonia                               X
Madagascar                              X
Malaysia                                                   X
Mali                                                       X
Malta                                                      X
Marshall Islands                                           X
Mauritius                                                  X
Mexico                                  X
Moldova                                 X
Monaco                                                     X
Mongolia                                X
Morocco                                                    X
Myanmar                                                    X
Namibia                                                    X
Netherlands                                                X
New Zealand                             X
Nicaragua                                                  X
Niger                                                      X
Nigeria                                 X
Norway                                  X
Pakistan                                                   X
Panama                                                     X
Paraguay                                X
Peru                                                       X
Philippines                             X
Poland                                  X
Portugal                                                   X
Qatar                                                      X
Romania                                 X
Russian Federation                                         X
Saudi Arabia                            X
Senegal                                                    X
Sierra Leone                                               X




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Appendix III
List of Countries Surveyed by GAO and
Responses




(Continued From Previous Page)
                                            Completed the           Did not complete the
Country                                     survey                  survey
Singapore                                                           X
Slovakia                                    X
Slovenia                                                            X
South Africa                                                        X
Spain                                       X
Sri Lanka                                                           X
Sweden                                      X
Switzerland                                 X
Tajikistan                                                          X
Tanzania                                    X
Thailand                                                            X
Tunisia                                                             X
Turkey                                      X
Uganda                                      X
Ukraine                                     X
United Arab Emirates                                                X
United Kingdom                                                      X
Uruguay                                                             X
Uzbekistan                                  X
Venezuela                                                           X
Vietnam                                                             X
Yemen                                                               X
Yugoslavia                                  X
Zambia                                                              X
Zimbabwe                                                            X
Source: GAO.
a
 IAEA membership has been approved by the IAEA General Conference and will take effect once the
necessary legal instruments are deposited.
b
IAEA member state as of March 17, 2003.




Page 64                                                 GAO-03-638 Nuclear Nonproliferation
Appendix IV

Information on Trafficking Incidents Involving
Sealed Sources                                                                                             Appendx
                                                                                                                 iIV




               This appendix provides information about the illicit trafficking in, or
               smuggling of, radioactive material over the past decade and focuses
               primarily on 17 incidents involving sealed radioactive sources. There is
               sketchy—and sometimes contradictory—information about many of these
               cases for a number of reasons, including (1) many trafficking incidents are
               never detected by authorities; (2) some may be known but not reported
               because the country does not participate in IAEA’s Illicit Trafficking
               Database program; (3) details about these incidents may be considered
               sensitive by the countries where they occur; and (4) until recently,
               trafficking of radioactive materials was not considered by U.S. and
               international nonproliferation experts to be as great a concern as the
               trafficking of weapons-grade nuclear material. IAEA is encouraging
               countries to provide more details about all trafficking incidents involving
               radioactive materials so that better information can be developed and more
               accurate assessments and analysis can be performed.

               Since the early 1990s, there have been numerous reports of illicit
               trafficking in, or smuggling of, radioactive material worldwide, including
               sealed sources. According to IAEA, sealed sources, such as cesium-137,
               cobalt-60, strontium-90, and iridium-192 are considered to pose the greatest
               security risk. In 1993, IAEA established a database to record incidents
               involving illicit trafficking in nuclear and radioactive materials. Seventy
               countries, or about one-half of IAEA’s member states, currently participate
               in the database. As of December 31, 2002, IAEA listed 272 confirmed
               incidents involving the illicit trafficking of radioactive materials, including
               sealed sources.1 According to IAEA, a confirmed incident is one in which
               the information has been verified to IAEA through official points of contact
               from the reporting country. Of the 272 confirmed illicit trafficking
               incidents reported by IAEA, there were 179 incidents with potentially high
               risk sealed sources that pose the greatest security risks. More than two-
               thirds of the 179 incidents involving these sources occurred after 1997.
               Figure 6 depicts the frequency of reported international trafficking
               incidents involving sealed sources since 1993. Figure 7 provides
               information on types of sealed sources and other radioactive materials
               involved in international trafficking incidents.



               1
                The IAEA database includes incidents since January 1, 1993, that involved radioactive
               material other than nuclear material. In most cases, the radioactive material was in the form
               of sealed sources, but some incidents involving unsealed radioactive sources or
               radioactively contaminated materials, such as contaminated scrap metal, have also been
               reported to the illicit trafficking database and are included in the statistics.




               Page 65                                                GAO-03-638 Nuclear Nonproliferation
Appendix IV
Information on Trafficking Incidents
Involving Sealed Sources




Figure 6: Reported International Trafficking Incidents Involving Radioactive
Sources, 1993-2002




Page 66                                           GAO-03-638 Nuclear Nonproliferation
                                            Appendix IV
                                            Information on Trafficking Incidents
                                            Involving Sealed Sources




Figure 7: Illicit Trafficking Incidents by Type of Radioactive Source, 1993-2002




Sources: IAEA (data); GAO (presentation).




Trafficking Incidents                       Several observations can be made based on the incidents involving the
                                            illicit trafficking of sealed sources.
Involving Sealed
Sources                                     • The majority of the incidents involved deliberate intent to illegally
                                              acquire, smuggle, or sell radioactive material. Several other incidents
                                              reported, however, do not reflect criminal intent but have resulted from,
                                              among other things, the inadvertent transportation of contaminated
                                              scrap metal. The unregulated scrap metal industry throughout the
                                              former Soviet Union and Eastern Europe poses potential security and
                                              safety risks nonetheless because many radioactive sources are stolen
                                              for the metal shielding, leaving the source exposed and potentially very
                                              dangerous.




                                            Page 67                                     GAO-03-638 Nuclear Nonproliferation
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Information on Trafficking Incidents
Involving Sealed Sources




• Since the mid-1990s, the trafficking of radioactive materials has
  generally increased. The increase in illicit trafficking cases may be due,
  in part, to the increased reporting of these incidents by countries and/or
  improved radiation detection systems placed at countries’ border
  crossings.

• From 1993 through 1998, trafficking incidents involving radioactive
  material were primarily reported in Russia, Germany, and Estonia. In
  the past few years, there appears to have been an increase in trafficking
  through Ukraine, Bulgaria, and Romania.

• According to the illicit trafficking incidents reported by IAEA, high-risk
  sealed sources are more likely to be trafficked than weapons-grade
  fissile material, such as highly-enriched uranium. This is because such
  sources have numerous beneficial applications and are not as tightly
  controlled as fissile materials.

IAEA and DOE officials told us that the actual number of trafficking cases
involving sealed sources is larger than what is currently being reported
because many trafficking incidents are never detected by authorities and
many countries are not always willing to share sensitive trafficking
information. Another factor that affects the number of confirmed cases
reported is the credibility of the information. According to DOE, a
significant amount of time and expertise is required to assess a particular
incident before it can be deemed credible. Despite difficulties in drawing
conclusions from illicit trafficking data, the threat posed by illicit
trafficking is a real and growing problem. The Director of IAEA’s Office of
Nuclear Security also told us that every reported case should be taken
seriously. Furthermore, she noted that countries need to report their
smuggling incidents more systematically so that better assessments can be
performed.

Table 7 provides information about 17 significant cases of illicit trafficking
identified by IAEA and others since 1993. A brief discussion of each case
follows the table.




Page 68                                       GAO-03-638 Nuclear Nonproliferation
                                                                      Appendix IV
                                                                      Information on Trafficking Incidents
                                                                      Involving Sealed Sources




Table 7: Significant Seizures of Illicitly Trafficked Sealed Sources Since 1993

                                         Country where
Date                                     material was seized                                      Material                                                    How material was found
April 1993                               Estonia                                                  Cesium-137                                                  Interdiction by police
July 1993                                Germany                                                  Strontium-90                                                Discovered by police
                                                                                                                                                              investigation
September 1994                           Bulgaria                                                 Multiple sources                                            Discovered by police
                                                                                                                                                              investigation
October 1994                             Romania                                                  Strontium-90                                                Discovered by police
                                                                                                                                                              investigation
July 1995                                Estonia                                                  Radium-226                                                  Discovered by police
                                                                                                                                                              investigation
November 1995                            Russia                                                   Cesium-137                                                  Tip provided to news reporter
October 1998                             Ukraine                                                  Multiple sources                                            Discovered by customs
                                                                                                                                                              officials at airport
July 1999                                Russia                                                   Californium-252                                             Discovered by police
                                                                                                                                                              investigation
August 1999                              Turkey                                                   Cesium-137                                                  Discovered by police
                                                                                                                                                              investigation
September 1999                           Ukraine                                                  Strontium-90                                                Discovered by police
                                                                                                                                                              investigation
August 1999                              Russia                                                   Cesium-137                                                  Discovered by police
                                                                                                                                                              investigation
February 2000                            Ukraine                                                  Strontium-90                                                Discovered by police
                                                                                                                                                              investigation
March 2000                               Uzbekistan                                               Radioactively contaminated material                         Interdiction at border by
                                                                                                                                                              customs officials
December 2000                            Romania                                                  Multiple sources                                            Discovered by police
                                                                                                                                                              investigation
January 2001                             Greece                                                   Multiple sources                                            Discovered by police
                                                                                                                                                              investigation
January 2002                             Belarus                                                  Strontium-90                                                Discovered by police
                                                                                                                                                              investigation
May 2002                                 Bulgaria                                                 Multiple sources                                            Interdiction by police
Sources: IAEA, Monterey Institute of International Studies Center for Nonproliferation Studies, and Ridgway Center for International Security Studies.




Khohtla-Jarve, Estonia,                                               This incident involved two men who worked as assistants to an “engine”
                                                                      driver at a mineral fertilizer plant, which is located in Khohtla-Jarve,
1993                                                                  Estonia. The two men stole a device containing 2.8 grams of cesium-137
                                                                      and were arrested. According to available information, the suspects
                                                                      intended to sell the cesium to an unspecified buyer.



                                                                      Page 69                                                                            GAO-03-638 Nuclear Nonproliferation
                         Appendix IV
                         Information on Trafficking Incidents
                         Involving Sealed Sources




Saarbrucken, Germany,    In July 1993, German police recovered an unidentified amount of
                         strontium-90 that had been transported from Ukraine. The material, which
1993                     was packed in small containers, was found by police from information
                         provided by Ukrainian security services. Reportedly, the containers were
                         discovered in three plastic bags after Ukrainian police had told the German
                         police where to find them. Police in Kiev, Ukraine, arrested 17 people in
                         connection with the operation.



Sofia, Bulgaria, 1994    In September 1994, following a 5-day undercover operation, Bulgarian
                         authorities arrested six Bulgarians and confiscated 19 containers of
                         radioactive substances, including plutonium, cesium-137, strontium-90,
                         plutonium-beryllium sources, and thallium-204 that had been stolen from
                         the Izotop Enterprise near the capital, Sofia. According to available
                         information, the theft was made possible by poor security at the laboratory.



Urechesti, Romania,      In October 1994, Romanian authorities arrested three Moldovans, two
                         Jordanians, and two Romanians for trying to sell 7 kilograms of strontium
1994                     in a lead pipe. One suspect, a former military officer, had smuggled the
                         strontium to Moldova. The material was then passed to intermediaries in
                         the Romanian province of Transylvania, where it was offered to the
                         Jordanians for $400,000.



Tallinn, Estonia, 1995   In July 1995, Estonian security police arrested two Estonians who had
                         radium-226 in their car. According to available information, it was thought
                         that the radium was smuggled into Estonia via middlemen in St.
                         Petersburg, Russia, indicating that more people were probably involved.



Moscow, Russia, 1995     In November 1995, acting on a tip, Russian television reporters discovered
                         a 32-kilogram container, containing cesium-137 and wrapped with
                         explosives, in a Moscow park. According to available information,
                         Chechen separatists were responsible for this incident and had reportedly
                         obtained the radioactive material from either cancer-treatment equipment
                         or an instrument calibration device used in flaw detection equipment. The
                         Chechens threatened to detonate the device if Russia decided to resume
                         combat operations in the region.




                         Page 70                                     GAO-03-638 Nuclear Nonproliferation
                          Appendix IV
                          Information on Trafficking Incidents
                          Involving Sealed Sources




Kiev, Ukraine, 1998       In October 1998, a radiation health specialist at a German company that
                          consults on reactor safety was arrested by customs police at Kiev airport in
                          possession of a container of radioactive material from Chernobyl.
                          According to available information, a Russian scientist asked the health
                          specialist to take a metal container holding a small amount of radioactive
                          material out of the country for analysis. Russian officials were unsure of
                          the exact type of material involved, but suspected it contained cesium,
                          strontium, and zirconium.



St. Petersburg, Russia,   In July 1999 Russian law enforcement officials arrested two men who
                          attempted to sell 5 grams of californium-252. One of those arrested, a
1999                      technician from Murmansk, was approached by a criminal group who
                          enlisted his help to procure californium-252. The technician, who was
                          responsible for removing spent nuclear components from a nuclear-
                          powered icebreaker, smuggled the radioactive material off the icebreaker.
                          Along with an accomplice, the technician packed the californium-252 into a
                          container filled with paraffin, which they placed within a canister of water.
                          After the initial offer from the criminal group fell through, the technician
                          and his accomplice traveled to St. Petersburg in search of another buyer,
                          where they were arrested.




Istanbul, Turkey, 1999    In a joint operation, the Istanbul Organized Crime and Arms Smuggling
                          Office and the National Intelligence Organization arrested five people, one
                          of whom was from the Republic of Georgia, as they tried to sell cesium-137
                          to policemen acting as buyers in Istanbul in August 1999. The cesium,
                          which was in two separate steel tubes and weighed 49 grams, was
                          smuggled into Turkey from an unknown location.



Uzhgorod, Ukraine,        In September 1999, a Russian citizen was arrested after police officers
                          discovered that he was carrying two containers of strontium-90. The
1999                      material was discovered on the suspect during a document check by
                          Ukrainian police. It is believed that the suspect was taking the radioactive
                          materials from Russia to Western Europe. The suspect was in possession
                          of a number of forged documents, including a forged diplomatic
                          identification card.



                          Page 71                                      GAO-03-638 Nuclear Nonproliferation
                          Appendix IV
                          Information on Trafficking Incidents
                          Involving Sealed Sources




Volgograd, Russia, 1999   In August 1999, Russian security police recovered six containers of cesium-
                          137, which were stolen from a Volgograd oil refinery in May 1998. Earlier
                          efforts to locate the stolen containers, including the establishment of
                          checkpoints with radiation monitors on local roads, had proven fruitless.
                          According to reports, the thieves had hidden the stolen cesium containers
                          to avoid this police dragnet and hoped to sell the material after the search
                          for it had finally been abandoned.



Donetsk, Ukraine, 2000    In February 2000, A Ukrainian law enforcement unit confiscated 27
                          containers of strontium-90. Five individuals were reportedly involved in
                          the illegal trafficking of this material. The group allegedly tried to contact
                          foreign buyers, who were in fact members of the law enforcement unit.
                          The radioactive material was reportedly stolen from a military unit
                          deployed in the region and was stored in an apartment. Reports stated that
                          the individuals were attempting to sell the 27 containers for $168,000.



Beshkoprik,               In March 2000, Uzbekistan customs officers seized an Iranian-registered
                          truck on the Kazakhstan-Uzbekistan border about 20 kilometers from
Uzbekistan, 2000          Tashkent, the capital of Uzbekistan, after discovering it contained highly
                          radioactive material. Kazakhstan customs officials had cleared the truck
                          and issued a certificate indicating that it had passed radiation screening.
                          Uzbekistan officials determined that the level of gamma radiation emitted
                          by the cargo was 100 times over the acceptable level. Uzbekistan customs
                          officials then returned the truck to their Kazakhstani counterparts. The
                          destination listed on the truck’s manifest was Quetta, Pakistan, and some
                          reports speculated that the incident involved efforts to smuggle radioactive
                          material intended for use by terrorist groups to build a radiological
                          weapon.



Piatra Neamt City,        In December 2000, five suspects were arrested while trying to sell
                          1 kilogram of radioactive material (strontium, plutonium, and cobalt), to
Romania, 2000             undercover police officers posing as prospective buyers of radioactive
                          material. The suspects included a former officer of an antiorganized crime
                          police unit in Moldova and four Romanians who were bodyguards in charge
                          of protecting the shipments and who were responsible for organizing the
                          sale of the materials.




                          Page 72                                       GAO-03-638 Nuclear Nonproliferation
                        Appendix IV
                        Information on Trafficking Incidents
                        Involving Sealed Sources




Thessaloniki, Greece,   In January 2001, Greek law enforcement officials uncovered several
                        hundred metal “wafers” of commercially available alpha-emitting ionization
2001                    sources, containing a total of 3 grams of plutonium and americium. The
                        cache was found buried in a forest 12 kilometers from Thessalonki. The
                        sources were believed to be smuggled from Eastern Europe, and there was
                        speculation about organized criminal involvement in the smuggling of these
                        sources. An investigation was launched, but to date, there have been no
                        publicly released results.



Minsk, Belarus, 2002    In January 2002, police in Minsk, Belarus, arrested two persons in
                        connection with an attempt to sell four sealed sources of strontium-90 that
                        one of the suspects had been storing in his apartment. One of the suspects
                        had stolen the sources 4 years earlier during his military service, and the
                        other was arrested while trying to sell them.



Veliko Tarnova,         In May 2002, Bulgarian authorities seized 101 plutonium sources and an
                        americium-beryllium source from a vehicle near Veliko Tarnova. The
Bulgaria, 2002          sources were detected when police officers stopped a taxi with four
                        individuals during a routine inspection. Thirty-nine of the plutonium
                        sources had certificates indicating that they had been manufactured in 1990
                        by Izotop-Moscow and had been ordered for a ferryboat station in Varna.
                        Because the 10-year guaranteed service life of the sources had expired, it is
                        possible that the sources were diverted after they had been removed from
                        service for disposal.




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Information About Accidents Involving Sealed
Sources                                                                                       Append
                                                                                                   x
                                                                                                   i
                                                                                                   V




               According to IAEA and the World Health Organization, there have been
               more than 100 accidents involving sealed sources over the past 50 years.
               Many of these accidents have been small and resulted in few injuries. The
               actual number of accidents worldwide is unknown because many countries
               do not report or record such events. This appendix describes 10 accidents
               that occurred since the early 1980s. Although these accidents were not the
               result of malevolent actions, they are useful in gaining a better
               understanding of the potential consequences following the loss of control
               of sealed sources.

               We have included, to the extent that it was available, information on the
               economic impacts of the accidents. The costs associated with lost
               equipment, damage to property, and the disposal of radioactive waste can
               be very significant. The cost components associated with radiological
               accidents include

               • medical treatment of exposed individuals;

               • radiation surveillance, including searching for lost sealed sources and
                 contaminated areas;

               • decontamination and dismantling of contaminated buildings and
                 property,

               • loss of production capacity;

               • radioactive waste management and disposal;

               • monetary compensation to individuals who received excessive doses of
                 radiation;

               • rebuilding or possible relocation costs; and

               • effects on international trade.

               Nonmonetary impacts may include:

               • loss of public confidence and credibility in the government, and

               • public questions about all uses of ionizing radiation.




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                                                    Information About Accidents Involving
                                                    Sealed Sources




                                                    Table 8 provides information about 10 significant cases of accidents
                                                    identified by IAEA and the World Health Organization since 1983. A brief
                                                    discussion of each case follows the table.



Table 8: Selected Accidents Involving Sealed Sources Since 1983

                                                                                      Number of     Number of
                                                   Type of sealed source              significant     related
Year                        Location               involved                           exposures        deaths Associated costs
1983                        Juarez, Mexico         Cobalt-60                                  80             0 $34 million
1984                        Morocco                Iridium-192                                11             8 Unknown
1987                        Goiania, Brazil        Cesium-137                                 50             4 $36 million
1994                        Tammiku, Estonia       Cesium-137                                  3             1 Unknown
1996                        Gilan, Iran            Iridium-192                                 1             0 Unknown
1997                        Lilo, Georgia          Cesium-137                                 11             0 Unknown
1998                        Los Barrios, Spain     Cesium-137                                  6             0 $28 million
1999                        Yanango, Peru          Iridium-192                                 1             0 Unknown
2000                        Samut Prakarn,         Cobalt-60                                  10             3 Unknown
                            Thailand
2001                        Lja, Georgia           Cesium-137                                  2             0 Unknown
Sources: IAEA and the World Health Organization.




Juarez, Mexico, 1983                                A teletherapy unit containing a cobalt-60 source was purchased and
                                                    imported by a Mexican hospital without compliance with existing import
                                                    requirements. After the unit was stored for 6 years in a warehouse, its
                                                    scrap value attracted the attention of a maintenance technician. The
                                                    technician dismantled the unit and removed the cylinder containing the
                                                    sources and other metal parts. He then loaded them into a pickup truck,
                                                    drove to a junkyard, and sold the parts as scrap. Before arriving at the
                                                    junkyard, he ruptured the sealed cobalt source, dispersing about 6,000 tiny
                                                    pellets of cobalt-60 in the truck bed.

                                                    When cranes moved the ruptured cylinder, the cobalt-60 pellets were
                                                    spread over the junkyard and mixed with other metal materials.
                                                    Consequently, pellets and pellet fragments were transferred to vehicles
                                                    used for transporting the scrap to various foundries. The technician’s
                                                    pickup truck remained parked on the street for 40 days and was then
                                                    moved to another street, where it remained for an additional 10 days. An



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                Sealed Sources




                unknown number of people passed by the truck each day and children used
                it as a play area. It was later discovered that contaminated scrap metal
                from the junkyard had been used to manufacture reinforcing rods and
                metal table bases. A truck transporting contaminated rods passed near a
                DOE national laboratory, where radiation detectors indicated the presence
                of radioactivity. Two days later, the authorities ascertained the origin of the
                contaminated rods.

                U.S. and Mexican officials spent an estimated $34 million to track, recover,
                and secure these radioactive products. An extensive investigation showed
                that 30,000 tables and 6,000 tons of reinforcing rods had been made from
                the contaminated material. In addition, 814 buildings were partly or
                completely demolished because the radioactivity in the reinforcing rods
                resulted in higher-than-acceptable levels of radiation. The accident
                exposed 4,000 people to radiation, and 80 people received significant
                doses. Table 9 provides a breakdown of the estimated costs associated
                with the accident.



                Table 9: Estimated Costs Related to the Accident in Mexico

                Dollars in thousands
                Action taken                                                                         Cost
                Transport and disposal of contaminated material                                   $15,640
                Demolition and reconstruction to remove contaminated reinforcement bars in
                buildings                                                                           8,500
                Loss of production capacity                                                         3,740
                Value of contaminated material                                                      2,040
                Technical and operational personnel and equipment                                     680
                Security and surveillance by police and army forces, and legal or political
                problems                                                                            3,400
                Total                                                                             $34,000
                Source: IAEA.




Morocco, 1984   In 1984, iridium-192 sources were being used to radiograph welds in a
                fossil-fuel power plant under construction. One of these sources dropped
                to the ground from a radiography camera, where a passerby picked it up
                and took it home. The source was lost from March to June 1984 and, as a
                result, eight persons died from overexposure to radiation. In addition,
                three others suffered severe injuries from overexposure that required



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                        Sealed Sources




                        hospitalization. It was initially assumed that the deaths were from
                        poisoning. Only after the last family member died was it suspected that the
                        deaths might have been caused by radiation.



Goiania, Brazil, 1987   A private radiography institute moved to new premises and left behind a
                        cesium-137 teletherapy unit without notifying the licensing authority.
                        Because the building was partially demolished, the teletherapy unit was
                        unsecured. Two people entered the building and removed the source
                        assembly. They dismantled the source assembly at home and ruptured the
                        sealed source. After the sealed source was ruptured, remnants of the
                        source assembly were sold for scrap to a junkyard owner. He noticed that
                        the material had a blue glow in the dark. Over a period of days, friends and
                        relatives came to witness the phenomenon. Fragments of the source, the
                        size of rice grains, were distributed to several families. Five days later, a
                        number of persons started to show gastrointestinal distress.

                        Because the sealed source contained cesium chloride, which is highly
                        soluble and easily dispersed, there was considerable contamination of the
                        environment, resulting in external irradiation and internal contamination of
                        several persons. Some individuals suffered very high internal and external
                        contamination because of the way they had handled the cesium chloride
                        powder, such as rubbing it on their skin, eating with contaminated hands,
                        and handling various objects. Consequently, four people died within 4
                        weeks of being hospitalized. In total, 249 people were contaminated, and
                        112,000 people were screened for contamination.

                        The environment was also severely contaminated. Eighty-five houses were
                        significantly contaminated, and 41 of these had to be evacuated. The
                        decontamination process required the demolition of seven residences and
                        various other buildings and generated 3,500 cubic meters of radioactive
                        waste.

                        The accident had a great psychological impact on the whole region. Many
                        people feared contamination, irradiation, and incurable diseases. Over
                        8,000 persons requested monitoring for contamination in order to obtain
                        certificates stating that they were not contaminated. These were needed
                        because operators of commercial airplanes and buses refused to allow
                        people from the region to board and hotels refused to register them. The
                        social and psychological impact of the accident was so great that an
                        outlying region to Goiania, where the waste repository was established, has
                        incorporated the trifoil symbol of radioactivity into the region’s flag.



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                    Sealed Sources




                    Economically, there was discrimination against products from Goiania,
                    resulting in a 20 percent decrease in the sales of cattle, grains, and other
                    agricultural products from the region. Tourism decreased virtually to zero
                    and the gross domestic product for the region decreased by 15 percent. It
                    took 5 years for the gross domestic product to return to preaccident levels.
                    In total, the direct and indirect costs for emergency response and remedial
                    action are estimated to be $36 million.



                    Figure 8: Contaminated Radioactive Debris from Demolished Residences in Goiania




Tammiku, Estonia,   In October 1994 a sealed source that was discovered in scrap metal was
                    recovered and transferred to a radioactive waste repository under the
1994                supervision of the national government. Three brothers entered the
                    repository without authorization and removed a metal container enclosing
                    a cesium-137 source and the source fell out of the container. One of the
                    men placed the source in his pocket and took it home. The source
                    remained in the house for 27 days, resulting in the overexposure of five
                    individuals, including one fatality. The sealed source was thought to be



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                      Sealed Sources




                      part of a gamma irradiator, but none had ever been used or registered in
                      Estonia. According to available information, it is possible that the source
                      was brought into Estonia from the Russian Federation with miscellaneous
                      scrap metals for export to Western Europe.



Gilan, Iran, 1996     At a combined cycle fossil fuel power plant in Iran, radiography equipment
                      with an iridium-192 sealed source was used to examine welds from a boiler.
                      At the end of the radiographer’s shift, the source became detached from its
                      drive cable and fell to the floor unnoticed. Later, a worker moving thermal
                      insulation materials around the plant noticed a shiny, pencil-sized metal
                      object in a trench and put it in his pocket. The source was in his chest
                      pocket for approximately two hours, resulting in a high radiation dose. As
                      a result of this exposure, the worker had abnormal redness of the skin,
                      severe bone marrow depression, and an unusually extended radiation
                      injury requiring plastic surgery.



Lilo, Georgia, 1997   Eleven border frontier guards became ill owing to exposure from multiple
                      radioactive sources, including 12 cesium-137 sources, one cobalt-60 source,
                      and 200 radium-226 sources. These sources were abandoned when the
                      military site was transferred from the Soviet Union to the Republic of
                      Georgia. All individuals suffered from skin ulcerations and chronic
                      radiation sickness. No deaths were associated with this accident.




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                      Sealed Sources




                      Figure 9: Location Where Sealed Sources Were Found, Lilo, Georgia




Los Barrios, Spain,   In May 1998, a cesium-137 source was accidentally melted at a stainless
                      steel factory. As a result of the periodic maintenance and cleaning of the
1998                  filter system at the factory, the dust was removed, and much of it was sent
                      to two different factories several hundred kilometers from the factory. The
                      dust was contaminated with cesium-137, and about 400 people were
                      monitored for contamination. Measurements of a large number of water,
                      air, and soil samples were obtained from nearby towns and at locations
                      several hundred kilometers away. Traces of cesium-137 were found but
                      considered negligible. In countries outside of Spain, the environmental
                      impact was minimal. The economic consequences of the accident,
                      including temporary suspension of factory operations, decontamination
                      operations, and management of the resulting radioactive waste, were
                      estimated to be over $25 million.



Yanango, Peru, 1999   In February 1999 an iridium-192 source fell out of a radiography camera
                      being used at a hydroelectric power plant. Later that day, a welder picked
                      up the iridium-192 source and placed it in the right back pocket of his



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                 Information About Accidents Involving
                 Sealed Sources




                 trousers. For the next several hours, the welder continued his work and
                 later took a minibus home with 15 other people onboard. Once home, the
                 welder’s wife fed their 18-month-old child while she was sitting on the
                 welder’s trousers, and two other children were 2-3 meters from the iridium
                 source for approximately 2 hours. The welder received extensive radiation
                 burns that required the amputation of his right leg. The wife suffered
                 lesions on her lower back after her brief exposure to the sealed source. No
                 radiation effects were reported for the children.



Samut Prakarn,   A company in Bangkok, Thailand, possessed several teletherapy devices
                 containing cobalt-60 without authorization from the Thailand Office of
Thailand, 2000   Atomic Energy for Peace. The teletherapy device was originally installed at
                 a hospital in Bangkok, Thailand, in 1969. In 1981, a new source was
                 installed, and the hospital received no further maintenance from the
                 manufacturer of the teletherapy unit and source. When the teletherapy unit
                 was removed from service in 1994, the maintenance contractor had gone
                 bankrupt and the manufacturer was no longer producing cobalt-60 units.
                 As a result, the hospital was left with the disused source to manage and
                 control. Since the hospital did not have sufficient storage space, it sold the
                 device and source to a new supplier without the authorization of the
                 regulatory authority. In 1999 the new supplier was notified that its lease of
                 the warehouse was to be terminated and relocated the device to a parking
                 lot that was owned by its parent company.

                 In the autumn of 1999, the company relocated the teletherapy devices to an
                 unsecured storage location without the authorization of the national
                 regulatory authority. In late January 2000, several individuals obtained
                 access to the unsecured storage location and partially disassembled the
                 teletherapy device. The individuals took the unit to a residence and
                 attempted to disassemble it further.

                 In early February 2000, two individuals took the disassembled device to a
                 junkyard in Samut Prakarn, Thailand, to segregate component metals and
                 sell them separately as scrap. While a junkyard worker was disassembling
                 the device, the cobalt-60 source fell out of its housing unobserved by the
                 junkyard workers or the individuals. By the middle of February 2000,
                 several of the people involved, including the finders of the source and
                 junkyard workers, had begun to feel ill and sought medical assistance.
                 Physicians at the hospital suspected the possibility of radiation exposure
                 and reported their suspicions to the regulatory authority. Altogether, 10




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                     Sealed Sources




                     people received high doses of radiation from the source. Three of those
                     people, all workers at the junkyard, died within 2 months of their exposure.



Lja, Georgia, 2001   In December 2001 three woodsmen found two heat-emanating metallic
                     containers near their campsite in a forest near the village of Lja in western
                     Georgia. This village is in the Abkhazia region of the Caucasus. This
                     region is subject to political unrest and has sought its independence from
                     the Republic of Georgia. As a result, during the past decade, the region has
                     been largely inaccessible to Georgian and international authorities. The
                     woodsmen involved in the accident used the containers as a heat source
                     and experienced nausea, vomiting, and dizziness within hours of exposure
                     to the containers. At a local hospital in Tbilisi, Georgia, the woodsmen
                     were diagnosed with radiation sickness and severe radiation burns, and at
                     least two of the three were in serious condition. In February 2002, an
                     IAEA-sponsored search and recovery team found the containers and
                     discovered that each one was previously used in Soviet-era radioisotope
                     thermoelectric generators.




                     Page 82                                      GAO-03-638 Nuclear Nonproliferation
Appendix VI

Information on Producers and Distributors of
Radioactive Material                                                                                                              Appendx
                                                                                                                                        iVI




                                          This appendix provides information about the major producers and
                                          distributors of radioactive material used to manufacture sealed sources.
                                          Six countries are the major suppliers of the radioactive material: Argentina,
                                          Belgium, Canada, the Netherlands, Russia, and South Africa. Canada is the
                                          largest exporter of radioactive material and has provided over half of all
                                          radioactive material used in medical applications worldwide. Table 10 lists
                                          the major producers and distributors of radioactive material used to
                                          manufacture sealed sources.



Table 10: Major Producers and Distributors of Radioactive Material Used to Manufacture Sealed Sources

Country                              Major organizations producing and/or distributing sources
Argentina                            National Atomic Energy Commission and INVAP S.E.
Australia                            Australian Nuclear Science and
                                     Technology Organization
Belgium                              National Institute for Radio Elements and Belgian Nuclear Research Centre
Brazil                               Instituto de Pasquisas Energeticas Nucleares
Bulgaria                             Institute for Nuclear Research and Nuclear Energy
Canada                               Atomic Energy of Canada, Ltd., and MDS Nordion
China                                China Isotope Corporation and Nuclear Power Institute of China
Czech Republic                       Nuclear Research Institute
Denmark                              Risoe National Laboratory
France                               CIS Bio International
                                     Commissariat A L’Energie Atomique Centre D’Etudes De Valduc
Germany                              AEA Technology QSA, GmbH., Chemotrade,
                                     Isotope Products Europe Blaseg, GmbH., and
                                     STS—Steuerungstechnik & Strahlesnschutz GmbH
Hungary                              Atomic Energy Research Institute and Institute of Isotopes Co., Ltd.
India                                Bhabha Atomic Research Centre
Indonesia                            National Nuclear Energy Agency
Japan                                Japan Atomic Energy Research Institute and Institute for Atomic Energy Rikkyo University
Malaysia                             Malaysian Institute for Nuclear Technology Research
Netherlands                          I.D.B. Holland B.V.
Russia                               Atomenergoexport, Institute of Physics and Power Engineering, Kurchatov Institute, Mayak
                                     Production Association, Scientific and Research Institute of Atomic Reactors, and St.
                                     Petersburg Institute of Nuclear Physics
South Africa                         South African Nuclear Energy Corporation
South Korea                          Korea Atomic Energy Research Institute
Sweden                               Studsvik AB




                                          Page 83                                               GAO-03-638 Nuclear Nonproliferation
                                                                      Appendix VI
                                                                      Information on Producers and Distributors of
                                                                      Radioactive Material




(Continued From Previous Page)
Country                                                        Major organizations producing and/or distributing sources
United Kingdom                                                 Ametek Advanced Measurement Technology, Nycomed Amersham, and Reviss Services
                                                               Limited
United States                                                  Department of Energy
Uzbekistan                                                     Institute of Nuclear Physics
                                                                                                .
Sources: IAEA and Monterey Institute of International Studies Center for Nonproliferation Studies




                                                                      Page 84                                        GAO-03-638 Nuclear Nonproliferation
Appendix VII

The Nuclear Regulatory Commission’s Policy
on Exports of Sealed Sources                                                                             Append
                                                                                                              x
                                                                                                              iVI




               In most cases, the Nuclear Regulatory Commission grants a general license
               for the export of sealed sources to all countries containing byproduct
               material except certain proscribed countries: Cuba, Iran, Iraq, Libya, North
               Korea, and Sudan. Byproduct material is (1) any radioactive material
               (except special nuclear material) yielded in, or made radioactive by,
               exposure to the radiation incident to the process of producing or using
               special nuclear material (as in a reactor) and (2) the tailings, or wastes
               produced by the extraction or concentration of uranium or thorium from
               ore.

               According to NRC, limited quantities of sealed sources can also be
               exported under a general license to “restricted” countries: Afghanistan,
               Andorra, Angola, Burma, Djibouti, India, Israel, Oman, Pakistan, and Syria.
               A general license, provided by regulation, grants authority to a person for
               certain activities, in this case, the export of sealed sources, and is effective
               without filing an application with NRC or the issuance of a licensing
               document to the person or organization exporting the sealed source. NRC
               has placed most sealed sources for export under a general license for
               several reasons, including the following: (1) subject to NRC or Agreement
               State1 oversight, the United States is responsible only for ensuring the safe
               use and control of radioactive materials used to manufacture sealed
               sources within U.S. territory; (2) foreign countries have the sovereign
               responsibility for ensuring appropriate regulatory controls over radioactive
               material, including such material imported from other countries; and
               (3) control over radioactive material would not be enhanced by requiring
               specific licenses for material exported from the United States. A specific
               license would not ensure that the exported materials would be subject to
               controls and regulatory oversight in a foreign country because the license
               does not ensure that the recipient country has adequate regulatory controls
               over the material that is exported from the United States. Under a specific
               license, the export request must be reviewed and approved by NRC in
               consultation with other appropriate agencies, including the Departments of
               Commerce, State, Defense, and Energy.

               NRC officials told us that they are required only to maintain a database of
               exports of sealed sources that are issued under a specific license and
               certain other exports of concern, such as americium-241 and neptunium-


               1
                A U.S. state that has signed an agreement with NRC under which the state regulates the use
               of by-product and other materials within that state. Currently, there are 32 U.S. Agreement
               States.




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The Nuclear Regulatory Commission’s Policy
on Exports of Sealed Sources




237. The United States, as a nuclear weapon state, has agreed to report all
exports of americium and neptunium to IAEA. With regard to shipments of
sealed sources, NRC officials told us that the Department of Homeland
Security’s Bureau of Customs and Border Protection maintains a database
of all transactions, identified by tariff number, including those including
sealed sources that are exported under a general license. However, these
officials also said that it would be very difficult for the Bureau of Customs
and Border Protection to track these specific shipments of sealed sources
because the information on manifests is general in nature.

NRC officials told us that they were not aware of any sealed sources that
were exported under a general license from the United States that have
been used for malicious purposes. They noted that there have been
thousands of such exports, most of which involve material in forms or
quantities that pose minimal safety or health risks if properly used and
controlled. However, there have been a few cases where lax local
regulatory oversight over high-risk materials resulted in instances where
sealed sources were eventually lost or improperly disposed of, resulting in
harmful exposure to individuals.

Specific licenses are required to export radioactive material in waste and
tritium for recovery and recycling purposes. This is because a final NRC
rule (59 F.R. 48994), effective November 10, 1994, revoked the general
license for bulk tritium and alpha-emitting radionuclides having an alpha
half-life of 10 days or greater but less than 200 years to conform NRC’s
regulations to the export control guidelines of the Nuclear Suppliers’
Group2 for nuclear-related, dual-use items. Tritium and reactor-produced
alpha-emitting radionuclides are two commodities on the Nuclear
Suppliers’ Groups dual-use list whose exports are regulated by NRC. In
addition, tritium and alpha-emitting radionucliedes are controlled by the
Nuclear Suppliers’ Group because of their potential application in the
production of weapons of mass destruction.

Another final rule on the import and export of radioactive material
(60 F.R. 37556), effective August 21, 1995, established specific licensing
requirements for the import and export of radioactive material in the form
of waste coming into or leaving the United States to conform with NRC’s


2
 The Nuclear Suppliers’ Group consists of 30 nuclear supplier countries and seeks to control
exports of nuclear materials, equipment, and technology, both dual-use and specially
designed and prepared.




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Appendix VII
The Nuclear Regulatory Commission’s Policy
on Exports of Sealed Sources




regulations to the guidelines of the IAEA Code of Practice on the
International Transboundary Movement of Radioactive Waste.

In view of increased post-September 11 terrorism concerns, NRC is
considering changes to its general license provisions to improve controls
over exports. Possible changes include (1) ensuring that the exporter
confirm that the customer in the foreign country is authorized by the
recipient country to possess the material; (2) requiring prior notification to
NRC for risk-significant shipments; and (3) as appropriate, providing
national or international source registries with data for risk-significant
shipments. Changes under consideration are expected to be implemented
in fiscal year 2004 by orders with compensatory measures and in fiscal
years 2004-2005 by a rule change as part of a broader NRC plan to improve
controls over the imports and exports of sealed sources. Other possible
and more restrictive controls for exports include a requirement for a
specific export license for high-risk material such as high-activity cobalt-60
sources or imposing a specific prohibition on such exports to countries
that do not have acceptable sealed source security, control, and
accountability requirements. The United States is coordinating these
efforts with other countries that export sealed sources to ensure
consistent, adequate controls. In addition, in conjunction with the change
of the national threat level to “orange” in March 2003, NRC issued a
security advisory to licensees concerning certain quantities of certain high-
risk sources, which included exports and imports.




Page 87                                       GAO-03-638 Nuclear Nonproliferation
Appendix VIII

Results of the International Conference on the
Security of Radioactive Sources                                                                  Appendx
                                                                                                       iI
                                                                                                       V




                This appendix provides information concerning several key findings and
                recommendations from the international conference on the security of
                radioactive sources held in Vienna, Austria, in March 2003. The conference
                was sponsored by the governments of the United States and the Russian
                Federation and hosted by the government of Austria. It was organized by
                IAEA in cooperation with the European Commission, the World Customs
                Organization, the International Criminal Police Organization, and the
                European Police Office. Over 700 delegates from more than 120 countries
                attended the conference.

                The conference produced key findings in the following areas:
                (1) identifying, searching for, recovering, and securing high-risk radioactive
                sources; (2) strengthening long-term control over radioactive sources;
                (3) interdicting illicit trafficking; (4) planning the response to radiological
                emergencies arising from the malevolent use of radioactive sources; and
                (5) recognizing the role of the media/public education, communication, and
                outreach.

                Regarding identifying and searching for sources, the conference
                encouraged countries to

                • develop and implement national action plans, on the basis of their own
                  specific conditions, for locating, searching for, recovering, and securing
                  high-risk radioactive sources;

                • accelerate the establishment of a coherent and transparent scheme for
                  the categorization of radioactive sources in order to provide for the
                  safety and security of sources; and

                • assist other countries, as appropriate, in identifying, searching for,
                  recovering, and securing high-risk sources.

                Concerning strengthening long-term control over radioactive sources, the
                conference encouraged countries to

                • formulate and implement national plans for the management of sources
                  throughout their life cycle;

                • develop, to the extent practical, standards for the design of sealed
                  sources and associated devices that are less suitable for malevolent use
                  (e.g., alternative technologies and less-dispersible forms of high-risk
                  sources); and



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Results of the International Conference on
the Security of Radioactive Sources




• establish arrangements for the safe and secure disposal of disused high-
  risk sources, including the development of disposal facilities.

Regarding illicit trafficking, the conference recognized the need for greater
international efforts to detect and interdict the illicit trafficking of high-risk
sources and to take appropriate enforcement actions. In support of this
objective, the conference encouraged countries to

• further develop and strengthen measures to detect, interdict, and
  respond to the illicit trafficking of high-risk radioactive sources;

• deploy and widely use technologies for detecting high-risk radioactive
  sources, with emphasis on ensuring the sustainability of monitoring and
  detection equipment;

• undertake further research on and development of detection
  technologies for use at borders and elsewhere;

• enhance cooperation between government agencies responsible for
  preventing, detecting, and responding to illicit trafficking incidents,
  especially in the fields of information sharing, communications, and
  training;

• pool resources through, for example, the sharing of monitoring and
  detection equipment on common borders; and

• continue support for and development of IAEA’s illicit trafficking
  database.

The conference recommended that countries develop comprehensive plans
to prepare for and respond to radiological emergencies involving
radioactive sources. In support of this recommendation, the conference
encouraged countries to, among other things,

• enhance current national and international response arrangements,
  taking into account the need to respond both proactively and reactively
  to the new scenarios presented by the possibility of the malevolent use
  of high-risk radioactive sources and

• consider establishing mechanisms to facilitate effective coordination in
  the event of a radiological emergency.




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Appendix VIII
Results of the International Conference on
the Security of Radioactive Sources




Finally, the conference recognized that the public’s understanding of the
nature and consequences of radiological emergencies will largely
determine how the public reacts to such emergencies. As a result, the
conference encouraged countries to

• conduct public outreach and awareness programs to foster a better
  understanding of radiological threats and the appropriate response in
  the event of a radiological emergency in order to minimize social and
  economic disruption;

• educate the public regarding the nature of radioactivity, the
  consequences of the malevolent uses of high-risk radioactive sources,
  and the procedures for mitigating those consequences in order to
  reduce the psychological impact of radiological terrorism;

• strengthen their education and training programs as a means to promote
  confidence building within the public; and

• assume greater responsibility for gaining the trust of the media and
  informing them about the potential threat of radiological terrorism to
  help ensure that the media will communicate information accurately in
  a nonsensational manner to avoid fueling public fear and panic.




Page 90                                      GAO-03-638 Nuclear Nonproliferation
Appendix IX

Information on IAEA’s Revised Categorization
of Radioactive Sources                                                                       Appendx
                                                                                                   IiX




               The purpose of IAEA’s Categorization of Radioactive Sources is to provide
               a fundamental and internationally harmonized basis for risk-informed
               decision making. The draft document provides a categorization for
               radioactive sources used in industry, medicine, agriculture, research, and
               education. The principles of the categorization can be equally applied to
               radioactive sources, such as radioisotope thermoelectric generators that
               may be under military control. The categorization does not apply to
               radiation-generating devices such as X-ray machines and particle
               accelerators, although it may be applied to radioactive sources produced
               by, or used as, target material in such devices. The revised categorization
               divides sources into five categories, according to their potential to cause
               harmful health effects, should the source not be managed safely and
               securely. The categories are defined as follows:

               • Category 1 sources are considered extremely dangerous. If not safely
                 managed safely, the radioactive material would likely cause permanent
                 injury to a person who handled it or were otherwise in contact with it
                 for more than a few minutes. It would probably be fatal to be close to
                 this amount of unshielded material for a period of a few minutes to an
                 hour. Furthermore, the amount of radioactive material, if dispersed by
                 fire or explosion, could possibly—but would be unlikely to—
                 permanently injure persons in the immediate vicinity or be life
                 threatening to them. There would be little or no risk of immediate heath
                 effects to persons beyond a few hundred meters. It would be highly
                 unlikely for a category 1 source to contaminate a public water supply to
                 dangerous levels, even if the radioactive material were highly soluble in
                 water.

               • Category 2 sources are also considered personally dangerous. If not
                 safely managed or securely protected, the radioactive material could
                 cause permanent injury to a person who handled it or were otherwise in
                 contact with it for a short time (minutes to hours). It could possibly be
                 fatal to be close to this amount of unshielded radioactive material for a
                 period of hours to days. The amount of radioactive material, if
                 dispersed by fire or explosion, could possibly—but would be very
                 unlikely to—permanently injure or be life threatening to persons in the
                 immediate vicinity. It would be virtually impossible for a category 2
                 source to contaminate a public water supply to dangerous levels, even if
                 the radioactive material were highly soluble in water.

               • Category 3 sources are also considered to be dangerous. If not safely
                 managed or securely protected, the radioactive material could cause



               Page 91                                     GAO-03-638 Nuclear Nonproliferation
Appendix IX
Information on IAEA’s Revised
Categorization of Radioactive Sources




   permanent injury to a person who handled it or were otherwise in
   contact with it, for some hours. It could possibly—although it is
   unlikely—be fatal to be in close contact to this amount of unshielded
   radioactive material for a period of days to weeks. The amount of
   radioactive material, if dispersed by fire or explosion, could possibly—
   but is extremely unlikely to—permanently injure or be life threatening
   to persons in the immediate vicinity. It would be virtually impossible for
   a category 3 source to contaminate a public water supply to dangerous
   levels, even if the radioactive material were highly soluble in water.

• Category 4 sources are unlikely to be dangerous. It is very unlikely that
  anyone would be permanently injured by this amount of radioactive
  material. This amount of radioactive material, if dispersed by fire or
  explosion, could not permanently injure persons.

• Category 5 sources are not considered dangerous. No one could be
  permanently injured by this amount of radioactive material.
  Furthermore, this amount of radioactive material, if dispersed by fire or
  explosion, could not permanently injure persons.

 IAEA has developed a list on the basis of practices (such as irradiators,
industrial radiography, and teletherapy) as part of its relative ranking of
sealed sources. Examples of the most dangerous (category 1) include
radioisotope thermoelectric generators, sterilization and food preservation
facilities containing cobalt-60 or cesium-137, and medical equipment
containing cobalt-60. The least dangerous (category 5) include low-dose-
rate brachytherapy devices and lightning detectors containing americium-
241.




Page 92                                      GAO-03-638 Nuclear Nonproliferation
Appendix X

Countries Participating in IAEA’s Model
Project Program                                                                                  Append
                                                                                                      x
                                                                                                      i
                                                                                                      X




               Table 11 provides a list of the countries participating in IAEA’s model
               project program and the year they joined the program.



               Table 11: Countries Participating in IAEA’s Model Project Program

               Country                                                   Year joined the program
               Albania                                                                       1996
               Algeria                                                                       2002
                         a
               Angola                                                                        2001
               Armenia                                                                       1996
               Azerbaijan                                                                    2003
               Bangladesh                                                                    1996
                             b
               Belarus                                                                       1996
               Benina                                                                        2003
               Bolivia                                                                       1996
               Bosnia and Herzegovina                                                        1996
               Bulgaria                                                                      2001
               Burkina Fasoa                                                                 2001
                                 a
               Cameroon                                                                      1996
               Central African Republica                                                     2003
               China                                                                         2001
               Columbia                                                                      1998
               Costa Rica                                                                    1996
               Croatia                                                                       2001
               Cyprus                                                                        1996
               Democratic Republic of the Congoa                                             1996
               Dominican Republic                                                            1996
               Ecuador                                                                       2000
               Egypt                                                                         2001
               El Salvador                                                                   1996
               Ethiopia                                                                      1996
               Estonia                                                                       1996
                         a
               Gabon                                                                         1996
               Georgia                                                                       1997
               Ghana                                                                         1996
               Guatemala                                                                     1996
               Haiti                                                                         1999
               Hungary                                                                       2001




               Page 93                                         GAO-03-638 Nuclear Nonproliferation
Appendix X
Countries Participating in IAEA’s Model
Project Program




(Continued From Previous Page)
Country                                             Year joined the program
Indonesia                                                               2001
Iran                                                                    2001
                a
Ivory Coast                                                             1996
Jamaica                                                                 1997
Jordan                                                                  1997
Kazakhstan                                                              1996
Kenya                                                                   2001
Kuwait                                                                  2001
Latvia                                                                  1996
Lebanon                                                                 1996
Libya                                                                   2001
Lithuania                                                               1996
Macedonia                                                               1996
Madagascar                                                              1996
Malaysia                                                                2001
Malia                                                                   1996
Malta                                                                   2001
Mauritiusa                                                              1996
Moldova                                                                 1996
Mongolia                                                                1996
Morocco                                                                 2001
Myanmar                                                                 1996
            a
Namibia                                                                 1996
Nicaragua                                                               1996
        a
Niger                                                                   1996
Nigeriaa                                                                1996
Pakistan                                                                2001
Panama                                                                  1996
Paraguay                                                                1996
Philippines                                                             2001
Portugal                                                                2001
Qatar                                                                   1996
Romania                                                                 2001
Saudi Arabia                                                            1996
            a
Senegal                                                                 1996
Sierra Leonea                                                           1996
Singapore                                                               2001




Page 94                                   GAO-03-638 Nuclear Nonproliferation
Appendix X
Countries Participating in IAEA’s Model
Project Program




(Continued From Previous Page)
Country                                                                 Year joined the program
Slovenia                                                                                     2001
South Africa                                                                                 2002
Sri Lanka                                                                                    1996
Sudan                                                                                        1996
Syria                                                                                        1997
Tajikistan                                                                                   2002
Tanzania                                                                                     2001
Thailand                                                                                     2001
Tunisia                                                                                      2001
Turkey                                                                                       2001
          a
Uganda                                                                                       1996
United Arab Emirates                                                                         1996
Uruguay                                                                                      2000
Uzbekistan                                                                                   1996
Venezuela                                                                                    2002
Vietnam                                                                                      1996
Yemen                                                                                        1996
Yugoslavia                                                                                   2003
Zambia                                                                                       2002
Zimbabwea                                                                                    1996
Source: IAEA.
a
These countries are participating only in milestones 1 and 2 of the model project program.
b
Belarus completed the program in 2000.




Page 95                                                    GAO-03-638 Nuclear Nonproliferation
Appendix XI

France’s System for Controlling Sealed
Sources                                                                                        Appendx
                                                                                                     iI
                                                                                                     X




               French officials told us that their system for controlling sealed sources has
               several key components, including stringent controls on the licensing and
               tracking of the sources. Distributors of devices containing sealed sources
               must be authorized to market such devices and must send monthly
               accounts of the movement of sources to the French government agency
               responsible for regulating sealed sources. End users must have a license
               covering each site where the sources are used, and the maximum duration
               of a license is 5 years. For items such as smoke detectors, the end user is
               not required to have a license, but the distributor must be licensed.
               Approximately 30,000 sources in use in France are tracked by the
               government, and there are nearly 5,000 licensees. This number does not
               include very small sources like iodine grains used for medical purposes
               (there are about 80,000 such sources) and smoke detectors (for 400,000
               buildings), which are exempt from licensing requirements for end users.

               Sealed sources are subject to an annual inspection, and the end user pays
               for the inspections. The fee is a function of the number of sealed sources
               owned by the licensee. The inspection is designed to confirm that the
               sealed sources are properly accounted for, adequately secured, and safely
               used. In order to renew a license, the licensing agency must be provided
               with documentation of the annual inspections. If the end user is not
               inspected, it is subject to fines and may also be fined if the inspection
               shows that it is not adequately protecting devices containing sealed
               sources. Fines are based on health and safety infractions—not security
               violations—and the fines can be as high as about $15,000.

               France has also established a system to control orphan sources that has
               three main components.

               • End users are required to remove any source from service not more than
                 10 years after it was purchased.

               • The company supplying the source to the end user is required to include
                 disposal costs within the purchase price.

               • All other companies in the supply chain agree contractually to take back
                 the source after 10 years.

               Under France’s system, the company supplying—or distributing—the
               sealed source is required to ensure, through a financial guarantee, that
               funds will be available to pay for the disposal of the source in case the
               distributor goes out of business or files for bankruptcy. The financial



               Page 96                                       GAO-03-638 Nuclear Nonproliferation
Appendix XI
France’s System for Controlling Sealed
Sources




guarantee is made either through an annual fee paid to an association of
source distributors or by providing France’s national waste management
agency with a deposit. The association represents 99 percent of all
distributors of devices containing sealed sources in France. About 50
distributors are members of the association. Typically, the distributor
makes an initial deposit of about $1,000 and then pays an annual fee on the
basis of the total activity of sources it has distributed, the technology that
the sealed sources are used for, and the value of the source. French
officials responsible for administering the system told us that, initially,
distributors did not like it because of the excessive amount of paper work
involved. However, companies now see the value of the system.

Distributors also have the option of contracting with France’s radioactive
waste management agency for disposal of the sources if they do not want
to join the association. Typically, the smaller distributors who choose this
option do so because they may only supply one or two sources per year and
do not want to share the risk of joining the larger association, where costs
are spread among many distributors. Distributors who choose this option
are required to deposit funds with the agency to guarantee that disposal
costs will be covered. The deposit ranges from about $1,000 to several
thousand dollars. When a source is returned, the agency returns the
deposit (less an administrative fee) to the distributor. According to French
officials, only 1 percent of the distributors of sources in France use this
option because they believe it is more expensive than belonging to the
association, which spreads the financial risk among all of its members. In
addition, the cost determined by the waste management agency is based on
the entire cost of disposal and takes into account inflation and other
economic factors. To date, the waste management agency has not had to
use the fund to dispose of any disused sealed sources. The agency has
always been able to locate a source’s manufacturer to take back the source
or find another manufacturer willing to accept it.

According to French officials, when the system was first put into place, it
posed a difficulty for distributors, who had to pass the cost of the financial
guarantee to the end user. However, now that the system has been in place
for many years, the additional costs are accepted, and users are pleased not
to have to deal with disposing of the sources on their own. We were told
that the process works well and has contributed to the reduction in the
number of lost, stolen, or abandoned sealed sources. Currently, about one
sealed source per year is orphaned in France.




Page 97                                       GAO-03-638 Nuclear Nonproliferation
Appendix XII

Comments from the Department of Energy                          Append
                                                                     x
                                                                     iI
                                                                     X




               Page 98        GAO-03-638 Nuclear Nonproliferation
Appendix XIII

Comments from the Department of State                           Append
                                                                     x
                                                                     iI
                                                                     X




                Page 99       GAO-03-638 Nuclear Nonproliferation
Appendix XIII
Comments from the Department of State




Page 100                                GAO-03-638 Nuclear Nonproliferation
Appendix XIII
Comments from the Department of State




Page 101                                GAO-03-638 Nuclear Nonproliferation
Appendix XIV

Comments from the Nuclear Regulatory
Commission                                                      Append
                                                                     x
                                                                     iIV
                                                                     X




               Page 102       GAO-03-638 Nuclear Nonproliferation
Appendix XIV
Comments from the Nuclear Regulatory
Commission




Page 103                               GAO-03-638 Nuclear Nonproliferation
Appendix XV

GAO Contacts and Staff Acknowledgments                                                        Appendx
                                                                                                    iV
                                                                                                    X




GAO Contact       Gene Aloise (202) 512-3841



Acknowledgments   In addition to the individual named above, Kerry Dugan Hawranek, Preston
                  S. Heard, Glen Levis, Judy K. Pagano, Terry L. Richardson, and Rebecca
                  Shea also made key contributions to this report.




(360199)          Page 104                                  GAO-03-638 Nuclear Nonproliferation
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