ML110310796

Official Exhibit - Mandatory Hearing - NRC000086-MA-BD01 - NRC Reg Issue Summary 2005-31, Control of Security-Related Sensitive Unclassified Non-Safeguards Info Handled by Individuals, Firms, and Entities Subject to NRC Regulation of the Us

ML110310796
Person / Time
Site:	Eagle Rock
Issue date:	12/22/2005
From:	Office of Nuclear Material Safety and Safeguards
To:	Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML110140706	List: ML110140709 ML110140719 ML110310796 ML110310810 RIS 2005-31, 2005/12/22-NRC Prefiled Exhibit Nrc000086, NRC Regulatory Issue Summary 2005-31, Control of Security-Related Sensitive Unclassified Non-Safeguards Information Handled by Individuals, Firms, and Entities Subject to NRC Regulation of the U RIS 2005-31, Official Exhibit - Mandatory Hearing - NRC000086-MA-BD01 - NRC Reg Issue Summary 2005-31, Control of Security-Related Sensitive Unclassified Non-Safeguards Info Handled by Individuals, Firms, and Entities Subject to NRC Regulation of the
References
70-7015-ML, ASLBP 10-899-02-ML-BD01, NRC000086, RAS 19424 RIS-05-031
Download: ML110310796 (29)

See also: RIS 2005-31

Text

Nuclear Regulatory Commission

Exhibit # - NRC000086-MA-BD01

Docket # - 07007015

Identified: 01/25/2011

Admitted: 01/25/2011 Withdrawn:

Rejected: Stricken:

NRC000086

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

WASHINGTON, D.C. 20555-0001

December 22, 2005

NRC REGULATORY ISSUE SUMMARY 2005-31

CONTROL OF SECURITY-RELATED SENSITIVE UNCLASSIFIED NON-

SAFEGUARDS INFORMATION HANDLED BY INDIVIDUALS, FIRMS,

AND ENTITIES SUBJECT TO NRC REGULATION OF THE USE OF

SOURCE, BYPRODUCT, AND SPECIAL NUCLEAR MATERIAL

ADDRESSEES

All licensees, certificate holders, applicants, and other entities (hereafter referred to as

licensees and others) subject to regulation by the U.S. Nuclear Regulatory Commission (NRC)

of the use of source, byproduct, and special nuclear material, except for those as covered by

provisions of Regulatory Issue Summary (RIS) 2005-26 for nuclear power reactors.

INTENT

This RIS sets forth procedures that licensees and others are encouraged to follow when

handling documents and/or when submitting documents to the NRC that contain security-

related sensitive information, other than classified or safeguards information, that could be

useful, or could reasonably be expected to be useful, to a terrorist in a potential attack.

Attached to this RIS are screening criteria that licensees and others should use to identify

security-related sensitive information.

No specific action nor written response is required.

BACKGROUND

NRC traditionally has given the public access to a significant amount of information about the

facilities and materials the Agency regulates. Openness has been and remains a cornerstone

of NRCs regulatory philosophy. The Atomic Energy Act, subsequent legislation, and various

NRC regulations have given the public the right to participate in the licensing and oversight

process for NRC licensees. To participate in a meaningful way, the public must have access to

information about the design and operation of regulated facilities and use of nuclear materials.

However, NRC and other Government agencies have always withheld some information from

public disclosure for reasons of security, personal privacy, or commercial or trade secret

protection.

ML053480073

RIS 2005-31

Page 2 of 5

In the post-September 11, 2001, environment, NRC, like many other agencies, has found it

necessary to be more judicious in determining what information to voluntarily release, so as not

to inadvertently provide assistance to those who might use certain information for malevolent

acts. NRC has issued orders and advisories and taken specific actions regarding the security

of its licensed facilities and has also assessed and revised its policies and practices for making

information available to the public. One of the actions NRC took was to suspend public access

to documents in its electronic Agency-wide Documents Access and Management System

(ADAMS) on October 25, 2004. Subsequently, NRC screened those documents to determine

whether they contained security-related sensitive information. Based on this screening, a large

number of documents were returned to public access in ADAMS. This screening process

continues as requests for specific documents are received and as new documents are created

by NRC and received from licensees and others.

To facilitate this screening process, NRC has developed screening criteria for conducting its

reviews. In November 2005, NRC issued guidance (NRC RIS 2005-26) for assessing whether

documents associated with reactor licensees should be made publicly available. As part of the

continuing efforts in this area, NRC has now developed the attached criteria for screening from

public disclosure security-related sensitive information associated with various NRC-regulated

activities of persons handling source, byproduct, and special nuclear material.

This RIS and its attachments do not apply to classified information or Safeguards Information.

Classified information (Confidential, Secret, Top Secret) is withheld from the public by law.

Safeguards Information is withheld because it provides details of security measures at nuclear

facilities. Handling requirements for classified information and Safeguards Information are set

forth in various NRC orders, regulations, and generic communications (e.g., requirements for

the handling and protection of Safeguards Information are discussed in RIS-2003-08,

Protection of Safeguards Information from Unauthorized Disclosure, dated April 30, 2003).

Sensitive (but unclassified, non-safeguards) information covers a range of information for which

the loss, misuse, modification, or unauthorized access can reasonably be foreseen to harm the

public interest, commercial or financial interests of an entity, the conduct of NRC and Federal

Programs, or the personal privacy of individuals. As noted above, this RIS covers security-

related information which, if released, could cause harm to the public interest as it could be

useful, or could reasonably be expected to be useful, to a terrorist in a potential attack.

Specifically, information that should be protected under this RIS is described in Attachment 2.

In addition, licensees and others should use the procedures set forth below to protect

information designated for protection by other federal, State, or local agencies.

SUMMARY OF ISSUE

This RIS:

1) Informs licensees and others of the screening criteria that NRC uses to identify and

protect security-related sensitive information in documents generated by the Agency

and in documents received from licensees and others;

2) Encourages licensees and others to identify security-related sensitive information

contained in documents submitted to NRC, by using the screening criteria in

Attachment 2 and marking procedures; and

RIS 2005-31

Page 3 of 5

3) Encourages licensees and others that may possess security-related sensitive

information to control the information, to limit the risk that the information might fall into

the hands of those who would use it for malevolent acts.

Specifically, protection of the information should be implemented in the following manner:

1. Screening of Future Documents Submitted to NRC

To assure that future submittals containing security-related sensitive information are not

made publicly available in ADAMS, while still making other appropriate information

available to the public, NRC is encouraging licensees and others to screen submittals in

accordance with the guidance in Attachment 2. If practical, documents submitted to

NRC should avoid including security-related sensitive information to permit releasing the

document to the public in its entirety.

2. Marking and Submitting Documents Containing Security-Related Sensitive Information

If it is necessary to include security-related sensitive information in a submitted

document, the submittal should be marked to indicate the presence of such information

as follows:

a) The cover letter should clearly state that the attached documents contain

security-related sensitive information. When separated from the attached

documents, if the cover letter itself does not contain security-related sensitive

information, the cover letter itself is uncontrolled.

b) As shown in Attachment 1 (Section A), the top of every page of a letter or

document that contains security-related sensitive information should include the

marking Security-Related Information Withhold Under 10 CFR 2.390 (note

that NRCs procedure for these documents is to mark them as Official Use Only

- Security-Related Information). For the pages having security-related sensitive

information, an additional marking (e.g., an editorial notebox) should be included

adjacent to the material meeting the screening criteria in Attachment 2.

Information on suggested handling and methods of submittal of security-related

sensitive information is also contained in Attachment 1 (Section B).

Licensees and others can submit both a public and a non-public version of a document,

when security-related documents need to be submitted. The public version could have

the security-related sensitive information marked out or removed with a notation that

the information was withheld on the basis that it is Security-Related Information. This

is similar to what is sometimes done to protect proprietary information under 10 CFR

2.390, except that an affidavit is not needed. Alternatively, security-related sensitive

information could be segregated from the main body of the document and included only

in attachments to the submittal. Only the attachments containing security-related

sensitive information would be marked for withholding from public disclosure. Using this

approach, the public version need not be marked as containing security-related sensitive

information.

RIS 2005-31

Page 4 of 5

3. Protection of Security-Related Sensitive Information

Documents that contain security-related sensitive information should be protected from

public disclosure, using methods similar to that for protecting proprietary information.

To the extent practicable, any existing documents containing security-related sensitive

information that licensees or others have previously made available to the public should

be withdrawn from public access. As with proprietary information, licensees and others

should have sufficient internal controls to prevent release of information. Possible

methods to prevent the inadvertent release of security-related sensitive information

include marking documents Security-Related Information - Withhold Under 10 CFR

2.390, restricting access to electronic recordkeeping systems that contain such

information, and controlling the reproduction, distribution, and destruction of potentially

sensitive records. Licensees and others should ensure that similar controls are in place

when security-related sensitive information is provided to outside parties such as

contractors or other Government agencies, and that the information is made available

only to such parties who have a need to know the information to perform their jobs and

who are made aware of the security-related nature of the information.

This RIS, the attached screening criteria, and additional explanatory material, as appropriate,

are also posted on the NRC Web site at http://www.nrc.gov/reading-rm/sensitive-info.html)

(note that the criteria for fuel cycle facilities in this website and in this RIS supercedes

information at http://www.nrc.gov/materials/fuel-cycle-fac/review-criteria-fuel-cycle.html).

The NRC staff will interact with licensees and others on a case-by-case basis to resolve

questions regarding the application of the procedures and screening criteria set forth in this RIS

and its attachments.

NRC will continue to make available to the public as much information as possible. Much of

NRCs information is readily available to the public via the NRC Web site (www.nrc.gov) and

NRCs ADAMS system (www.nrc.gov/reading-rm/adams.html). In addition, other information

may be released to the public in response to formal and/or informal requests. Although the

security-related sensitive information screening criteria were developed with the principles of

the Freedom of Information Act (FOIA) in mind, a review for security-related sensitive

information does not substitute for a FOIA review. FOIA requests will continue to be reviewed

and processed independently from the security-related sensitive information review process.

BACKFIT DISCUSSION

This RIS requires no action nor written response and is, therefore, not a backfit under 10 CFR 70.76, 72.62, or 76.76. Consequently, the NRC staff did not perform a backfit analysis.

FEDERAL REGISTER NOTIFICATION

A notice of opportunity for public comment on this RIS was not published in the Federal

Register because it is informational and does not represent a departure from current regulatory

requirements and practice.

RIS 2005-31

Page 5 of 5

SMALL BUSINESS REGULATORY ENFORCEMENT FAIRNESS ACT OF 1996

NRC has determined that this action is not subject to the Small Business Regulatory

Enforcement Fairness Act of 1996.

PAPERWORK REDUCTION ACT STATEMENT

This RIS does not contain information collections and, therefore, is not subject to the

requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501, et seq.).

Please direct any questions about this matter to the technical contacts listed below.

/RA/

Charles L. Miller, Director

Division of Industrial and Medical

Nuclear Safety

Office of Nuclear Material Safety

and Safeguards

Technical Contacts:

Spent Fuel Storage and

Materials IMNS/Regional Transportation Fuel Cycle

Paul Goldberg, NMSS/IMNS Joe Sebrosky, NMSS/SFPO Patricia Silva, NMSS/FCSS

301-415-7842 301-415-1132 301-415-8029

E-mail: pfg@nrc.gov E-mail: jms3@nrc.gov E-mail: pas6@nrc.gov

Decommissioning HLWRS Import/Export

Ted Carter, NMSS/DWMEP Alexander Sapountzis Stephen Dembek

301-415-6668 301-415-7822 301-415-2342

E-mail: thc1@nrc.gov E-mail: aps@nrc.gov E-mail: sxd@nrc.gov

Attachments:

1. Suggested Markings; Withhold From Public Disclosure in Accordance With 10 CFR 2.390

2. NMSS Guidance on Screening Criteria for Security-Related Sensitive Unclassified Non-

Safeguards Information

3. List of Recently Issued NMSS Generic Communications

Attachment 1

RIS-2005-31

Page 1 of 2

SUGGESTED MARKINGS AND HANDLING

This attachment provides information on suggested markings for pages of a document that

contains security-related sensitive information (Section A) and suggested handling of such

documents (Section B).

A. Page Markings

Overall page marking on the top of all pages

of a document that contains security-related

sensitive information

Security-Related Information Note that a cover letter should clearly state

Withhold Under 10 CFR 2.390 that attached documents contain security-

related sensitive information - - However,

this marking is also needed on the cover

letter only if it itself contains security-

related sensitive information.

Subject

Ensure Subject Line is non-sensitive

XXXXXXXXXX

XXXXXXXXXX

XXXXXXXXXX

XXXXXXXXXX

Attachment 1

RIS-2005-31

Page 2 of 2

B. Appropriate Controls for Handling Documents

Access: Need-to-know in order to perform official licensee, applicant or

entity functions.

Storage: Openly within licensee, applicant, or other entity facilities with

electronic or other access controls, for example, key cards,

guards, alarms.

Mail: U.S. Postal Service first class mail, registered mail, express mail,

or certified mail in single opaque envelope with no external

markings to indicate 10 CFR 2.390 contents.

Electronic Transmission: Over phone if the recipient is confirmed as being

authorized to access the information; over facsimile if it is

confirmed that a recipient who is authorized to access the

information will be present to receive the transmission;

over encrypted computer e-mail (using computer software

such as SecureZip).

Note that NRC is using SecureZip when transmitting security-

related sensitive information by e-mail to licensees and others to

encrypt electronic information. Users will be prompted for a

password to access a free download of the reader.

Attachment 2

RIS 2005-31

Page 1 of 19

NMSS GUIDANCE

SCREENING CRITERIA FOR SECURITY-RELATED

SENSITIVE UNCLASSIFIED NON-SAFEGUARDS INFORMATION

DECEMBER 2005

-1-

Attachment 2

RIS 2005-31

Page 2 of 19

SCREENING CRITERIA FOR SECURITY-RELATED

SENSITIVE UNCLASSIFIED NON-SAFEGUARDS INFORMATION

DECEMBER 2005

INTRODUCTION:

This guidance provides the criteria which will be used to determine the types of security-related

sensitive information, other than classified or safeguards information, associated with materials

licensees, applicants, certificate holders, and other entities that will not be voluntarily disclosed

to the public so as not to inadvertently provide assistance to those who might wish to use this

information for malevolent acts.

BACKGROUND:

Historically, the Nuclear Regulatory Commission (NRC) has made routinely available to the

public large amounts of information, more than required by law. In the post-September 11,

2001 environment, however, like many other agencies, the NRC has found it necessary to be

more judicious in what it voluntarily releases, so as not to inadvertently provide assistance to

those who might use this information for malevolent acts.

The NRC developed guidance several months ago for conducting a broad security/sensitivity

review to assess whether documents associated with reactor licensees should be made publicly

available in the first instance as a matter of administrative discretion (SECY-04-0191). In

November 2005, the NRC issued guidance (NRC RIS 2005-26) in this area. As part of the

continuing efforts in this area, the NRC has now developed this guidance which addresses the

criteria for screening from public disclosure certain types of information associated with various

classes of materials licensees, applicants, certificate holders and other entities.

Consistent with the Task Force Report on Public Disclosure of Security-Related Information,

(SECY 05-0091) and the Commission guidance on that Task Force Report, the screening

criteria in these guidelines ...should follow the principles for withholding security-related

information under FOIA. Although the security-related sensitive screening criteria were

developed with the principles of the Freedom of Information Act (FOIA) in mind, a review for

security-related sensitive information does not substitute for a FOIA review. FOIA requests will

continue to be reviewed and processed independently from the security-related sensitive

information review process.

ORGANIZATION OF THIS GUIDANCE:

This guidance is organized as follows (see Table 1 for an outline on navigating the guidance):

- Section 1 indicates the thresholds under which documents may be released to the public

without any further screening. However, Section 1 also notes specific requirements for

withholding documents in certain cases even if the documents fall under the threshold.

- Section 2 contains general criteria for screening documents above the threshold.

Attachment 2

RIS 2005-31

Page 3 of 19

- Appendices 1 - 5 contain guidance, in addition to that in Section 2, for screening

documents specific to fuel cycle facilities; decommissioning and low-level waste sites;

medical, industrial, and academic uses of nuclear materials; spent fuel/transportation;

and export/import, respectively.

Table 1 Stakeholders Using This Guidance and Applicable Sections of the Guidance1

Stakeholder Applicable guidance

Fuel cycle facilities including milling, Sections 1 and 2 for general information and

conversion, enrichment and fuel fabrication Appendix 1.

facilities

Decommissioning and low-level waste sites Sections 1 and 2 for general information and

Appendix 2.

Medical, Industrial, and Academic Uses of Sections 1 and 2 for general information and

Nuclear Materials Appendix 3.

10 CFR Part 71: certificate holders, and Sections 1 and 2 for general information and

registered users Appendix 4, parts A, B, and E. Special

attention should be given to the guidance

relative to detailed design drawings, and

control of registered users list for

transportation packages.

10 CFR Part 71: Quality Assurance Program Sections 1 and 2 for general information and

holders Appendix 4, parts A, B, and E. Based on

NRC staff experience, most QA program

holder submittals do not contain sensitive

information as defined in this RIS. However,

attention should be given to the guidance

relative to detailed design drawings, and

control of registered users list for

transportation packages.

10 CFR Part 72: certificate holders, general Sections 1 and 2 for general information and

licensees, and site specific licensees Appendix 4, parts A, B, C, D and E.

Export and Import Sections 1 and 2 for general information and

Appendix 5.

1

With regards to High-Level Waste, requirements for making information publicly

available via the Licensing Support Network (LSN) is contained in 1O CFR Part 2 Subpart J for

an applicant of the proposed geological repository at Yucca Mountain in Nevada. Furthermore,

the "Joint DOE and NRC Sensitive Unclassified Information and Classification Guide for the

Office of Civilian Radioactive Waste Management Program" (CG-OCRWM-1) provides

guidance for determining sensitive information.

Attachment 2

RIS 2005-31

Page 4 of 19

1. NMSS THRESHOLD CRITERIA:

Documents containing information falling under these thresholds may be released without any

further screening, except as specifically noted.

A. Low Hazard: The following types of licensee files need NOT be screened due to the low

hazard of the radioactive material at the sites:

- Licensees authorized to possess quantities of radionuclides in any single location that

are below the International Atomic Energy Agencys (IAEA) Category 3 quantities (as

listed in Table 1 of these guidelines). However, documents which give the exact

location of the material should be withheld, even if they refer to material levels below

the Category 3 threshold. Thus, a document may be released if it indicates a general

location (i.e., in a certain building), but documents giving the exact location should be

withheld unless the location is intuitively obvious.

- Licensees (other than fuel cycle) authorized to possess radionuclides which are not

listed in Table 1. However, information on the exact location of this radioactive material

should be withheld.

- Uranium recovery (yellow cake and tailings only)

- Current information on decommissioning materials sites with diffuse contamination only.

(Check for other active licenses or radioactive material at the site; e. g., high activity

reactor components, and high activity waste. Screen any such documents separately.)

- Terminated licenses where all radioactivity except diffuse contamination has been

removed. (Screen old files for operational information which may contain sensitive

information.)

B. Information Readily Available to the Public Elsewhere:

Based on Reactor Criteria Approved by Commission (see SECY-04-0191):

- If the information is available from open source literature such as text books, Web sites,

or other sources, an NRC decision to withhold the information may decrease the

openness of our regulatory programs without obstructing an adversary.

- Information clearly visible from locations accessible to the public is generally released.

This includes general (low resolution) drawings of the site and adjacent areas.

Attachment 2

RIS 2005-31

Page 5 of 19

2. GENERAL CRITERIA FOR SCREENING DOCUMENTS ABOVE THE THRESHOLD

A. Descriptions of Facilities Where Licensed Material May Be Located

Criteria:

(1) Locations and quantities of radioactive material (above the thresholds listed in Table 1)

- Withhold information identifying the exact locations of radioactive material

- Withhold information on possession limits or actual inventories of radionuclides.

- Withhold manufacturers and model numbers of sealed sources and devices.

- For fuel cycle facilities, withhold information on possession limits and inventories of

enriched uranium above 6% U-235, and mixed oxide materials.

- Withhold lists of licensees registered to use NRC-approved 10 CFR Part 71

transportation packages.

- Release identification of radionuclides and form.

- Release 10 CFR Part 71 certificates and 10 CFR Part 72 information related to

radionuclide form, content, quantities, model numbers, and locations of independent

spent fuel storage installations, regardless of the quantities.

- Release event reports involving lost/stolen/abandoned/found radioactive material.

(2) Design of structures/equipment (site specific)

- Withhold information related to security requirements, information from analyses which

could reveal vulnerabilities, reports of specific or predicted failures, and any other

information which could reasonably be expected to be useful to potential adversaries.

- Release information regarding the design of structures provided to the NRC which

typically consists of analyses to show that the design feature will withstand the

combinations of forces associated with design basis events and natural hazards. The

analyses do not typically provide realistic information on the failure of structural features,

and, except for fuel cycle facilities, are not considered sensitive. However, withhold

information related to predicted structural failures that could be useful to terrorists. (See

Appendix 1 for specific guidance on fuel cycle facilities.)

(3) Nearby Facilities

- Withhold information related to nearby facilities if the information might reasonably be

helpful to those planning an attack.

B. Design Information (non-site-specific): Spent Fuel Casks, Transportation Packages,

Sealed Source and Device Catalog and Files, etc.

- Withhold drawings showing detailed design information.

- Withhold design/performance information which indicates vulnerabilities that could

reasonably be expected to be useful to potential adversaries.

- Release text information containing descriptions of how packages/devices/sources are

constructed.

Attachment 2

RIS 2005-31

Page 6 of 19

C. Emergency Planning/Fire Protection Information

- Withhold information related to emergency planning, emergency response, and fire

protection. Review any considerations and/or requests for release on a case-by-case

basis. As part of the review, check to see whether the State or local governments are

withholding related information as sensitive.

- Withhold information describing licensee or government responses to malevolent

attacks.

- Withhold information and drawings identifying locations of radioactive material, and

onsite routes and pathways to or from the locations of radioactive material.

- Withhold information which State or local government agencies have designated as

sensitive.

D. Security Program Information

- Much information related to security programs at fuel cycle facilities and other materials

facilities with high risk sources has already been designated to be withheld as

Classified, Safeguards, or Proprietary Information.

- In addition to withholding Classified, Safeguards, or Proprietary Information, withhold

any security information which could reasonably be expected to be useful to potential

adversaries.

E. Vulnerability/Security Assessments/Accident Analyses/Safety Analyses/Risk Assessments

- Release typical accident analyses which involve conservative models to demonstrate a

facilitys ability to respond to design basis events (i.e., non-security related events),

unless the analysis could reasonably be expected to be useful to an adversary.

- Withhold assessments which use a malevolent event as an initial condition

(e.g.,vulnerability/security analysis).

- Withhold descriptions of structural features related to potential malevolent attacks.

- Withhold detailed information and drawings describing the specific locations of

equipment relied upon for safety or security.

- Withhold discussions of safety features or mitigation strategies within

vulnerability/security assessments.

- Withhold any analysis that identifies which events have significant consequences and

which events don't.

- Withhold information related to security events and any information which could be

useful to an adversary due to identification of vulnerabilities.

Attachment 2

RIS 2005-31

Page 7 of 19

APPENDICES 1-5: ADDITIONAL GUIDANCE FOR SECURITY-RELATED SENSITIVE

INFORMATION SCREENING REVIEWS

These appendices contain additional guidance for screening documents for security-related

sensitive information specific to fuel cycle facilities; decommissioning and low-level waste sites;

medical, industrial, and academic uses of nuclear materials; spent fuel/transportation; and

export/import licensing. These appendices are organized as follows:

1. Fuel cycle facilities including milling, conversion, enrichment and fuel fabrication

facilities;

2. Decommissioning and low-level waste sites;

3. Medical, industrial, and academic uses of nuclear materials;

4. Spent Fuel/Transportation (10 CFR Part 71: certificate holders, and registered users;

10 CFR Part 71: Quality Assurance Program holders; 10 CFR Part 72: certificate

holders, general licensees, and site specific licensees);

5. Export/Import licensing.

Attachment 2

RIS 2005-31

Page 8 of 19

APPENDIX 1 - - FUEL CYCLE FACILITY REVIEWS (NRC CONTACT: DIVISION OF FUEL

CYCLE SAFETY AND SAFEGUARDS (FCSS), NMSS)

A. Descriptions of Facilities Where Licensed Material May Be Located

- Withhold information on possession limits or actual inventories of radionuclides, and

quantities, including such information on the license itself, for mixed oxide material and

uranium enriched to greater than 6 % U-235. (Release identification of radionuclides

and their forms.)

- Withhold information related to military contract operations, even if it is publicly available

elsewhere.

- Withhold information identifying the exact locations (e.g., detailed floor plans) of

radioactive and hazardous material whose release or theft could allow adversaries to

create a diversion for theft of material or result in a significant consequence.

Information for planning a sabotage activity (e.g., bombing a building) would likely

require less detailed information than theft where exact locations would likely be

needed.

- Withhold information about the design of structures that consists of analyses to show

that design features will withstand the forces associated with both security-related

scenarios and non-security-related scenarios, such as tornadoes, high winds, snow

loads, etc. Analyses indicating forces associated with non-security regulatory

requirements could be useful in planning terrorist activities. For instance, information

related to seismic loadings could be used to determine blast loads for bombs.

- Withhold detailed design information, including diagrams showing dimensions, material

properties, and descriptions of how the facilities/equipment is constructed. Additionally,

withhold process information that could potentially allow an adversary to access

radioactive or hazardous materials or gain knowledge of detailed information or potential

weaknesses of systems designed to ensure safe operations (necessary to prevent or

mitigate accidents) at fuel cycle facilities.

B. Design Information (non-site specific)

No additional fuel cycle facility guidance for this category.

C. Emergency Planning/Fire Protection Information

- Withhold information contained in Emergency Planning and Fire Protection Plans that

could potentially allow an adversary to gain knowledge of detailed information or

potential weaknesses of systems designed to ensure safe operations (necessary to

prevent or mitigate accidents) at fuel cycle facilities.

Attachment 2

RIS 2005-31

Page 9 of 19

- Withhold information and drawings identifying routes to or from the locations of

radioactive and hazardous material whose release or theft could allow adversaries to

achieve their goals.

- Withhold information that State or local government agencies have designated as

sensitive.

- Withhold any detailed accident analysis that identifies which accidents have significant

consequences and which accidents don't. Accident analysis information can appear in

many documents (i.e., emergency plan, fire protection plan, Integrated Safety Analysis

Summary, environmental assessment, etc.). General information may be releasable,

but details should be withheld.

D. Security Program Information

- Much information related to security programs at fuel cycle facilities and other materials

facilities with high risk sources has already been designated to be withheld as

Proprietary, Classified or Safeguards Information.

- Withhold information about security equipment and programs, descriptions of equipment

and radioactive or hazardous materials, and accident studies that bear a close

resemblance to programs, equipment, radioactive or hazardous materials, and studies

at other active licensee sites if that information would reveal vulnerabilities or be

expected to be useful to adversaries at active licensee sites.

E. Vulnerability/Security Assessments/Accident Analyses

- Withhold detailed information and drawings describing the exact locations of radioactive

or hazardous materials or gain knowledge of detailed information or potential

weaknesses of system designed to ensure safe operations (necessary to prevent or

mitigate accidents) at fuel cycle facilities.

- Withhold any detailed accident analysis which contains accident sequences, identifies

accident consequences, identifies systems and components relied upon for safety, or

identifies which accidents have significant consequences and which accidents don't.

Accident analysis information can appear in many documents (i.e., emergency plan, fire

protection plan, Integrated Safety Analysis Summary, environmental assessment, etc.).

General information may be acceptable, but details should be withheld.

- Withhold information identifying the exact locations (e.g., detailed floor plans) of

radioactive and hazardous material whose release or theft could allow adversaries

create a diversion for theft of material or result in a significant consequence.

Information for planning a sabotage activity (e.g., bombing a building) would likely

require less detailed information than theft where exact locations would likely be

needed.

Attachment 2

RIS 2005-31

Page 10 of 19

APPENDIX 2 - - DECOMMISSIONING AND LOW-LEVEL WASTE SITE REVIEWS (NRC

CONTACT: DIVISION OF DECOMMISSIONING, WASTE MANAGEMENT, AND

ENVIRONMENTAL PROTECTION (DWMEP), NMSS)

DECOMMISSIONING AND LOW-LEVEL WASTE SITE THRESHOLD CRITERIA

1. Diffuse contamination consists of soil, groundwater, surface contamination on and in

buildings, including that which is on equipment, floors, walls, etc. It also could include

volumetrically contaminated materials whose concentrations are sufficiently low.

For determining whether only diffuse contamination is present at a decommissioning

site, apply the following information derived from the IAEA Code of Conduct on the

Safety and Security of Radioactive Sources (see Table 1). Category 3 sources in the

Code of Conduct, for which NRC is developing a rulemaking to control their import and

export, are typically about 1 curie. At a concentration of 2000 pCi/gram, which is well

above the concentrations of plutonium typically found in soil at sites undergoing

decommissioning, this equates to approximately 15,000 cubic feet of material, well in

excess of what a terrorist could reasonably use for malevolent purposes. For materials

at the 10 CFR Part 61 Class A limit for plutonium (10 nCi/gram), the volume of waste

that would contain the Category 3 activity limit for plutonium would be 3000 cubic feet,

also in excess of what could reasonably be used by a terrorist. However, for Co-60, the

amount of loose material or rubble at the Class A limit (700 Ci/cubic meter) containing

the Category 3 quantity (about 1 curie) would be less than 0.1 cubic foot, an amount that

could easily be used for malevolent purposes because of its small volume.

Reviewers should apply values taking into consideration the examples given above in

making a determination on whether a decommissioning site is within the threshold limits.

2. DWMEP has little licensing work in low-level waste. However, that which is performed

may not be below the threshold. For example, import and export licensing could involve

quantities of materials that would be useful to terrorists.

GENERAL GUIDANCE FOR DECOMMISSIONING AND LOW-LEVEL WASTE SITES

Most sites undergoing decommissioning are expected to be below the threshold, so that

most licensing documents can be released. Sensitivity reviews must be conducted on

documents related to LLW storage, safety, and security systems and procedures. Reviews

should focus on determining if the information contained in these documents could be

useful to an adversary in planning a terrorist act. Examples include the location and

security arrangements for high-activity waste, the location of highly activated components,

or the transportation security arrangements for high-activity waste or activated

components.

Attachment 2

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Page 11 of 19

For fuel cycle, materials, and spent fuel pool and independent spent fuel storage

installation (ISFSI) licensees that are undergoing decommissioning, issues that are not

unique to decommissioning (such as descriptions of plant processes, vulnerability/security

assessments, etc.) should be reviewed with regard to Appendices 1, 3, and 4, respectively.

A. Descriptions of Facilities Where Licensed Material May Be Located

- Withhold information identifying the exact locations of radioactive material. For

example, detail drawings or maps of facilities, room numbers and locations, and specific

locations of waste storage/processing operations.

- Withhold design information that could reasonably be expected to be useful to potential

adversaries. Examples include detailed drawings or maps showing the locations of

security measures/operations and infrastructure, locations of critical site infrastructure

(electrical or power systems), and the design of facilities that could be useful in

developing approaches to breech the facility.

- For transportation package information provided in connection with decommissioning or

LLW disposal licensing, consider Appendix 4 for sensitivity of the information.

No additional guidance for decommissioning and low-level waste sites for other categories.

Attachment 2

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Page 12 of 19

APPENDIX 3 - - REVIEWS OF MEDICAL, INDUSTRIAL, AND ACADEMIC USERS OF

NUCLEAR MATERIALS (NRC CONTACT: DIVISION OF INDUSTRIAL AND MEDICAL

NUCLEAR SAFETY (IMNS), NMSS)

A. Descriptions of Facilities Where Licensed Material May Be Located (above the thresholds in

Table 1)

(1) Copies of Licenses and Mailing Lists

- Copies of licenses: Release authorized radionuclides and form. Withhold authorized

quantities. Withhold manufacturers and model numbers of sealed sources and devices.

Withhold information which identifies buildings or rooms where radioactive material is

located (this may be in the license condition specifying authorized location).

- Withhold mailings lists which are compiled for security purposes or identify high risk

facilities or vulnerable facilities.

- Release individual mailing addresses, and street address where material is located

(normally included on licenses).

(2) Locations of radioactive material

- Withhold lists of authorized or actual inventories of radionuclides.

- Withhold building numbers and room numbers (other than mailing addresses) or similar

information which identify locations of material.

- Withhold site drawings which identify individual buildings on the licensee site.

- Withhold building drawings which identify the location of radioactive material, or onsite

pathways or routes to and from locations of radioactive material.

- Release individual mailing addresses and street addresses.

(3) Design/description of structures/equipment/operating procedures (site specific)

- Most descriptions of structures/equipment/procedures may be released if they are not

security-related.

- Withhold drawings of buildings/rooms/devices where radioactive material is located.

- Withhold manufacturers and model numbers of sealed sources and devices.

- Withhold information on security programs, guards, access controls, key cards, alarms,

barriers, chains, locks, etc.

B. Design Information (non-site specific) - Sealed Source and Device Catalog

- Release information on addresses of manufacturers/distributors.

- Establish a password system for users with a valid need-to-know, and who have agreed

to protect the information from unauthorized disclosure.

Attachment 2

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Page 13 of 19

C. Emergency Planning/Fire Protection Information

- Release general descriptions of emergency procedures for safety related events, such

as radioactive material spills, releases, contamination, and fires.

- Withhold information on routes to and from locations of radioactive material.

- Withhold information related to responses to security events and malevolent events.

- Withhold information on responses of offsite law enforcement officials.

- Withhold information designated by State or local governments as sensitive.

D. Security Program Information

- Certain security information at specified facilities is already designated as Safeguards

Information and should continue to be withheld and protected accordingly.

- In addition to withholding Safeguards Information, withhold any security information

related to malevolent events or which could be useful to potential adversaries.

Examples as given in Section A above: information on guards, access controls, key

cards, alarms, barriers, chains, locks, etc.

E. Vulnerability/Security Assessments/Accident Analyses

- No additional guidance for medical, industrial, and academic users of nuclear material

for this category.

Attachment 2

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Page 14 of 19

APPENDIX 4 - - SPENT FUEL/TRANSPORTATION REVIEWS (NRC CONTACT: SPENT

FUEL PROJECT OFFICE (SFPO), NMSS)

A. Descriptions of Facilities Where Licensed Material Be Located

Subject Discussion and/or typical controls

10 CFR Part 72 Specific ISFSI Uncontrolled - Information provided to the NRC for

Licenses and General Licenses specific ISFSI licenses and general licenses typically

- Text descriptions of the consists of analyses to show that the design feature will

following: general description, withstand the combinations of forces associated with

site characteristics, principal design basis events and natural hazards. The analyses

design criteria, storage cask do not typically provide realistic information on the failure

design, operations, waste of structural features and are not considered sensitive.

management, radiation

protection, accident analyses,

conduct of operations, operating

controls and limits, and quality

assurance

10 CFR Part 72 Specific ISFSI Potentially Controlled - Decisions regarding the control of

Licenses and General Licenses information that show the plant site and buildings are

- Drawings and locations of dependent on the level of detail. Information clearly

related hazards visible from locations accessible to the public near the site

is generally released. This includes general (low-

resolution) layout drawings of the site and adjacent areas.

Drawings showing details such as the specific locations of

equipment within buildings, doorways, stairways, storage

areas, etc. are to be withheld under 10 CFR 2.390(d).

Drawings showing locations of hazards in relation to the

ISFSI are also withheld. A text description of the hazards

in relation to the ISFSI is uncontrolled and will not be

reviewed.

10 CFR Part 72 Specific ISFSI Controlled - Information related to non-nuclear facilities

Licenses and General Licenses located near the ISFSI such as pipeline data (usually

- Nearby industrial, withheld per DOT) and chemical facilities (some data

transportation, and military withheld per EPA) is controlled. Other information may

facilities be protected by other federal agencies (e.g., DHS, FERC,

EPA, DOT)

10 CFR Part 72 Specific ISFSI Uncontrolled - Information related to radionuclides, form,

Licenses and General Licenses and quantities

Lists of licensees registered to Withhold lists and associated letters required by 10 CFR

use NRC-approved 10 CFR Part 71.17(c)(3).

71 transportation packages.

Attachment 2

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Page 15 of 19

B. Design Information (non-site specific): Transportation Packages, and Spent Fuel Casks

Subject Discussion and/or typical controls

10 CFR Part 71 Transportation Uncontrolled - Information provided to the NRC typically

Package Descriptions Text consists of analyses to show that the design feature will

Descriptions Including withstand the combinations of forces associated with

Radionuclide Form, Content and design basis events and natural hazards. The analyses

Quantity do not typically provide realistic information on the failure

of structural features and are not considered sensitive.

Text descriptions regarding the design of transportation

packages do not need to be controlled for 3 basic

reasons: 1) Part 71 does not authorize possession of

byproduct, source or special nuclear material, 2) package

design information is required for commerce both

domestically and internationally, and 3) the information

that could reasonably be expected to be useful to

terrorists in planning or executing an attack for

transportation packages containing large quantities of

byproduct, source or special nuclear material is controlled

by other means (e.g., route controls, escort requirements,

etc., in accordance with Commission Orders, interim

compensatory measures or other applicable

requirements).

10 CFR Part 71 Drawings Potentially Controlled - Withhold diagrams showing

detailed design information. Do not withhold drawings

which have already been made public through FOIA

requests, hearings, rulemakings, or other public forums.

10 CFR Part 71 Transportation Uncontrolled - An entity wishing to use or fabricate an

Quality Assurance Program approved transportation package must submit a

Plan Descriptions description of its quality assurance program to the NRC.

This submittal is assigned a 10 CFR Part 71 docket and

reviewed and approved by the staff. The QA program

description typically does not contain the type of

information found in the generic criteria that would cause

it to be controlled. In addition, filing and approving a QA

program description does not authorize possession of

byproduct, source, or special nuclear material.

10 CFR Part 71 Package Uncontrolled

Information related to

radionuclides, form and

quantities

Attachment 2

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Page 16 of 19

Subject Discussion and/or typical controls

10 CFR Part 71 Advance NSIR has programmatic responsibility for reviewing and

Notification of Shipments of controlling this information. 10 CFR 71.97 requires

Irradiated Reactor Fuel and advance notifications to the governor of a State, or the

Nuclear Waste governors designee, of certain shipments of high-risk

radioactive material.

10 CFR Part 72 Dry Cask Uncontrolled - Information provided to the NRC typically

Storage Systems -Certificates of consists of analyses to show that the design feature will

Compliance (COC) safety withstand the combinations of forces associated with

analysis report information design basis events and natural hazards. The analyses

do not typically provide realistic information on the failure

of structural features and are not considered sensitive.

Text information in the safety analysis report including

design information is not controlled for the following

reasons: 1) the design of the casks are simple by nature

and the criteria for which they are designed are widely

known; 2) most casks designs involve storage of the

casks in open areas on concrete pads that are often

readily seen from offsite locations; and 3) this information

has been historically released to the public to support

rulemaking for approved cask designs, and other public

outreach efforts.

10 CFR Part 72 Dry Cask Potentially Controlled - Withhold diagrams showing

Storage Systems -Drawings detailed design information. Do not withhold drawings

which have already been made public through FOIA

requests, hearings, rulemakings, or other public forums.

10 CFR Part 72 Package Uncontrolled

Information related to

radionuclides, form and

quantities

Attachment 2

RIS 2005-31

Page 17 of 19

C. Emergency Planning Information

Subject Discussion and/or typical controls

10 CFR Part 72 Specific ISFSI Potentially Controlled - Incoming documents are initially

Licenses and General Licenses profiled as nonpublic - staff will review for release upon

- Emergency Planning request. Most information related to emergency planning

will not need to be designated as sensitive. Special

attention is needed to determine if information relates to

the response by a licensee or government agency to a

terrorist attack. Note that some State and local

governments consider parts of their emergency plans to

be sensitive.

D. Security Program Information

Subject Discussion and/or typical controls

10 CFR Part 72 Specific ISFSI Potentially Controlled - Information related to security

Licenses and General Licenses programs is generally designated as SGI or SGI-M and is

- Security protected in a manner similar to classified confidential

information. Security-related information within the

inspection and oversight program is withheld from public

disclosure under 10 CFR 2.390(d).

E. Vulnerability/Security Assessments/Accident Analyses/Risk Assessments

Subject Discussion and/or typical controls

Vulnerability/Security Controlled - Vulnerability/security assessments to

Assessments for: determine the ability of transportation packages, dry cask

- 10 CFR Part 71 storage systems, or ISFSIs to withstand events from

transportation package malevolent acts have been and will continue to be

designs withheld from public disclosure.

- 10 CFR Part 72 dry cask

storage systems

- 10 CFR Part 72

independent spent fuel

storage installations (ISFSI)

Attachment 2

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Page 18 of 19

APPENDIX 5 - - EXPORT/IMPORT LICENSING (NRC CONTACT: OFFICE OF

INTERNATIONAL PROGRAMS (OIP)

- Withhold information on authorized quantities or actual inventories of radionuclides,

above the thresholds in Table 1, mixed oxide materials, and enriched uranium above 6%

U-235. Release information identifying radionuclides and form.

- For quantities above the thresholds in Table 1, mixed oxide materials, and enriched

uranium above 6% U-235, withhold information on projected or actual shipment

schedules, delivery dates, date required, mode of transport, storage arrangements, or

any other related logistical information provided by the licensee in the application or

added by the NRC.

Attachment 2

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Page 19 of 19

Table 1: Radionuclide Screening Threshold Values

Radionuclide Quantity of Quantity of

Concern1 (TBq) Concern2 (Ci )

Am-241 0.06 1.6

Am-241/Be 0.06 1.6

Cf-252 0.02 0.54

Cm-244 0.05 1.4

Co-60 0.03 0.81

Cs-137 0.1 2.7

Gd-153 1 27

Ir-192 0.08 2.2

Pm-147 40 1100

Pu-238 0.06 1.6

Pu-239/Be 0.06 1.6

Se-75 0.2 5.4

Sr-90 (Y-90) 1 27

Tm-170 20 540

Yb-169 0.3 8.1

Combinations of See Footnote

radioactive materials listed Below4

above3

1

The aggregate activity of multiple, collocated sources should be included when the total

activity exceeds the quantity of concern.

2

TBq values are the regulatory standard and the Curie values are rounded to two significant

figures.

3

Radioactive materials are to be considered collocated if breaching a common physical security

barrier (e.g., a locked door at the entrance to a storage room) would allow access to the

radioactive material or devices containing the radioactive material. For sources installed in

devices, each device should be considered a separate location.

4

If several radionuclides are aggregated, the sum of the ratios of the activity of each source, I

of radionuclide, n, A(i,n), to the quantity of concern for radionuclide n, Q(n), listed for that

radionuclide exceeds one. [(aggregated source activity for radionuclide A) ÷ (quantity of

concern for radionuclide A)] + [(aggregated source activity for radionuclide B) ÷ (quantity of

concern for radionuclide B)] + etc........ >1

Attachment 3

RIS 2005-31

Page 1 of 3

Recently Issued NMSS Generic Communications

Date GC No. Subject Addressees

2/11/05 BL-05-01 Material Control and Accounting at All holders of operating licenses for

Reactors and Wet Spent Fuel nuclear power reactors, decommissioning

Storage Facilities nuclear power

reactor sites storing spent fuel in a pool,

and wet spent fuel storage sites.

11/23/05 RIS-05-24 Control of Radiation Dose to All medical licensees.

Visitors of Hospital Patients

11/14/05 RIS-05-21 Clarification of the Reporting All U.S. Nuclear Regulatory Commission

Requirements in licensees and Part 76 certificate holders

10 CFR 20.2201 authorized to possess licensed material.

11/08/05 RIS-05-27 NRC Timeliness Goals, All 10 CFR Parts 71 and 72 licensees

Prioritization of Incoming License and certificate holders.

Applications and Voluntary

Submittal of Schedule for Future

Actions for NRC Review

10/28/05 RIS-05-22 Requirements for the Physical All holders of licenses for the possession

Protection During Transportation of of special nuclear material (SNM) that

Special Nuclear Material of ship Category II and III quantities of this

Moderate and Low Strategic material.

Significance: 10 CFR Part 72 vs.

Regulatory Guide 5.59 (1983)

10/07/05 RIS-05-23 Clarification of the Physical All gamma stereotactic radiosurgery

Presence Requirement During (GSR) licensees.

Gamma Stereotactic Radiosurgery

Treatments

09/27/05 RIS-04-17, Revised Decay-in-Storage All licensees regulated under 10 CFR

Rev. 1 Provisions for the Storage of Parts 30, 32, 33, 35, 39, and 50.

Radioactive Waste Containing

Byproduct Material

08/25/05 RIS-05-18 Guidance for Establishing and All licensees, applicants for licenses,

Maintaining a Safety Conscious holders of certificates of compliance, and

Work Environment their contractors subject to NRC authority

08/10/05 RIS-05-16 Issuance of NRC Management All licensees and certificate holders.

Directive 8.17, Licensee

Complaints Against NRC

Employees

08/03/05 RIS-05-15 Reporting Requirements for All material licensees possessing

Damaged Industrial Radiographic industrial radiographic equipment,

Equipment regulated under 10 CFR Part 34.

Attachment 3

RIS 2005-31

Page 2 of 3

Date GC No. Subject Addressees

07/13/05 RIS-05-13 NRC Incident Response and the All licensees and certificate holders.

National Response Plan

07/11/05 RIS-05-12 Transportation of Radioactive Licensees authorized to possess

Material Quantities of Concern radioactive material that equals or

NRC Threat Advisory and exceeds the threshold values in the

Protective Measures System Additional Security Measures (ASM) for

transportation of Radioactive Material

Quantities of Concern (RAMQC) under

their 10 CFR Part 30, 32, 50, 70, and 71

licenses and Agreement State licensees

similarly authorized to possess such

material in such quantities under their

Agreement State licenses.

07/11/05 RIS-05-11 Requirements for Power Reactor All holders of operating licenses for

Licensees in Possession of nuclear power reactors and generally

Devices Subject to the General licensed device

License Requirements of 10 CFR vendors.

31.5

06/10/05 RIS-05-10 Performance-Based Approach for All industrial radiography licensees and

Associated Equipment in 10 CFR manufacturers and distributors of

34.20 industrial radiography equipment.

04/18/05 RIS-05-06 Reporting Requirements for All material licensees possessing

Gauges Damaged at Temporary portable gauges, regulated under 10 CFR

Job Sites Part 30.

04/14/05 RIS-05-04 Guidance on the Protection of All holders of operating licenses or

Unattended Openings that construction permits for nuclear power

Intersect a Security Boundary or reactors,

Area research and test reactors,

decommissioning reactors with fuel on

site, Category 1 fuel cycle

facilities, critical mass facilities, uranium

conversion facility, independent spent

fuel storage

installations, gaseous diffusion plants,

and certain other material licensees.

02/28/05 RIS-05-03 10 CFR Part 40 Exemptions for All persons possessing aircraft

Uranium Contained in Aircraft counterweights containing uranium under

Counterweights - Storage and the exemption in

Repair 10 CFR 40.13(c)(5).

11/17/05 IN-05-31 Potential Non-conservative Error in All licensees using the KENO V.a or

Preparing Problem-dependent KENO-VI criticality code module in

Cross Sections for use with the Version 5 of the Standardized Computer

KENO V.a or KENO-VI Criticality Analyses for Licensing Evaluation

Code (SCALE) software developed by Oak

Ridge National Laboratory (ORNL).

10/31/05 IN-05-28 Inadequate Test Procedure Fails All licensees authorized to possess a

to Detect Inoperable Criticality critical mass of special nuclear material.

Accident Alarm Horns

10/07/05 IN-05-27 Low Dose-Rate Manual All medical licensees.

Brachytheraphy Equipment

Related Medical Events

Attachment 3

RIS 2005-31

Page 3 of 3

Date GC No. Subject Addressees

07/29/05 IN-05-22 Inadequate Criticality Safety All licensees authorized to possess a

Analysis of Ventilation Systems at critical mass of special nuclear material.

Fuel Cycle Facilities

06/23/05 IN-05-17 Manual Brachytherapy Source All medical licensees authorized to

Jamming possess a Mick applicator.

05/17/05 IN-05-13 Potential Non-conservative Error in All licensees using the Keno-V.a criticality

Modeling Geometric Regions in code module in Standardized Computer

the Analyses for Licensing Evaluation

Keno-v.a Criticality Code (SCALE) software developed by Oak

Ridge National Laboratory (ORNL)

05/17/05 IN-05-12 Excessively Large Criticality Safety All licensees authorized to possess a

Limits Fail to Provide Double critical mass of special nuclear material.

Contingency at Fuel Cycle Facility

04/07/05 IN-05-10 Changes to 10 CFR Part 71 All 10 CFR Part 71 licensees and

Packages certificate holders.

040/01/05 IN-05-07 Results of HEMYC Electrical All holders of operating licenses for

Raceway Fire Barrier System Full nuclear power reactors, except those who

Scale Fire Testing have

permanently ceased operations and have

certified that fuel has been permanently

removed

from the reactor vessel, and fuel facilities

licensees.

03/10/05 IN-05-05 Improving Material Control and All licensees authorized to possess a

Accountability Interface with critical mass of special nuclear material.

Criticality Safety Activities at Fuel

Cycle Facilities

Note: NRC generic communications may be found on the NRC public website at

http://www.nrc.gov, under Electronic Reading Room/Document Collections.