DHS OIG, OIG-25-27, CBP's Detection Capabilities at U.S. Ports of Entry Risk Missing Contraband - (REDACTED) (2025)

LAW ENFORCEMENT SENSITIVE OIG-25-27 FINAL REPORT June 16, 2025 CBP's Detection Capabilities at U.S. Ports of Entry Risk Missing Contraband (REDACTED) WARNING: This document is Law Enforcement Sensitive (LES). Do not distribute or copy this report without the expressed written consent of the Office of Inspector General. LAW ENFORCEMENT SENSITIVE LAW ENFORCE~ffiNT SENSITPlE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Washington, DC 20528 I www.oig.dhs.gov June 16, 2025 MEMORANDUM FOR: Pete Flores Senior Official Performing the Duties of the Commissioner U.S. Customs and Border Protection FROM: SUBJECT: Joseph V. Cuffari, Ph.D. JOSEPH V CUFFARI Inspector General Digitally signed by JOSEPH V CUFFARI Date: 202s.06.16 17:30:36 -04'00' CBP's Detection Capabilities at U.S. Ports of Entry Risk Missing Contraband Law EnfefCeFFieRt SeR-sitibre Attached for your action is our final report, CBP's Detection Capabilities at U.S. Ports of Entry Risk Missing Contraband - Law E-RfercemeRt SeR-sitib'€ provided by your office. . We incorporated the formal comments The report contains four recommendations aimed to improve CBP's use of large-scale NII systems.

Based on the information provided in your response to the draft report, we consider recommendation 1 open and unresolved. As prescribed by Department of Homeland Security Directive 077-01, Follow-Up and Resolutions for the Office of Inspector General Report Recommendations, within 90 days of the date of this memorandum, please provide our office with a written response that includes your (1) agreement or disagreement, (2) corrective action plan, and (3) target completion date for the recommendation. Also, please include responsible parties and any other supporting documentation necessary to inform us about the current status of the recommendation. Until your response is received and evaluated, the recommendation will be considered open and unresolved.

Based on information provided in your response to the draft report, we consider recommendations 2 through 4 open and resolved. Once your office has fully implemented recommendations, please submit a formal closeout letter to us within 30 days so that we may close the recommendations. The memorandum should be accompanied by evidence of completion of agreed-upon corrective actions. Please send your response or closure request to [email protected].

Consistent with our responsibility under the Inspector General Act, we will provide copies of our report to congressional committees with oversight and appropriation responsibility over the Department of Homeland Security. We will post the report on our website for public dissemination. OIG Project No. 23-046-AUD-CBP LAW ENFORCE~T SENSITPlE LAW ENFORCE~ffiNT SENSITPlE Please contact me with any questions, or your staff may contact Craig Adelman, Deputy Inspector General for Audits, at (202) 981-6000. Attachment Office of Inspector General U.S. Department of Homeland Security I Washington, DC 20528 I www.oig.dhs.gov 2 LAW E-WORCE~OOJT SE~JSITPlE DHS OIG HIGHLIGHTS CBP’s Detection Capabilities at U.S. Ports of Entry Risk Missing Contraband June 16, 2025 Why We Did This Audit Illicit fentanyl, a type of contraband, is one of the top threats facing our country.

CBP is the largest law enforcement agency in the United States, making it uniquely positioned to detect, identify, and seize contraband, e.g., weapons and narcotics such as fentanyl. CBP’s Office of Field Operations uses large- scale NII systems during inspections at ports of entry to help detect anomalies, which can lead to seizures of contraband, including fentanyl. We conducted this audit to determine the extent to which CBP’s Office of Field Operation’s large- scale NII systems improve detection of contraband. What We Recommend We made four recommendations to improve CBP’s use of large-scale NII systems.

For Further Information: Contact our Office of Public Affairs at (202) 981-6000, or email us at: [email protected]. What We Found U.S. Customs and Border Protection (CBP) did not fully leverage its large-scale non-intrusive inspection (NII) systems to detect contraband coming into the United States, potentially wasting taxpayer funds, missing opportunities to detect and seize contraband, and losing an important tool to fight the fentanyl epidemic. • CBP did not fully or effectively deploy large-scale NII systems. CBP purchased 150 fixed large-scale NII systems from 2020 through 2024 but deployed and installed only 50 (33 percent) of these at ports of entry across the country. Of the other 100 systems, 21 were deployed but not installed, 31 were being built and awaiting delivery, and 43 — valued at over $96 million — were in storage.

CBP could not provide the status of five NII systems. • Many NII systems installed at ports of entry were not operational. At the time of our review, CBP had deployed and installed 361 large-scale NII systems. We found that 166 (46 percent) of installed large-scale NII systems were inoperable between fiscal years 2019 and 2023, in some cases for up to 344 days, while awaiting repair. CBP officers also did not record accurate data on the utilization and operability of the large-scale NII systems.

We found that CBP did not effectively plan and manage the large-scale NII program, which led to the identified deficiencies. CBP did not follow Department of Homeland Security acquisition policy, did not consider relevant information during planning, and did not have a well-defined maintenance and sustainment plan for large-scale NII systems. CBP Response CBP concurred with all four recommendations. Appendix B contains CBP’s response in its entirety. www.oig.dhs.gov OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Table of Contents Background ..........................................................................................................................................

1 NII Program .............................................................................................................................. 2 Results of Audit .................................................................................................................................... 4 CBP Did Not Effectively Deploy Large-Scale NII Systems ....................................................... 4 Installed Large-Scale NII Systems Were Not Operational for Extended Periods...................

7 CBP Does Not Have Reliable Data on Large-Scale NII System Performance......................... 9 CBP Did Not Effectively Plan and Manage the Large-Scale NII Program ............................. 10 Conclusion.......................................................................................................................................... 13 Recommendations.............................................................................................................................

14 Management Comments and OIG Analysis....................................................................................... 14 Appendix A: Objective, Scope, and Methodology ............................................................................. 17 DHS OIG’s Access to DHS Information................................................................................... 18 Appendix B: CBP Comments on the Draft Report .............................................................................

19 Appendix C: Port of Entry Inspection Process Using NII System...................................................... 23 Appendix D: Report Distribution........................................................................................................ 24 Abbreviations CBP ETAP OFO NII U.S. Customs and Border Protection Equipment Transactional Analysis Platform Office of Field Operations non-intrusive inspection www.oig.dhs.gov OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Background The United States has experienced an unprecedented overdose epidemic from fentanyl and other illicit drugs. Since 2019, fentanyl overdoses have been the leading cause of death for Americans aged 18 to 45, making the drug a top threat facing our Nation.

In April 2022, the White House Office of National Drug Control Policy released the National Drug Control Strategy, which called for a whole-of-government approach to combat the drug overdose epidemic. The Strategy focused on two drivers of the epidemic: untreated addiction and drug trafficking. The Strategy instructed Federal agencies to prioritize actions to address the epidemic. DHS Operations to Combat Fentanyl Operation Blue Lotus, launched in March 2023, surged CBP and Homeland Security Investigations resources to the Southwest border ports of entry to increase targeted inspections conducted by officers and agents, canine units, and advanced technology.

Blue Lotus 2.0, launched 3 months later, leveraged the intelligence and investigative information derived from the original operation. Operation Four Horsemen, launched in March 2023, was a complementary United States Border Patrol operation to Operation Blue Lotus to stop fentanyl between ports of entry and at checkpoints near the border. Operation Artemis, launched in June 2023, was led by CBP with support from Homeland Security Investigations and targeted the fentanyl supply chain, including items required in the production of fentanyl. Operation Rolling Wave, launched in June 2023, surged inbound inspections at Southwest border checkpoints.

Operation Apollo, launched in October 2023 in Southern California, gathered intelligence on the logistics and routes transnational criminals use to traffic fentanyl into the country. Operation Plaza Spike, launched in April 2024, targeted transnational criminals funneling fentanyl from Mexico. “Plazas” are cartel territories directly south of the United States. Accordingly, the Department of Homeland Security developed several departmental strategies.

For example, in September 2023, U.S. Immigration and Customs Enforcement’s Homeland Security Investigations directorate released its Strategy for Combating Illicit Opioids, described as an intelligence-driven approach to disrupting and dismantling transnational criminal organizations and keeping dangerous substances such as illicit fentanyl off America’s streets. U.S. Customs and Border Protection (CBP) released its CBP Strategy to Combat Fentanyl and Other Synthetic Drugs in October 2023, which listed four goals, one of which is to “conduct coordinated and unified intelligence and data- driven operations to target the production, trafficking, and distribution of illicit synthetic materials.” CBP, supported by Homeland Security Investigations and other DHS entities, has led several surge operations — Blue Lotus, Four Horsemen, Artemis, Rolling Wave, Apollo, and Plaza Spike — to target and prevent fentanyl and its precursor chemicals from entering the country. CBP’s strategy also calls for using non- intrusive inspection (NII) technology to improve www.oig.dhs.gov 1 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security its drug detection capabilities and stop fentanyl from being smuggled through the Nation’s ports of entry. CBP is the largest law enforcement agency in the United States.

Its Office of Field Operations (OFO) is responsible for America’s border security at ports of entry, safeguarding the country and communities from terrorism, illegal activity, narcotics, and human trafficking. To execute the CBP Strategy to Combat Fentanyl and Other Synthetic Drugs, CBP OFO leverages NII technology. According to CBP OFO, it seized 18,900 pounds of fentanyl in fiscal year 2024, nearly doubling the 10,183 pounds of fentanyl it seized in FY 2021. NII Program NII is one tool CBP uses to screen for and detect contraband, including fentanyl and other illicit drugs.1 Small- and large-scale NII systems — including fixed, mobile, and handheld technologies and sensors — use x-ray or gamma ray technology to detect anomalies concealed in vehicles, railcars, cargo containers, luggage, packages, and mail.

Small-scale NII systems include those used to examine individual travelers, cargo components, mail, baggage, or similarly sized objects. Large-scale NII systems include high-energy railcar scanning systems and low- and multi-energy portal systems that scan vehicles and cargo,2 which allow CBP officers to examine vehicles and cargo for contraband without physically opening or unloading them.3 Figure 1 shows types of large-scale NII systems currently used at ports of entry. Figure 1. Types of Large-Scale NII Systems Low-Energy Portal System Multi-Energy Portal System High-Energy Railcar Scanning System Source: Photos taken by DHS Office of Inspector General at the Bridge of the Americas port of entry in El Paso, Texas (left); the Santa Teresa, New Mexico port of entry (center); and the Nogales, Arizona port of entry (right).

1 Other tools include canines in the inspection process. 2 A high-energy railcar scanning system can inspect the contents of rail cargo containers. A low-energy portal system is a drive-through system that can scan passenger vehicles moving more than 5 miles per hour. A multi-energy portal system uses x-rays to provide detailed images of commercial trucks and cargo container contents.

3 According to its FY 2025 Budget Justification, CBP uses large-scale NII systems to examine vehicles and cargo for contraband in as little as 8 minutes, versus 120 minutes for a physical exam. www.oig.dhs.gov OIG-25-27 2 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security CBP OFO’s inspection process begins when vehicles (or railcars) enter the United States at a port of entry.4 When the vehicles or railcars are scanned using large-scale NII systems, CBP officers analyze the resulting images to identify anomalies. Figure 2 shows examples of images resulting from scans performed by large-scale NII systems. If CBP officers determine additional inspection is needed, they will refer the vehicle to secondary inspection. See Appendix C for further details on the inspection process.

Figure 2. Images Resulting from Large-Scale NII System Scans Source: Photos taken by DHS OIG of images scanned by CBP officers using large-scale NII systems at the Tornillo, Texas port of entry (left); Brownsville, Texas port of entry (center); and Bridge of Americas port of entry in El Paso, Texas (right). Prior to CBP’s creation in 2003, processing people and goods at ports of entry was the responsibility of the U.S. Customs Service. In 1995, the U.S. Customs Service developed a 5-year Technology Acquisition Plan for the Southern Tier of the United States to address the increasingly sophisticated techniques drug-smuggling organizations used to conceal narcotics within commercial vehicles and cargo.

This plan included acquiring and deploying large-scale NII systems, the first of which — a truck x-ray system — was deployed at the Otay Mesa, California port of entry in September 1996. In FY 2019, Congress appropriated $570 million for NII systems at land ports of entry.5 From 2020 through 2024, CBP purchased 150 large-scale NII systems6 from four contractors. According to CBP’s timeline, CBP will continue to deploy NII systems with funds from FY 2019 and subsequent appropriations ($199 million) through 2029. CBP’s NII program has grown into a significant investment; it currently has an estimated lifecycle cost (costs of procurement, installation, training, maintenance, decommission, and disposal) of over $6.9 billion.

4 The Border Patrol also uses large-scale NII systems at checkpoints to scan vehicles. Checkpoints are locations set up by the Border Patrol between ports of entry. At checkpoints, Border Patrol agents can screen vehicles and question individuals to verify their immigration status. 5 Consolidated Appropriations Act, 2019 (Public Law 116-6).

6 CBP also purchased seven mobile large-scale NII systems during this time. We did not include those in the scope of this review. www.oig.dhs.gov OIG-25-27 3 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security In September 2020, DHS OIG issued a report, CBP Does Not Have a Comprehensive Strategy for Meeting Its [Large-Scale] NII Needs (OIG-20-75), in which we noted that CBP’s acquisition plans for its large-scale NII program included inconsistent information and did not align with the program’s approved lifecycle cost estimate. We also noted that the equipment CBP purchased may not have met the component’s mission needs. We concluded that these deficiencies occurred because officials did not provide effective oversight of CBP’s acquisition planning efforts.

The three recommendations we made to address the deficiencies have since been closed and resolved. We conducted this audit to determine the extent to which CBP OFO’s large-scale NII systems improve detection of contraband. Results of Audit CBP did not fully leverage its large-scale NII systems to detect contraband coming into the United States, potentially wasting taxpayer funds, missing opportunities to detect and seize contraband, and losing an important tool to fight the fentanyl epidemic. • CBP did not fully or effectively deploy large-scale NII systems. CBP purchased 150 fixed large- scale NII systems from 2020 through 2024, but deployed and installed only 50 (33 percent) of these at ports of entry across the country.

Of the remaining 100 systems, 21 were deployed but not installed, 31 were being built and awaiting delivery, and 43 (29 percent) — valued at over $96 million — were in storage. CBP could not provide the status of five NII systems. • Many NII systems installed at ports of entry were not operational. At the time of our review, CBP had deployed and installed 361 large-scale NII systems. We reviewed work orders submitted from FYs 2019 through 2023 and found that 166 (46 percent) large-scale NII systems were inoperable, in some cases up to 344 days, while awaiting repair.

CBP officers also did not record accurate data on the utilization and operability of the large-scale NII systems. We found that CBP did not effectively plan and manage the large-scale NII program, which led to the identified deficiencies. CBP did not follow DHS acquisition policy, did not consider relevant information during planning, and did not have a well-defined maintenance and sustainment plan for its large-scale NII systems. CBP Did Not Effectively Deploy Large-Scale NII Systems From 2020 through 2024, CBP purchased 150 fixed large-scale NII systems from four contractors to screen for and detect contraband, including fentanyl and other illicit drugs at land ports of entry across the country.

The 150 systems include 90 low-energy portals, 43 multi-energy portals, and 17 high-energy rail systems. www.oig.dhs.gov 4 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Figure 3. Large-Scale NII Systems Purchased by CBP At the time of our review, 50 systems had been deployed and installed at the ports of entry, 21 systems had been deployed but not yet installed at the ports of entry, 31 systems were being built and awaiting delivery from the contractor, and 43 systems were in storage. CBP could not provide the status of five high- energy rail systems (see Figure 3). Almost 30 Percent of Large-Scale NII Systems Purchased Were in Storage Of the 150 large-scale NII systems CBP purchased between 2020 and 2024, 43 (29 percent) — valued at over $96 million — remained in storage at various locations, as shown in Table 1.

Source: DHS OIG analysis of CBP data Table 1. Fixed Large-Scale NII Systems in Storage, as of December 31, 2024 Type Low-energy portal Low-energy portal Multi-energy portal Multi-energy portal Multi-energy portal Multi-energy portal Multi-energy portal High-energy rail system High-energy rail system High-energy rail system High-energy rail system High-energy rail system High-energy rail system Quantity 12 5 Total Value $14,369,172 $5,573,860 Average Days in Storage 392 19 5 3 3 3 2 3 3 1 1 1 1 $19,063,508 $9,925,000 $8,692,800 $4,877,400 $6,550,000 $7,020,000 $5,850,000 $2,340,000 $3,550,032 $3,550,032 $4,655,782 422 153 214 153 731 1,430 611 1,430 61 1,127 1,249 Total 43 $96,017,586 N/A N/A Source: Generated by DHS OIG based on data provided by CBP and contractors 7 The contractor providing three multi-energy portal systems has a facility in were in storage waiting to be deployed and installed. www.oig.dhs.gov 5 LAW ENFORCEMENT SENSITIVE . These systems OIG-25-27 LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security CBP has been unable to deploy these systems for reasons such as radiation portal monitor interference, insufficient funding, and difficulties obtaining land lease agreements. • Two multi-energy portals stored in the contractor’s facility in , for 731 days have not been deployed to the their installation would interfere with the operations of the radiation portal monitors8 at the port of entry. Radiation portal monitor interference occurs when a nearby large-scale NII system, like those we examined in this report, disrupts the normal operation of a radiation portal monitor, causing false alarms or inaccurate readings.

According to a site survey conducted by Pacific Northwest National Laboratories in October 2020,9 radiation portal interference would need to be mitigated at the before the multi-energy NII systems could be deployed. port of entry because port of entry • Three high-energy rail systems stored in , for an average of 611 days have not been deployed because of a lack of funding. According to CBP’s contractor, “CBP grossly underestimated the cost for site preparation and installation” for these systems. CBP initially estimated that it would need $4.4 million to prepare and install these systems. However, the contractor estimated the cost will total approximately $47.4 million — nearly 11 times CBP’s estimate.

Because the site preparation and installation costs exceed CBP’s initial estimates, deployment of these systems is delayed until CBP receives additional funding. • One high-energy rail system stored at the port of entry for 1,127 days, has not been deployed to the difficulties securing a land lease agreement with the railroad company. High-energy rail systems are installed on land owned by private companies, which requires a land lease agreement. According to a CBP official, the component is navigating through the railroad companies’ complex bureaucracy and compliance requirements to finalize land lease agreements. Figure 4 shows the containers storing the high-energy rail system. port of entry because of 8 A radiation portal monitor is a detection device that provides a passive, non-intrusive means to screen trucks and other vehicles for the presence of nuclear and radiological materials.

CBP uses radiation portal monitors at the ports of entry in conjunction with NII systems to help detect radiological materials entering the country. 9 Pacific Northwest National Laboratories is a federally funded research and development center contracted by DHS to help with the deployment of radiation detection technology at ports of entry. www.oig.dhs.gov OIG-25-27 6 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Figure 4. High-Energy Rail NII System in Storage at the Entry Port of Source: Photo taken by DHS OIG on November 19, 2024 More Than 30 Percent of Large-Scale NII Systems Purchased Were Not Yet Installed or Delivered CBP deployed 21 systems that had not yet been installed at the ports of entry. According to CBP, site installation and testing need to be completed before a system can become operational.

In addition, contractors were still building 31 systems that CBP purchased for delivery once completed. Although CBP originally estimated that all 150 large-scale NII systems would be fully deployed by the end of FY 2025, it now estimates complete deployment by the end of FY 2029. According to the contractors’ estimates, it will cost CBP $386 million to fully deploy all 150 systems. Installed Large-Scale NII Systems Were Not Operational for Extended Periods At the time of our review, CBP had deployed and installed 361 large-scale NII systems at ports of entry along the Southwest border because, according to CBP, fentanyl enters the United States primarily through the land ports of entry along the Southwest border.

We found that many of these systems were not operational for extended periods of up to 1 year and CBP did not ensure contractors met requirements for maintenance and sustainability. We found that 166 (46 percent) of installed large-scale NII systems were not operational for 400,369 cumulative hours, based on a review of 22,270 work orders that the ports of entry submitted to the Maintenance Dispatch Center from FY 2019 to FY 2023.10 Work orders included requests for repairs to the systems’ motor, engine light, and software, among other parts. Table 2 shows examples of large-scale NII systems with a high number of nonoperational cumulative hours. 10 To determine the duration that a large-scale NII system was not operational, we evaluated work order reports for 200 large-scale NII systems at the Southwest border from FY 2019 through FY 2023.

The reports were provided by CBP’s Integrated Logistics Division’s Asset Management System. www.oig.dhs.gov 7 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Table 2. Select Large-Scale NII Sites with Extended Non-Operational Periods Days Not Operational 201 264 173 344 83 Year 2023 2022 2021 2020 2019 Source: DHS OIG review of work orders, FY 2019 to FY 2023 Figure 5. Low-Energy Portals at the Port of Entry Source: Photo taken by DHS OIG on December 7, 2023 port Three low-energy portals at the of entry — which cost $32 million to procure and deploy — have not been operational since June 2023. Since their deployment, the port of entry has submitted 135 work orders identifying issues with the portals’ communication system, image quality, and x-ray system.

Because of these issues, CBP decided to decommission the three low-energy portals (pictured in Figure 5) and replace them in the future. Port leadership stated that they rely on their primary officers and canine teams to determine if any vehicles should be referred for secondary inspection. CBP did not ensure its contractors met specific requirements with respect to sustainment and maintenance for large-scale NII systems, as defined in the contract. For example, the contractors must: • Ensure operational availability (i.e., the percentage of time during the reporting period that the system is available to support the operations for which it was designed) 95 percent of the time.

To reach that goal, the contracts state that “the Contractor shall provide all the required support services, repair parts, hardware, software, firmware, test equipment, and supplies to maintain the system, booth, and shelters to meet the target performance metrics for the operational needs of CBP.” • “… respond onsite and restore down systems to a satisfactory Equipment Operational Status within the required Customer Wait Time,” which is 24 hours according to the contracts. www.oig.dhs.gov 8 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security CBP Does Not Have Reliable Data on Large-Scale NII System Performance CBP requires its officers to track daily large-scale NII system utilization in the Equipment Transactional Analysis Platform (ETAP). Per CBP Directive No. 3340-036A, Non-Intrusive Inspection (NII) Technology, dated July 2, 2015, officers must enter the utilization data at the conclusion of their shift or at the end of daily operations, and port supervisors must review the data entry. According to the Equipment Transactional Analysis Platform User Manual, officers record the port/station where the system was used, number of vehicles scanned each day; date the large- scale NII system was used; and seizures associated with the NII system. We found inconsistencies with ETAP’s utilization data.

For example, we found 42 instances in which the number of vehicle scans recorded in ETAP were greater than the number of vehicles that reportedly crossed through the port of entry during a month’s timeframe. • In December 2022, the crossing in its low-energy portals scanned 134,410 vehicles.11 However, the vehicle scanning reporting system12 registered only 31,776 vehicle crossings during that month. , recorded in ETAP that • Officers at the port of entry recorded that more than 217,000 vehicles were scanned on March 25, 2022, by a single low-energy portal when the portal typically averages 242 scans per day.13 • We found that 600,000 vehicle scans recorded in ETAP did not include the location of the port of entry or station where the scans were taken. ETAP’s data on operational interruptions was also unreliable. In addition to requiring officers to record utilization data, the ETAP user manual requires officers to record when a large-scale NII system is not being used. The manual requires officers to document operational interruptions, including the date and time the systems became inoperable, the reasons for the operational interruptions, and the date and time the systems became operable again.

The ETAP database includes a dropdown menu with common categories and reasons for operational interruptions for the officers to select. The categories available in ETAP include closed, COVID-19, idle time, personnel, pm/upgrade, and system problem. The reasons available in ETAP include daily maintenance, power outage, repairs, semiannual maintenance, staffing, system upgrades, traffic flow problems, training, and weather. If the operational interruption 11 We compared port of entry traffic counts to large-scale NII system scan rates to obtain the traffic volume at ports of entry along the Southwest border.

12 The BorderStat Operations Management Reporting system provides a monthly summary of operational traffic data at the national, field office, port, and site levels. 13 We conducted an analysis for this low-energy portal based on data captured in ETAP and found that the system averaged 242 scans per day across 345 days reported. www.oig.dhs.gov OIG-25-27 9 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security occurred for other reasons, ETAP allows the officer to select a field labeled “other” and manually enter the reason. CBP officers recorded 508 instances of operational interruptions in ETAP between FY 2019 and FY 2023. Within those records, information on the duration of the operational interruptions and the reasons for the interruptions was incomplete. • 32 percent (161) of records contained no data in the “category” field; • 27 percent (136) of records showed the same date and time for the start and end of the operational interruptions; • 3 percent (13) of records contained no data in the reason field;14 and • 2 percent (12) of records had no time entered.

In addition, during our site visits, CBP officers stated that NII systems were not operational because the ports of entry did not have enough trained officers to operate them. According to CBP’s policy, each location must have at least two trained individuals to operate large-scale imaging systems. • At the port of entry in CBP officers stated they could not use their NII system for 8 days because they did not have enough trained officers. • At the port of entry, CBP officers also stated that they were unable to use one of their large-scale NII systems due to a lack of training. Although ETAP provides “training” as one of the common reasons for an operational interruption, it is unclear whether this reason relates to untrained staff or whether it refers to staff in training. Of the 508 records reviewed, we were only able to identify one instance in which CBP manually recorded the reason for the interruption as “certified personnel.” In this instance, the record in ETAP indicated the interruption lasted for 1 hour.

CBP Did Not Effectively Plan and Manage the Large-Scale NII Program The deficiencies we identified occurred because CBP did not effectively plan and manage the large-scale NII program. Although CBP took actions to implement the recommendations we made in our 2020 report, CBP Does Not Have a Comprehensive Strategy for Meeting Its [Large-Scale] NII Needs (OIG-20-75), challenges remain. 14 For the remaining 495 instances, officers selected the following reasons for the operational interruptions, which were not consistent and had no defined explanations: 129 for staffing; 109 for system upgrades; 107 for repairs; 59 for weather (lightning); 27 for x-ray systems; 27 for closed; 19 for other with descriptions such as damaged system, system issues, mechanical failures, and connection problems; 3 for daily maintenance; 2 for power outages that the notes described as calibration issues; 2 for detectors; 2 for holiday, which the notes described as a Mexican holiday; 2 for monthly maintenance; 2 for traffic flow problems; 2 for training; 1 for semiannual maintenance; 1 for truck; and 1 for video system. www.oig.dhs.gov OIG-25-27 10 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security CBP Did Not Have a Deployment Plan for Its Large-Scale NII Systems CBP was unable to deploy the large-scale NII systems it purchased, in part, because it did not follow Department policy and develop a deployment plan. According to DHS’ acquisition policy, “deployment planning is especially critical for new vessels, aircraft, or systems where facilities or infrastructure may require upgrades, new leasing, or construction.”15 The policy requires CBP to develop a deployment plan before purchasing large-scale NII systems, and it states that a deployment plan must include information on the resources needed to operate and sustain the new system when it arrives at the port of entry.

Per DHS’ acquisition policy, a deployment plan contains the following: • overall costs and resources needed at each site for deployment (such as hardware, software, facilities, materials, training, and personnel); • deployment strategy; • brief description of the major activities involved in the deployment; • deployment/installation schedule, including a schedule of activities to be accomplished; • brief overview of the assets being deployed; and • organizations, roles, and responsibilities associated with the deployment process. CBP OFO officials cited several challenges in developing the deployment plan for the large-scale NII systems. They stated that the way in which they deployed the systems was shaped by the following factors: • evolving lessons learned, the unique nature of the program, and funding availability; • legislative pressure to deploy systems to locations with minimal restrictions (e.g., larger ports that would not require radiation portal monitor interference mitigation strategies), allowing for faster implementation; • weather and site-specific challenges that introduced variables that could not be fully accounted for during testing and that required adjustments during deployment; and resource constraints that complicated the process, as the program lacked dedicated support to manage deployment efforts. • CBP also stated that these challenges led the component to make decisions based on immediate needs, rather than developing a structured, long-term plan. As a consequence of this unstructured and short-term planning, CBP needed to make unexpected modifications to the infrastructure at the ports of entry, further delaying and increasing cost of the deployment.

For example, a radiation shielding wall that cost approximately $2.1 million had to be built at the Brownsville, Texas port of entry to mitigate radiation portal monitor interference. 15 Systems Engineering Life Cycle (SELC) Guidebook, May 2021, DHS Office of Program Accountability and Risk Management. www.oig.dhs.gov 11 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security CBP Did Not Consider Relevant Information During Planning CBP also was unable to deploy the large-scale NII systems it purchased because it did not consider relevant information during the planning phase of the acquisition. In October 2020, Pacific Northwest National Laboratory conducted a site survey of the port of entry to determine the feasibility of deploying low-energy portals. Pacific Northwest National Laboratory concluded that although the deployment of the systems would be “straightforward,” the port would need to relocate the radiation portal monitors to address issues with interference. port of entry for Site surveys of the deployments of other large-scale NII systems conducted in 2021 also noted radiation portal monitor interference as a challenge.

In these assessments, Pacific Northwest National Laboratory offered solutions including moving the radiation portal monitors further from the large-scale NII systems or using blanking (i.e., minimizing or removing the unintended radio frequency interference from pulsed x-ray radiation by using blanking pulses). According to CBP officials, large-scale NII deployment is critical and they are working through the system interference challenges. Officials noted that every port of entry is different, and the radiation portal monitors also differ from vendor to vendor which further complicates the interference mitigation process. CBP Did Not Adequately Oversee Large-Scale NII Maintenance Contracts Some large-scale NII systems were not operational, in part, because CBP did not have adequate oversight of its large-scale NII maintenance contracts.

Initial maintenance contracts for the systems we reviewed did not include language to allow CBP to hold the contractors accountable for not meeting sustainability and maintenance requirements. In October 2024, CBP modified the contracts for these systems to include language for accountability. CBP added the statement, “Operational Availability is imperative to the effective execution of CBP operations… [sic] To which longstanding and ineffective repairs shall have disincentives applied.” The maintenance contracts outlined three different types of disincentives that can be applied. 16 CBP experienced significant turnover of contracting officers and contracting officer’s representatives overseeing the large-scale NII maintenance contracts.

From 2018 to 2024, there were 13 different contracting officers and 14 different contracting officer’s representatives overseeing the four maintenance contracts. Table 3 shows, for example, that five different contracting officers and three different contracting officer’s representatives have been assigned to oversee contract 1. CBP officials stated that the turnover has been a challenge for oversight. 16 Per the contracts, fees will be assessed if, for example, the equipment drops below operational availability, if it is delivered late, or if additional funding is required because of failure to assess the nature and requirements of a project. www.oig.dhs.gov 12 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Table 3.

Contracting Officers and Contracting Officer’s Representatives Overseeing Large-Scale NII Maintenance Contracts Contract Contract 1 Contract 2 Contract 3 Contract 4 Total Contracting Officers 5 1 3 4 13 Contracting Officer’s Representatives 3 3 5 3 14 Source: DHS OIG analysis of contracting officers and contracting officer’s representatives for large-scale NII contracts CBP Does Not Have Sufficient Procedures for Recording Large-Scale NII Performance CBP does not have reliable data on large-scale NII systems’ utilization and operability, in part, because it does not have documented procedures for recording the utilization and downtime. Although CBP had an ETAP user manual, the manual does not have guidance for how supervisors should ensure that officers promptly and accurately enter utilization data. In addition, the user manual does not have sufficient guidance for officers to record the reasons for operational interruptions accurately and consistently. Although ETAP includes common reasons in a dropdown menu, the user manual does not define these reasons so that CBP officers can better select the most appropriate choice.

CBP’s Non-Intrusive Inspection Division receives utilization data from ETAP and uses this data to assess needs in the field relative to equipment locations. Non-Intrusive Inspection Division officials stated that their focus has been more on increasing the scan rates of large-scale NII systems to meet congressional requirements17 and less on evaluating and documenting large- scale NII performance. Further, the Non-Intrusive Inspection Division officials stated that they are developing an annual post-implementation review process that will examine the performance and utilization of each large-scale NII system deployed to a port of entry. Conclusion DHS stated that coordination and collaboration among components — as well as technology including large-scale NII systems — contributed to the successful operations that interdicted over 19,000 pounds of fentanyl and fentanyl precursors in 2023.18 When NII systems are not being used 17 In FY 2021, Congress passed the Securing America’s Ports Act, requiring CBP to develop a plan to increase vehicle scan rates to 100 percent using large-scale NII systems at each land port of entry by 2026.

18 According to DHS, Operation Blue Lotus resulted in the seizure of 4,721 pounds of fentanyl and 1,700 pounds of fentanyl precursors and the arrest of more than 200 alleged smugglers, traffickers, and dealers during 2 months in www.oig.dhs.gov 13 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security — either in warehouses, awaiting deployment, or awaiting repair — not only are funds potentially being wasted, but CBP misses opportunities to detect and seize contraband and loses an important tool in the fight against the fentanyl epidemic. Also, without reliable data on the utilization and operability of these large-scale NII systems, CBP is unable to measure the systems’ effectiveness and make informed decisions for the future of the NII program. Recommendations Recommendation 1: We recommend that the Executive Assistant Commissioner for the Office of Field Operations develop and implement a plan to deploy and install the large-scale non-intrusive inspection systems identified in this report. Recommendation 2: We recommend that the Executive Director of CBP’s Integrated Logistics Division develop and implement policies and procedures, as required by the modified maintenance contracts, to hold venders accountable by tracking and applying any disincentives for longstanding and ineffective repairs.

Recommendation 3: We recommend that the Executive Assistant Commissioner for the Office of Field Operations Non-Intrusive Inspection Division develop and implement guidance to ensure non-intrusive inspection utilization data is recorded in Office of Field Operations systems accurately to include equipment downtime. Recommendation 4: We recommend that the Executive Assistant Commissioner for the Office of Field Operations Non-Intrusive Inspection Division update guidance to ensure non-intrusive inspection operational interruption data recorded reflects the reasons for an operational disruption. Management Comments and OIG Analysis CBP provided management comments on a draft of this report. In its comments, CBP emphasized that NII systems are only one of multiple tools within its enforcement portfolio to detect and prevent contraband.

We acknowledge this fact and believe we captured it appropriately in the report. CBP concurred with all four recommendations. Appendix B contains CBP’s response in its entirety. CBP also provided technical comments to the draft, which we incorporated as appropriate.

We consider recommendation 1 open and unresolved and recommendations 2 thorough 4 open and resolved. A summary of CBP’s responses to the recommendations and our analysis follows. 2023. In the 4 months of Operation Artemis that same year, CBP reported that it made over 900 seizures, including over 13,000 pounds of fentanyl precursor chemicals. www.oig.dhs.gov 14 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security CBP’s Response to Recommendation 1: Concur.

The CBP OFO NII Program Management Office maintains and makes monthly updates to the Integrated Master Schedule, which CBP uses as a plan for deploying and implementing NII systems. CBP provided DHS OIG context on the Integrated Master Schedule deployment plan, including steps in the process for site surveys, designs, civil works, installation, testing, and various other activities to deploy and install large- scale NII systems. In February 2025, OFO also provided DHS OIG with documentation of existing deployment and installation plans. CBP requested that DHS OIG consider this recommendation as closed and resolved, as implemented.

OIG Analysis: Although CBP concurred with the recommendation, we do not consider CBP’s actions responsive to the recommendation. CBP’s schedule of NII deployment does not include overall costs and resources needed at each site for deployment (such as hardware, software, facilities, materials, training, and personnel); a deployment strategy; a brief description of the major activities involved in the deployment; a deployment/installation schedule, including a schedule of activities to be accomplished; and organizations, roles, and responsibilities associated with the deployment process, as required by DHS policy. DHS’ acquisition policy requires CBP to develop a deployment plan before purchasing large-scale NII systems. As noted in the report, CBP stated challenges led the component to make decisions based on immediate needs rather than developing a structed, long-term plan.

Accordingly, we consider the recommendation open and unresolved. We will close the recommendation when CBP provides documentation demonstrating that it has developed and implemented a plan to deploy and install the large-scale NII systems identified in this report. CBP’s Response to Recommendation 2: Concur. The Integrated Logistics Division, under CBP’s Enterprise Infrastructure and Operations Directorate, will develop and implement policies and procedures to track operational availability data and preventive maintenance data for each large- scale NII system monthly, per the vendor’s equipment list.

CBP’s Enterprise Infrastructure and Operations Directorate will also provide a list of non-performing equipment and late preventive maintenance to the appropriate contracting officer to apply disincentives to each monthly invoice through invoice modification. Estimated completion date: December 31, 2025. OIG Analysis: We consider the recommendation open and resolved. We will close the recommendation when CBP provides documentation demonstrating that it has developed and implemented policies and procedures, as required by the modified maintenance contracts, to hold venders accountable by tracking and applying any disincentives for longstanding and ineffective repairs.

CBP’s Response to Recommendation 3: Concur. The CBP OFO Non-Intrusive Inspection Division is considering which enterprise tools may be appropriate to consolidate system reporting. In the interim, CBP is addressing limitations to system data, such as adding new fields to existing systems and providing additional training and examinations for inputs to end users. Estimated completion date: January 30, 2026. www.oig.dhs.gov 15 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security OIG Analysis: We consider the recommendation open and resolved.

We will close the recommendation when CBP provides documentation demonstrating that it has developed and implemented guidance to ensure NII utilization data is recorded in OFO systems accurately to include equipment downtime. CBP’s Response to Recommendation 4: Concur. The CBP OFO Non-Intrusive Inspection Division is considering alternative tools for data collection and reporting of equipment disruptions. Once a tool is selected, guidance will be updated as appropriate to ensure interruption data reflects the reasons for disruption.

Estimated completion date: December 31, 2025. OIG Analysis: We consider the recommendation open and resolved. We will close the recommendation when CBP provides documentation demonstrating it has updated its guidance to ensure NII operational interruption data recorded reflects the reasons for an operational disruption. www.oig.dhs.gov 16 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Appendix A: Objective, Scope, and Methodology The Department of Homeland Security Office of Inspector General was established by the Homeland Security Act of 2002 (Pub. L. No. 107−296) by amendment to the Inspector General Act of 1978.

The objective of this audit was to determine the extent to which CBP OFO’s large-scale NII systems improve detection of contraband. To answer our objective, we examined CBP’s decisions to acquire and deploy large-scale NII systems to various ports of entry and the effectiveness of the systems once they were deployed. We reviewed Federal laws and regulations and DHS and CBP policies and guidance associated with large-scale NII systems. We analyzed contracting documents, inventory records, utilization data, work orders, supplies and services orders, program goals and metrics, invoices, and site surveys.

We reviewed prior audits and reports, media reports, and congressional testimonies. We also reviewed congressional priorities outlined in the January 5, 2021, Securing America’s Ports Act. In addition, we reviewed: • DHS Report to Congress Large-Scale Non-Intrusive Inspection Scanning Plan, January 18, 2022; • CBP’s Strategy to Combat Fentanyl and Other Synthetic Drugs; • CBP Directive No. 3340-036A, Non-Intrusive Inspection (NII) Technology, July 2, 2015; • CBP’s Equipment Transactional Analysis Platform User Manual; and • the Integrated Logistics Division’s Accident/Incident/Time & Material Repair Reporting for Non-Intrusive Inspection and Radiation Detection System Policy. We interviewed officials from the DHS Science and Technology Directorate and the National Finance Center; CBP’s Laboratories and Scientific Services Interdiction Technology Branch, Integrated Logistics Division, Office of Training Development, Office of Acquisition, and Office of Professional Responsibility; CBP’s OFO Non-Intrusive Inspection Division (within its Planning, Program Analysis, and Evaluation Directorate); officials from the Department of Energy’s Pacific Northwest National Laboratory; and contractors manufacturing the large-scale NII systems.

We also interviewed Border Patrol officials from the Non-Intrusive Inspection Division and agents at four Border Patrol checkpoints in Texas including Laredo West, Falfurrias, Kingsville, and Laredo North. We conducted site visits to three CBP OFO field offices (Laredo, Texas; El Paso, Texas; and Tucson, Arizona) and 23 land ports of entry (Laredo World Trade Bridge, Texas; Colombia Solidarity Bridge in Laredo, Texas; Roma, Texas; Anzalduas, Texas; Donna, Texas; Progreso, Texas; Brownsville, Texas; Bridge of the Americas, Texas; Stanton, Texas; Paso Del Norte, Texas; Tornillo, Texas; Ysleta, Texas; Los Indios, Texas; Hidalgo, Texas; Pharr, Texas; Rio Grande City, Texas; Santa www.oig.dhs.gov 17 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Teresa, New Mexico; Nogales, Arizona; Warroad, Minnesota; International Falls, Minnesota; Calexico (East and West), California; and Otay Mesa, California). We also conducted site visits to where contractors manufactured two facilities and stored the large-scale NII systems. We assessed internal controls related to CBP’s large-scale NII system and identified internal control components and underlying internal control principles that were significant to the audit objective.

Specifically, we identified weaknesses for the control environment, risk assessment, control activities, information and communication, and monitoring control components. These internal control weaknesses are discussed in the body of this report. However, because we limited our assessment to the audit objective, the report may not have disclosed all internal control deficiencies that may have existed at the time of our audit. We analyzed data from CBP’s ETAP to determine large-scale NII system utilization rates and operational interruptions.

To assess data reliability, we interviewed an official knowledgeable about the data and reviewed information and documents about the data and the system that produced it. To assess completeness, we reviewed the data for blank and incomplete data fields. To assess accuracy, we compared 1 month of utilization data with 1 month of operational interruption data from ETAP. Based on our assessment, we concluded the data from ETAP is not sufficiently reliable.

We included examples of incomplete and inaccurate data in the audit findings and provided recommendations to strengthen the data quality. We analyzed work orders from CBP’s Asset Management System to determine how long large- scale NII systems were inoperable. To assess the accuracy and completeness of the data, we reviewed documents about the Asset Management System and interviewed knowledgeable officials about the system and the data within the system. We observed officials extract the data we requested.

Based on our assessment, we concluded the data was sufficiently reliable for the purposes of this audit. We conducted this audit from October 2023 through March 2025 pursuant to the Inspector General Act of 1978, 5 U.S.C. §§ 401–424, and according to generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

DHS OIG’s Access to DHS Information During this audit, CBP provided timely responses to our requests for information and did not delay or deny access to information we requested. www.oig.dhs.gov 18 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Appendix B: CBP Comments on the Draft Report www.oig.dhs.gov 19 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security www.oig.dhs.gov 20 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security www.oig.dhs.gov 21 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security www.oig.dhs.gov 22 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Appendix C: Port of Entry Inspection Process Using NII System Source: DHS OIG analysis based on observations and interviews with OFO officials www.oig.dhs.gov 23 OIG-25-27 LAW ENFORCEMENT SENSITIVE LAW ENFORCEMENT SENSITIVE OFFICE OF INSPECTOR GENERAL U.S. Department of Homeland Security Appendix D: Report Distribution Department of Homeland Security Secretary Deputy Secretary Chief of Staff Deputy Chiefs of Staff General Counsel Executive Secretary Director, GAO/OIG Liaison Office Under Secretary, Office of Strategy, Policy, and Plans Assistant Secretary for Office of Public Affairs Assistant Secretary for Office of Legislative Affairs CBP Audit Liaison DHS Component Liaison Office of Management and Budget Chief, Homeland Security Branch DHS OIG Budget Examiner Congress Congressional Oversight and Appropriations Committees www.oig.dhs.gov 24 OIG-25-27 LAW ENFORCEMENT SENSITIVE To view this and any other DHS OIG reports, Please visit our website: www.oig.dhs.gov Additional Information For further information or questions, please contact the DHS OIG Office of Public Affairs via email: [email protected] DHS OIG Hotline To report fraud, waste, abuse, or criminal misconduct involving U.S. Department of Homeland Security programs, personnel, and funds, please visit: www.oig.dhs.gov/hotline If you cannot access our website, please contact the hotline by phone or mail: Call: 1-800-323-8603 U.S. Mail: Department of Homeland Security Office of Inspector General, Mail Stop 0305 Attention: Hotline 245 Murray Drive SW Washington, DC 20528-0305