Nuclear Terrorism: Assessment of U.S. Strategies to Prevent, Counter, and Respond to Weapons of Mass Destruction (2024)

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7 Managing the Risks and Benefits of Radioactive Sources BOX 7-1 Summary Radioactive sources found in commonly used tools and equipment can be used in a radiological dispersal device (RDD) or a radiological exposure device (RED). As such, more attention should be directed to mobilizing and sustaining efforts to identifying technological alternatives to these materials, raising awareness of the risk, and enacting stronger measures for safeguards and security. This should include working with industry and international partners to close gaps in detecting illicit trafficking along the various pathways that terrorist groups might exploit. Highlights • Radioactive sources provide ionizing radiation for many beneficial services such as cancer treatment, blood irradiation, and sterilization, but pose a nuclear terrorism risk since these sources can be stolen and used in an RDD or RED. • The NNSA has effective programs in place to support the development and deployment of alternative technologies to replace radioactive sources taking into account the need for cost- effective devices for providing beneficial services. • Emerging technology, such as artificial intelligence and machine learning, have risks and benefits to the U.S.-led efforts to address the terrorism risk posed by RDDs and REDs. “We’ll also work together to lock down fissile and radiological material to prevent terrorist groups from acquiring or using them.” President Joseph Biden February 19, 2021 7.1 RADIOACTIVE SOURCES – RISKS AND BENEFITS FINDING 7-1: Radioactive sources provide ionizing radiation for many beneficial services such as cancer treatment, blood irradiation, sterilization, oil prospecting, medical research, calibration of dosimeters, food safety, and radiography. However, the radiological materials in these sources pose a nuclear terrorism risk since these sources can be stolen. For example, americium-241, cobalt-60, cesium-137, or iridium-192 can be extracted, and then used in radiological dispersal devices (RDD) or radiation exposure devices (RED). Radioactive sources provide ionizing radiation for many beneficial services such as cancer treatment, blood irradiation, sterilization, oil prospecting, medical research, calibration of dosimeters, food safety, and radiography. These sources are manufactured products that contain radionuclides that emit gamma rays, alpha particles, beta particles, or neutrons. The radionuclides are typically encapsulated inside the source to prevent accidental release of the Prepublication Copy 82 

Managing the Risks and Benefits of Radioactive Sources radiological material. Encapsulation can be in the form of layered stainless steel. Common radionuclides used in sources showing the half-lives and type of radiation emitted include: Americium-241 (432.2 years; principally alpha radiation with weak gamma ray; neutron radiation when combined with beryllium), Cesium-137 (30.17 years; strong gamma ray with beta radiation), Cobalt-60 (5.27 years; two strong gamma rays), Iridium-192 (74 days; beta and gamma radiation), Strontium-90 (29 years; beta radiation). There are many common, but shorter-lived isotopes used in medical diagnostics. Most radionuclides have short half-lives (typically less than several days) or have long half-lives (more than several hundred years). Short half-life materials decay rapidly and do not last long enough to pose a radiological contamination threat. Long half-life materials emit their radiation slowly and thus pose a lower radiation hazard. Of the common radionuclides used in sources, two are among the most frequently used and both present a risk should terrorist use them in an RDD or RED and are a significant security concern: cesium-137 and cobalt-60. According to the 2021 National Academies study on radioactive sources, the United States has approximately 72,000 of the higher activity Category 1 and Category 2 cobalt-60 sources, accounting for about 90 percent of all Category 1 and 2 sources in the United States; there are approximately 3,200 cesium-137 sources in these categories, accounting for about 4 percent of all such sources in the United States (National Academies of Sciences 2021) (the categories are defined below). Cobalt-60, a solid metal, is used in radiation therapy either in implants or as an external source for exposure (Jefferson Lab Resources 2023). It is also used in industry in irradiating medical instruments and in food sterilization. In addition, cobalt-60’s radiation is used in sterile insect technique for control of pests that can infect crops. Cobalt-60 teletherapy units are being phased out in high-income countries as new technologies are adopted, but remain in wide use in many low-to-middle income countries (LMIC) (Oncology Medical Physics 2023). The 2021 National Academies study identified a number of barriers to replacing cobalt-60 teletherapy in LMIC with non-radioisotopic linear accelerators (LINACs). In particular, lack of reliable electricity and access to technical resources to maintain LINACs can hinder adoption of this alternative technology. Cesium-137 is usually in the chemical form of cesium chloride, a powder-like “salt” substance that is easily dispersible if removed from its encapsulation. Cesium chloride (CsCl) is commonly used in blood irradiation and in research irradiators. Because these devices can be found in so many domestic and international locations (e.g., blood blanks), ensuring that they are adequately safeguarded is challenging. A prominent example of both the danger and security challenge that CsCl represents is highlighted in an incident that took place in Goiania, Brazil in September 1987 (International Atomic Energy Agency 1988). Two individuals, who were looking for scrap metal to sell, broke into an abandoned radiotherapy institute and stole a teletherapy unit, not knowing there was a radiological risk. The unit was accidentally damaged, breaking the encapsulated sealed source containing the CsCl, and as a result of the dispersal, four people died from radiation sickness, and more than 249 were contaminated, internally or externally. The impact resulted in more than 112,000 people needing to be monitored and tens of millions of dollars spent over three years to complete the cleanup (International Atomic Energy 1988). As noted above, CsCl is a salt-like substance, which means it can dissolve and penetrate soil and other geological materials. The cesium can also bind to concrete in buildings, raising the difficulty and cost of cleanup. This is why the risk of an RDD containing high explosive (HE) Prepublication Copy 83 

Nuclear Terrorism: Strategies to Prevent, Counter, & Respond to Weapons of Mass Destruction materials combined with the CsCl, perhaps stolen from a local blood bank, is so concerning. Should such a device be detonated in an urban environment, contaminating the buildings and critical infrastructure in the vicinity, the disruption to the community and associated economic costs could be enormous. In addition to half-life and the types of emitted radiation, the amount of radioactivity in a source is an important consideration for developing and implementing safety and security protocols. The International Atomic Energy Agency (IAEA) has developed and published a categorization scheme with five categories, Box 7-2 (International Atomic Energy 2005). Each category is defined by the potential harm to the health of people should they be exposed to radiation from an unshielded source. This harm is a deterministic effect, meaning that the health effect is observable and directly related to the ionizing radiation received by an individual person and is associated with higher doses of radiation. By contrast, a stochastic health effect is related to low doses of ionizing radiation and is probabilistic in that a particular individual may not manifest a health effect, but a large population of exposed individuals would have a certain fraction showing effects. The fraction depends on the dose received by the population. In addition to not accounting for these stochastic (probabilistic) health effects, the IAEA’s categorization scheme does not factor in economic and social disruption effects. In light of these gaps, the 2021 National Academies (National Academies of Sciences 2021) study highlighted that the IAEA and government agencies responsible for regulating sources should consider reframing the categorization scheme to include stochastic, economic, and social effects. BOX 7-2 IAEA Categories for Radiological Sources Category 1 has the safety concern that an unshielded source would likely cause permanent injury to someone who was in close contact for more than a few minutes and could be fatal for contact beyond several minutes to an hour. The thresholds of radioactivity for radionuclides in Category 1 sources are 60 Terabecquerel (TBq) for americium-241, 30 TBq for cobalt-60, 100 TBq for cesium-137, and 80 TBq for iridium-192. Examples of Category 1 sources are radioisotope thermoelectric generators, panoramic irradiators used in sterilization applications, large self-shielded irradiators used in blood and research irradiation, teletherapy, and stereotactic radiosurgery devices. Category 2 sources also pose a concern due to the potential to cause permanent injury to someone in contact with an unshielded source for many minutes to an hour and possibly fatal for contact of hours to days. The corresponding thresholds of radioactivity content are 0.6 TBq for americium-241, 0.3 TBq for cobalt-60, 1.0 TBq for cesium-137, and 0.8 TBq for iridium-192. Examples include smaller self- shielded irradiators, industrial gamma radiography, well logging devices, and calibrators. These first two categories clearly can pose a health threat and thus need strong security protection as well as safety protection. Category 3 sources are in the middle ground of unlikely to be fatal from the radiation from one unshielded source but also cross over to posing health concerns if enough Category 3 sources are aggregated to cross over to the Category 2 level. The thresholds of radioactivity content for Category 3 sources are 0.06 TBq for americium-241, 0.03 TBq for cobalt-60, 0.1 TBq for cesium-137, and 0.08 TBq for iridium-192. Examples include high- and medium-dose-rate brachytherapy, fixed industrial gauges, and well logging devices. Categories 4 and 5 sources do not contain enough radioactivity to pose significant concerns from unshielded sources. Examples include low-dose-rate brachytherapy, thickness gauges, portable gauges, bone densitometers, and smoke detectors. Prepublication Copy 84 

Managing the Risks and Benefits of Radioactive Sources A 2019 event illustrates that even a relatively small amount of radioactivity released from a larger source can generate substantial economic and disruptive effects. On May 2, 2019, International Isotopes, a subcontractor to the U.S. Department of Energy, was assigned to remove a Category 1 sealed cesium-137 source (107 TBq) from the Harborview Research and Training Facility in Washington State. This assignment was made under the National Nuclear Security Administration’s (NNSA’s) program to remove, secure, and replace higher activity cesium-137 sources. The subcontractor had difficulties in removing the source and in the process inadvertently released a small amount of cesium chloride (about 37 GBq), which is less than a Category 3 amount. The resulting contamination of the building resulted in 13 workers and observers receiving low doses no greater than 0.55 mSv. However, more than 200 researchers and laboratory staff had to be relocated. The resultant disruption of more than 80 funded research programs with budgets at tens of millions of dollars led NNSA to project that the final cost for response, recovery, remediation, and reconstruction will ultimately exceed $100 million (National Academies of Sciences 2021). 7.2 NNSA’S PROGRAMS TO REDUCE RISK FINDING 7-2: The United States maintains a robust program across several agencies and with international partners, to detect, counter, and respond to the possibility that a terrorist or terrorists could obtain and use radiological materials in a Radiological Dispersal Device (RDD) or a Radiological Exposure Device (RED). The NNSA also has effective programs in place to support the development and deployment of alternative technologies to replace radioactive sources taking into account the need to have cost effective devices for maintaining beneficial services. In the aftermath of collapse of the Soviet Union in 1991, the risk that nuclear and radiological materials might end up in the hands of criminals or terrorists was a major concern. As a result, the United States and Russia established programs to better secure facilities that held these materials and establish detection systems at border crossings should these security controls fail and traffickers tried to smuggle them out of the country. The Material Protection Control and Accounting (MPC&A) program whose mission was to protect these materials when they could not be eliminated, was one of the earliest DOE programs. DOE and NNSA also established Nuclear Security Centers of Excellence in Obninsk. In 2004, partly in response to 9/11, the Global Threat Reduction Initiative (GTRI) was launched to secure, protect and remove vulnerable nuclear and radiological materials at civilian facilities worldwide. The original structure of GTRI for radiological security was a global regional-based approach, and a separate division established for domestic work. That has evolved in the reorganization under Global Material Security (GMS). 7.3 CURRENT PROGRAMS TO REDUCE RADIOLOGICAL RISK Since the 9/11 attacks, NNSA has established a number of programs to improve the security surrounding the most significant radiological sources both in the United States and internationally. NNSA, within it protect, control, and respond program, has specific activities designed to develop security systems to protect facilities containing the highest level sources. One of those Prepublication Copy 85 

Nuclear Terrorism: Strategies to Prevent, Counter, & Respond to Weapons of Mass Destruction activities, launched in 2021, is the RadSecure 100 radiological security initiative. The objectives are to remove radiological material from facilities where feasible and improve security at the remaining facilities located in 100 metropolitan areas throughout the United States (National Nuclear Security Administration 2021). NNSA’s focal point for its radiological security programs is the Office of Radiological Security (ORS). ORS has a three-pillar strategy: (1) protection of radioactive sources in medical, research, and commercial use, (2) removal and disposition of disused sources, and (3) reduction in use of sources by promoting adoption and development of non-radioisotopic alternative technologies. For the first pillar, ORS works with partner agencies, states, local governments, and tribal nations to help implement security requirements (see more details below) through development and deployment of hardening of devices containing sources, alarming buildings, training law enforcement personnel, and tracking technologies during transportation of sources. ORS leverages the capabilities of national laboratories in these efforts with Pacific Northwest National Laboratory and Sandia National Laboratories assigned as lead laboratories. In addition, for implementing the second pillar, Los Alamos National Laboratory and Idaho National Laboratory have helped remove and secure thousands of disused and excess sources. For the third pillar, ORS has enlisted the national laboratories network to help develop technologies and provides R&D funding to companies to create alternative technologies that could replace sources. Another funding approach is to support analysis of studies that could show that an alternative technology can provide equivalent results to a radioactive source. In 2014, ORS began a highly successful program to replace cesium-137 irradiators with alternative technologies. This Cesium Irradiator Replacement Project (CIRP) offers incentives for users of these irradiators to switch to alternative technologies such as x-ray. Incentives include covering the removal and disposal costs and providing cost-share (typically 50 percent) for the purchase of the alternative. This has proven to be a powerful incentive since the disposal cost for a cesium-137 irradiator is on the order of $300,000. CIRP also includes cobalt-60 sources used in irradiators. In 2015, about 750 cesium irradiators (420 blood irradiators and 330 research irradiators) and 100 cobalt-60 (20 blood and 80 research) were identified in the United States as potentially eligible for CIRP. The 2019 National Defense Authorization Act (Section 3141) established the goal of replacing all cesium-137 blood irradiators with x-ray devices by December 31, 2027 via CIRP. Internationally, the IAEA maintains programs to assist member states in improving the security of radiological materials at facilities and transportation. It has programs to “repatriate” disused sources, no longer needed, but which still pose a risk (International Atomic Energy 2023). The IAEA in its role of issuing advice on safety and security practices to its member states has worked with these states and has published several guidance documents relevant to safety and security of radiological materials. Notably, the Code of Conduct on the Safety and Security of Radioactive Sources (revised and issued in 2004) gives a framework for effective safety and security practices throughout the lifecycle of radioactive sources (International Atomic Energy 2004). While this code is non-legally binding, member states are encouraged to implement its practices. Some experts such as Ambassador Kenneth Brill have called for making the code legally binding “to promote national accountability” in international efforts to prevent radiological terrorism (Brill and Bernhard 2020). One of the practices in the code is to track radioactive sources throughout their lifecycle; how the United States has implemented this tracking is detailed below. Prepublication Copy 86 

Managing the Risks and Benefits of Radioactive Sources The U.S. Nuclear Regulatory Commission (NRC) has responsibility for licensing and regulating civilian use of radiological materials in the United States. The regulations cover both safety and security of these materials. Regulations in 10 CFR Part 20 titled “Standards for Protection Against Radiation,” Subpart I, “Storage and Control of Licensed Material” include security requirements for all radiological materials unless specifically exempted. In response to security concerns following the 9/11 terrorist attacks, the NRC issued orders in November 2005 for licensees to provide additional security for Category 1 and 2 sources. These orders were replaced by formal regulations in 2013. These regulations in 10 CFR Part 37 titled “Physical Protection of Category 1 and 2 Quantities of Radioactive Material” specify “requirements for physical security, source monitoring, personnel background checks, facility security plan, local law enforcement protection, training, and documentation” (National Academies of Sciences 2021). Notably, Part 37 only applies to Category 1 and 2 sources, as defined by the IAEA categorization scheme. Part 37 covers lower category sources if their aggregate amounts at a facility meet or exceed the Category 2 threshold. As of 2022, 39 of the 50 U.S. states belong to the Organization of Agreement States. As such, they regulate radiological materials within their states and must meet at a minimum the NRC’s regulatory requirements and may promulgate stricter oversight of certain radiological materials. The NRC has implemented the National Source Tracking System (NSTS) that serves as a national registry of all Category 1 and 2 sources used in the United States. The sources in the NSTS are organized as discrete sources and not by device or use. Certain devices have more than one discrete source, for example, sterilization devices can have more than hundreds of cobalt-60 sources. The NRC requires licensees to update the NSTS when they transfer a source or sources to another licensee or out of the country. The NSTS is a useful mechanism for providing an understanding of the lifespan of sources within the United States. The U.S. Department of Transportation (DOT) coordinates with the NRC and the U.S. Department of Homeland Security in regulating the safe and secure transport of radiological materials in the United States. DOT and NRC have a memorandum of understanding that details roles in package review, inspection, reporting of accidents and other events, and information sharing. DOT has approved specific containers for certain types of radioactive sources. 7.4 THE EVOLVING SECURITY LANDSCAPE FINDING 7-3: The security landscape for preventing the development and use of an RDD or RED continues to be challenging. There is a growing opportunity for RDD or RED attacks due to both the increased use of radiological materials and relevant emerging technologies. At the same time, these technologies may also assist the U.S.-led efforts to address the threat posed by RDDs and REDs. Led by the NNSA’s Office of Radiological Security, the United States has a strong awareness and has instituted programs to understand both the risks and benefits of new technologies. As discussed earlier in this report, violence by far-right extremist groups has risen globally and domestically in recent years. Evidence suggests that these groups have considered and continue to have interest in the use of Chemical, Biological, Radiological and Nuclear (CBRN) weapons. One report (Fleer 2020) considered three incidents involving radiological materials. Two that received considerable coverage include the 2017 incident where Brandon Russell, the founder of Atomwaffen, was found to be in possession of explosive materials as well Prepublication Copy 87 

Nuclear Terrorism: Strategies to Prevent, Counter, & Respond to Weapons of Mass Destruction as radiological materials. In another case, James G. Cummings was found to have a cache of radiological materials in his home suitable for building a dirty bomb (Fleer 2020). Concurrently there has been the rapid development and global dispersions of new technologies that have implications for managing the RDD and RED threat. These technological developments include additive manufacturing, artificial intelligence/machine learning, quantum computing, 5G networking, Internet of things, autonomous systems and vehicles, commercial satellite imagery. Individually and in combination, these new technologies pose both risk and opportunity, i.e. they have the potential to both improve U.S. capabilities to detect adversary actions, and, alternatively, could be exploited by adversaries. To this end, DOE/NNSA’s Strategic Outlook Initiative has a pilot, enterprise-wide analytical effort underway for examining “over the horizon” technological developments that may impact DOE/NNSA’s mission (National Nuclear Security Administration and U.S. Department of Energy 2021). 7.5 UPDATE ON RADIOACTIVE SOURCE REPLACEMENTS An important approach to reducing the RDD and RED threat is to replace widely used commercial sources with alternative technologies. A major effort has been to phase out the use of high-risk cesium-137 sources, particularly in blood irradiators where x-ray technology offers an affordable replacement technology. The National Research Council (now the National Academies) made this recommendation in 2008 in a consensus study report, and the NNSA has since instituted programs such as CIRP as described above, to implement that recommendation (Council 2008) . Similarly, there have been a number of recommendations to either secure facilities with teletherapy tools containing cobalt-60, redesign those tools to build in enhanced safeguards, or find alternatives to the use of cobalt-60 (National Academies of Sciences 2021). With regard to sources that are disused and have reached their end-of-life, the NNSA has responded to the recommendations of the National Academies and the IAEA and developed programs with international partners to provide means to obtain and secure such sources (U.S. Department of Energy 2023) (International Atomic Energy 2023) . One important barrier to radioactive sources replacement efforts is that disposal costs for disused sources can be expensive especially for higher activity disused sources, and disposal facilities for these sources may not be available in many countries. In addition to known and accountable disused sources, orphan sources pose challenges because these sources are by definition outside of regulatory control and accounting systems. Thus, orphan sources are particularly vulnerable to theft or diversion to malicious non-state actors. More efforts are required to implement better regulatory and accounting systems in countries across the globe to identify end eliminate orphan sources. The IAEA has guidance on how to implement effective regulatory and accounting systems. The NRC via its international program office can also provide guidance to other countries, and the NRC can serve as a role model. It is also important to invest in efforts to procure and safely dispose of orphan sources. RECOMMENDATION 7-1: The United States, with NNSA as the lead, and in cooperation and partnership with the IAEA and other international organizations should strengthen and accelerate current national and international activities and programs for end-of-life management of sources. Such efforts should identify disused and orphan sources and ensure that there are financial guarantees for safe and secure Prepublication Copy 88 

Managing the Risks and Benefits of Radioactive Sources disposal of such materials as mentioned in a previous National Academy study (National Academies of Sciences 2021). RECOMMENDATION 7-2: The United States, with NNSA as the lead, and in cooperation and partnership with industry should continue and, where feasible, expand its efforts to phase out high-risk cesium-137 and cobalt-60 sources and by developing and deploying reliable alternative technologies such as x-ray irradiators. Where replacement is not feasible, the NNSA should continue to assess the security risks of facilities and develop security systems to reduce the risks attendant with cesium-137 and cobalt-60. During its information gathering, the committee reviewed the recommendations contained in an earlier National Academies report titled Radioactive Sources: Applications and Alternative Technologies (National Academies of Sciences 2021) and agrees that several actions suggested for implementation in that report have merit and would complement ongoing actions to enhance the security of radiological materials. These include: a. Prioritize research funding and development of alternatives for alternatives to the use of radiological materials, where no such alternatives exist but would be beneficial. b. In low-and middle-income countries where there are logistical or other barriers to deployment of alternative technologies, focus on ensuring security of radioactive sources already in use, while engaging in cooperation with such countries to address these barriers, where possible. c. Support equivalency studies for applications such as oil-well logging, research irradiation, and radiography to provide a technical basis for development of potential alternatives. The committee also noted that the prior report recommended measures related to reframing radiological source characterization schemes, domestically and internationally, to account for economic and social impacts, in addition to any deterministic effects of ionizing radiations from these sources and to extend source tracking systems for category 1 and 2 sources, to include category 3 sources. To date, such proposals have failed to secure regulatory approval with any national regulatory body, principally due to the rigors of regulatory cost benefit analyses and the challenges of regulating to public confidence and perceptions of risk. Although the committee did not hold a uniform view on adoption of these measures, the committee acknowledges the challenge of regulating to perceived levels of risk with most members seeing the merit of future consideration of source tracking measures, as changing security circumstances may warrant. References Brill, Kenneth C., and John H. Bernhard. 2020. “Preventing the preventable: Strengthening international controls to thwart radiological terrorism.” Bulletin of the Atomic Scientists 76 (4): 206-209. https://doi.org/10.1080/00963402.2020.1778371. https://doi.org/10.1080/ 00963402.2020.1778371. Prepublication Copy 89 

Nuclear Terrorism: Strategies to Prevent, Counter, & Respond to Weapons of Mass Destruction Council, National Research. 2008. Radiation Source Use and Replacement: Abbreviated Version. Washington, DC: The National Academies Press. Fleer, BreAnne K. 2020. “Radiological-weapons threats: case studies from the extreme right.” The Nonproliferation Review 27 (1-3): 225-242. https://doi.org/10.1080/10736700. 2020.1775987. https://doi.org/10.1080/10736700.2020.1775987. International Atomic Energy, Agency. 1988. The Radiological Accident in Goiânia. Vienna: IAEA. ---. 2004. Code of Conduct on the Safety and Security of Radioactive Sources. ---. 2005. Categorization of Radioactive Sources. ---. 2023. “Disused sources.” https://www.iaea.org/topics/disused-sources. International Atomic Energy Agency. 1988. The Radiological Accident in Goiânia. Vienna: IAEA. Jefferson Lab Resources. 2023. “The Element Cobalt.” It’s Elemental. https://education.jlab.org/ itselemental/ele027.html. National Academies of Sciences, Engineering, Medicine,. 2021. Radioactive Sources: Applications and Alternative Technologies. Washington, DC: The National Academies Press. National Nuclear Security Administration. 2021. NNSA launches RadSecure 100 radiological security initiative in 100 U.S. cities. National Nuclear Security Administration, and U.S. Department of Energy. 2021. Prevent, Counter, and Respond—NNSA’s Plan to Reduce Global Nuclear Threats FY 2022-FY 2026. Oncology Medical Physics. 2023. “Medical Physics Made Easy.” https://oncologymedical physics.com/. U.S. Department of Energy. 2023. “ENERGY.GOV.” https://www.energy.gov/. Prepublication Copy 90 

FIGURE 8-1 Mobile Radiation Detection and Identification System (MRDIS, orange structure in upper and lower images) allows vehicles with containers to pass through and be scanned for radioactive signatures (lower image). Photos are from an NNSA project at the port of Salalah in Oman where cargo is offloaded from large ships into smaller vessels appropriate for travel through the Suez Canal or taken off site via trucks. The project was a multi-lab project. Sandia was the system lead, LANL developed the sodium iodide collectors, and PNNL assisted in logistics. This is an example of deploying technologies to improve the visibility and accountability of containerized cargo to both deter trafficking of nuclear materials across borders, and improve the safety of commercial shipping. SOURCE: Photos courtesy of Dr. Rodney K. Wilson. Prepublication Copy 91